Privacy Policy
SCOPE
This policy is applicable to all applicants, employees, independent contractors and former employees.
PURPOSE
Hematology Oncology Associates of CNY (HOACNY) is committed to protecting the privacy and security of your personal information while you are an applicant, employee and after your employment ends for any reason. HOACNY manages the collection, use, and disclosure of personal information in accordance with applicable data protection and privacy laws in the jurisdictions in which we have employees. This Privacy Notice applies to all employees and former employees, independent contractors, and job applicants of the HOACNY. It also applies to all personal information that we collect, use, and disclose regarding your emergency contacts and beneficiaries and by providing such information you confirm that you have permission to provide such information to us.
POLICY & PROCEDURES
HOACNY collects information that may be “personal information” according to applicable law. Subject to applicable law, this information may include information that identifies you, your household, your device, or that is reasonably capable of being connected with or linked to you, your household, or your device ("Personal Information"). HOACNY only collects Personal Information that is necessary for operating its business, which may include the following:
• Identifiers
o First and last name
o Email address
o Mailing address
o Phone number
o Birth date
o Place of birth
o Social Security Number / Social Insurance Number
o Driver's license Number
o Passport and other government identification numbers
o Employee photos for identification badges and system profiles
o Emergency contact information including relationship to employee
o Dependent and beneficiary information
• Characteristics of Protected Classifications
o information regarding minority, veteran, age, gender, religious, and disability status (which may vary from jurisdiction to jurisdiction)
• Commercial Information
o Bank routing and deposit information
• Internet or Other Electronic Network Activity Information
o Cookies
o Domain name
o Browser type
o Operating system
o Usage data
• Geolocation Data
o Information that tells us from where you access our website if you are applying for a job or working remotely
o Information that tells us where Company work vehicles are located
• Professional or Employment-Related Information
o Resumé/CV
o Job title, job status, department, and job code
o Work authorization status and related documents not otherwise listed
o Withholding tax information
o Dependent and beneficiary information
o Pay information such as pay rate, lump sum payments, and payroll deduction information
o Direct deposit information
o 401(k) loan information
o Leave of absence information
o Other information necessary to administer benefits
o Performance management information such as employment status (full-time or part-time, regular or temporary), work schedule, job assignments, hours worked, business travel information, accomplishments and awards, training and development information, performance evaluation information, discipline and counselling information, and employment termination information
o HIPAA approved medical record set
o Health and safety information such as health condition, job restrictions, drug testing information, workplace accident and illness information, and health insurance information
o Employment history
o Background check information
o Information relevant to securities law disclosures
• Non-public Education Information
o Educational information relevant to hiring qualifications
• Inferences Drawn from Other Personal Information
o Performance management information derived from other information above.
Personal Employee Information
To the extent permitted by applicable privacy legislation, HOACNY may collect, use or disclose Personal Information of any potential, current or former employee without their consent for the purposes of establishing, managing or terminating the employment relationship, or managing the post-employment relationship. As required and necessary, HOACNY will provide you with notice that your Personal Information will be collected, used or disclosed, including the purposes for which such information will be collected, used or disclosed.
Your Personal Information may be collected, used, and disclosed for purposes including, but not limited to:
• in the case of an emergency;
• hiring, promotion and compensation;
• compliance with legal requirements and obligations;
• compliance with requirements of applicable professional governing bodies;
• provision and administration of health and welfare benefits and programs;
• human resources and payroll administration;
• professional development and performance management; and
• enforcement of the HOACNY’s policies and procedures.
Categories of Sources of Personal Information
We generally collect information from the following sources:
• Directly from you. For example, when you provide information to us when applying for a job or using our employee on-boarding processes. We also collect information about dependents and beneficiaries directly from you.
• From third parties. For example, we collect certain identifiers and employment related information from recruiters and companies that we use to perform background checks. We also collect information from job candidates through our HRIS system.
HOACNY will seek your consent to collect, use or disclose Personal Information, but may do so without your consent if doing so is authorized or required by law. HOACNY may imply consent in cases where you volunteer information for an obvious purpose.
You may withdraw your consent to the use and disclosure of Personal Information at any time unless the Personal Information is necessary to fulfill HOACNY’s legal obligations. The withdrawal of your consent to the use and disclosure of Personal Information may mean that the Company will not be able to provide you with certain benefits, etc.
How We Use Your Personal Information
• We use all of the above information to onboard new employees, comply with applicable laws, comply with government requests for information, meet our contractual obligations and to initiate or respond to legal claims.
• We use Identifiers, Internet or Other Electronic Network Activity Information, Geolocation Data, Professional or Employment-Related Information, and Inferences Drawn from Other Personal Information to perform human resource functions, manage your employment and administer benefits.
• We use Identifiers, account information, and Professional or Employment Related Information to administer payroll, reimbursements, and benefits and to provide work-related items such as payment cards and access cards.
• We use Characteristics of Protected Classifications to implement our diversity programs and to comply with applicable laws.
• We use Professional or Employment-Related Information such as health and safety Information to maintain a safe workplace, assess your working capacity, to establish, manage, or terminate the employment relationship or manage the post-employment relationship, administer health and Workers’ Compensation insurance programs, and comply with applicable laws.
• We use Identifiers and Biometric Information to ensure that employees properly log-in to our equipment and ensure that only authorized employees have access to secured locations of HOACNY.
• We use Internet or Other Electronic Network Information to protect HOACNY, patients, and employee property, equipment, and confidential information; monitor employee performance; and enforce HOACNY’s electronic communications acceptable use policies.
HOACNY protects Personal Information in a manner appropriate to the sensitivity of the information. HOACNY will make every reasonable effort to prevent loss, misuse, disclosure, copying, modification, disposal or destruction of Personal Information or any unauthorized access to Personal Information. Access to your Personal Information is limited to those individuals who require such Personal Information to carry out their responsibilities.
HAOCNY will retain Personal Information only for as long as is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes and will employ appropriate measures to render Personal Information non-identifying or destroy Personal Information, including shredding paper records and permanently deleting electronic records, once the information is no longer necessary
How We Share Your Personal Information
We share Personal Information in each of the above categories as follows:
• All categories of Personal Information
o We will share Personal Information in all the above categories in connection with a law enforcement request that is compliant with applicable laws.
• Identifiers, Internet or Other Electronic Network Activity Information, Geolocation Data, and Professional or Employment-Related Information
o We share this Personal Information to service providers who use such information only to provide services to us such as sending postal mail or email, processing job applications, administering benefits, recruiting, background checks, administering HR and payroll services and processing data.
o We share some of this Personal Information with our security service providers to protect the HOACNY’s property, equipment, and people.
o Workers’ Compensation vendors will receive no more than name, address, date of birth, gender, income, age, marital status, and email addresses.
HOACNY may disclose Personal Information in special cases. For example, when we believe that we must disclose information to identify, contact, investigate or bring legal action against someone who may be violating applicable laws, policies and procedures including the Acceptable Use of Technology and Social Media Policy or Code of Business Ethics (as applicable), or may be causing injury to or interference with our rights or property, other website users or patients and their information, or anyone else who may be harmed by such activities.
We may disclose access or monitor your Personal Information when we believe
in good faith that applicable law requires it and for administrative and other purposes that we deem necessary to maintain, improve our services and our information security.
Additionally, HOACNY may disclose Personal Information to other third-party service providers for the purposes of providing services or functions on behalf of the HOACNY. Personal Information will not be disclosed to such third-party service providers except as described in this Privacy Notice, with your consent or as required or permitted by applicable law. HOACNY will endeavor to ensure that its contracts with third party service providers limit the retention, use and disclosure of Personal Information by the third-party service provider solely for the purpose of carrying out the contracted services and provide a level of protection for Personal Information that is comparable to that provided by HOACNY.
Violations of this Privacy Notice
If you become aware of a material breach in Personal Information or confidential information, you should immediately report the incident to management. HOACNY has the responsibility to investigate the incident and take corrective action. Violations of this Privacy Notice should be reported immediately to management. Any employee found in violation of this Privacy Notice will be subject to disciplinary action including discharge for just cause. Violation may also result in criminal and civil liability. None of the statements included in this Privacy Notice are intended to limit or restrict any protected rights under the U.S. National Labor Relations Act or other applicable law.
Who Do I Contact for More Information?
If you have any questions or concerns regarding this Privacy Notice or the collection of your personal information, please contact a member of the Compliance team.
You may access your Personal Information in HOACNY’s custody or control, subject to certain exceptions. For example, applicable law may prohibit access to information that may contain Personal Information about another person or confidential business information. If refusing a request in whole or in part, HOACNY will provide the reasons for the refusal, as may be required by applicable law. In some cases where exceptions to access apply, HOACNY may withhold that information and provide the remainder of the information.
You may make a request for access to your Personal Information by writing to Human Resources. Sufficient information must be provided in the access request to allow HAOCNY to identify the information you are seeking. You may also request information about the HOACNY’s use of your Personal Information and any disclosure of that information to persons outside the organization.
Additionally, you may request a correction if there is an error or omission in your Personal Information.
If you are not satisfied with a response or you have a complaint, you may contact the Chief Quality Officer.