HealthNet, Inc. Comprehensive Employment Privacy and Background Investigation Policy


I. Purpose

HealthNet, Inc. ("HealthNet") is committed to safeguarding the confidentiality, integrity, and lawful use of all personal and employment-related data collected throughout the hiring process and during employment. This consolidated policy outlines HealthNet's practices regarding the collection, use, disclosure, and protection of applicant and team member information. It also addresses procedures for background investigations and personnel file confidentiality in accordance with applicable laws, including the Indiana Consumer Data Protection Act (ICDPA).


II. Scope

This policy applies to all HealthNet employees (“team members”), individuals applying for employment with HealthNet, including permanent, temporary, contract roles, and participants in educational or clinical programs affiliated with HealthNet.


III. Collection and Use of Applicant Data

When you apply for employment with HealthNet, we collect your personal information for purposes such as:

1. Identifying and evaluating employment candidates.

2. Conducting background checks.

3. Managing recruitment process.

4. Complying with federal and state requirements.

5. Supporting diversity, equity, and include initiatives.

Types of Information Collected:

1. Contact details (name, address, email, phone number)

2. Employment and education history

3. Job preferences, licenses, certifications

4. Skills, references, resume, and transcripts

5. Language proficiencies

6. Criminal history and motor vehicle records (where applicable)

7. Personal identifiers (e.g., Social Security Number for verification)

8. Any other information voluntarily provided.

Legal Basis for Processing:

Under the Indiana Consumer Data Protection Act (ICDPA), HealthNet processes personal data on the following legal bases:

1. The necessity of processing for employment purposes

2. Consent of the applicant

3. Compliance with legal obligations

4. Legitimate interests of HealthNet in maintaining workplace safety and integrity
 

IV. Data Privacy Notice and Consent

By submitting your application to HealthNet you:

1. Consent to the collection, use, and disclosure of your personal information as described in this policy.

2. Certify that all submitted information is accurate.

3. Understand that misrepresentation may result in disqualification or dismissal.
 

HealthNet will retain applicant data in accordance with this policy and applicable law. If you are not selected for a position, your information may be retained for consideration for future opportunities, subject to your consent.


V. Applicant Rights Under the Indiana Consumer Data Protection Act include:

1. Access to your personal data

2. Correct inaccuracies in your personal data

3. Request deletion of your personal data

4. Receiving data in portable format

5. The right to opt out of targeted advertising or data sales (Note: HealthNet does not engage in either).

To exercise these rights, contact Human Resources at hr@indyhealthnet.org. If your request regarding your personal data is denied, you have the right to appeal. Appeals should be submitted to Human Resources and you will receive a response within 60 days. For privacy-related inquiries or to exercise your data rights, contact HealthNet’s compliance line at 1-888-892-9224 or contact the Chief Compliance Officer at 317-957-2042.


VI. Background Investigation Policy

HealthNet performs background checks on all applicants before a final offer is made to promote a safe environment for patients, team members, and visitors. Applicants are notified in advance and provided with Fair Credit Reporting Act (FCRA) disclosures.

Investigations include but are not limited to:

1. Social Security Verification

2. National Criminal Radar Search

3. Seven-Year County Criminal History

4. Indiana State Court Records

5. FACIS Level 3 Search

6. License and Education Verification (as needed)

7. Motor Vehicle Records (if required)

Review and Decision:

1. A criminal record does not automatically disqualify an applicant.

2. Suitability is assessed based on:

a. Nature and relevance of the offense

b. Time elapsed since the offense.

c. Number of offenses

d. Risk posed to HealthNet and its stakeholders.

If adverse action is considered based on background check results:

1. The applicant will be notified and provided a copy of the report and this policy.

2. The applicant may dispute the accuracy or relevance of the findings before a final decision is made.

Existing team members must report any arrests or convictions during their employment to Human Resources.


VII. Safeguards and Security

HealthNet conducts Data Protection Assessments (DPAs) for high-risk processing activities, including background checks and processing of sensitive personal information, in compliance with the Indiana Consumer Data Protection Act.


VIII. Confidentiality of Personnel Records and Access

HealthNet maintains the confidentiality of all personnel records. Employment details such as job title, dates of employment, and employment status (active or terminated) may be disclosed, but no further information will be released without a subpoena or other legal requirement, subject to review by HealthNet’s legal counsel.

Access Rights:

1. Team members may view their own official personnel file upon request.

2. Personnel records are accessible only to authorized personnel within the Senior Leadership Team, Human Resources, legal counsel, or relevant management, especially in transfer scenarios.

Third-Party Requests:

1. Written authorization is required for the release of payroll or employment information for purposes such as credit checks, mortgages, or loans. Requests should be directed to hr@indyhealthnet.org.

 Any exceptions to this policy must be approved by the Chief Administrative Officer or their designee.


IX. Equal Opportunity Statement

HealthNet is an Equal Opportunity Employer and prohibits discrimination based on race, religion, color, national origin, ancestry, citizenship, sex, gender identity, sexual orientation, marital status, veteran status, age, disability, genetic information, or any other status protected under federal, state, or local law.


X. Policy Updates and Revisions

This policy may be updated from time to time. Any material changes will be communicated through HealthNet’s official channels. No changes will reduce your rights without your explicit consent where required by law.