BeWell Privacy Notice
This BeWell Privacy Notice supplements the Stanford University Online Privacy Policy and applies to the personal information that Stanford University’s BeWell program collects and uses when individuals access the BeWell website (bewell.stanford.edu), BeWell mobile application or participate in the BeWell Programs and activities. This Notice describes how this information is processed and the choices that are available to you regarding the use of the personal information you provide.
If you are participating in our Healthy Living Programs, please see our Healthy Living Privacy Notice.
Information Collected and Used
Personal information is any information related to an identified or identifiable individual. We are committed to protecting your privacy, and we will only use your personal information that you provide for the purpose of providing you resources to improve your health, for the strategic planning, administration and evaluation of our wellness programs and benefits offerings, and for gaining an understanding through analysis of de-identified data of the well-being of our employee population.
As part of the BeWell Programs and activities, we may collect your name, organization, university employee ID, age, date of birth, location, email address, contact information, gender, gender identity, time zone, lifestyle behaviors, physical activity, attitudes, screening data, behavioral action plans and other health information. Individuals who sign up for Lifestyle Coaching, BeWell Check-in and Follow-up will be directed to schedule their appointments and answer intake questions using third-party platforms such as Squarespace and Qualtrics; session notes are stored in a third-party platform.
The BeWell incentive program website and mobile application are hosted by a third party, Virgin Pulse digital platform. When you access the Virgin Pulse digital platform, your name, gender, date of birth (DOB), Employee ID, email address, organization, business unit, department, hire date, office location, employee type, and union status are automatically sent to Virgin Pulse and compared to an eligibility file provided by Stanford University to confirm eligibility to access the website.
If you participate in Healthy Living, Lifestyle Coaching, BeWell Check-in, BeWell Follow-up or Stanford Recreation and Wellness offerings, employee name, Employee ID, activity and activity completion date would then be shared with Virgin Pulse for the purposes of granting participation credit. Please refer to Stanford Recreation and Wellness Terms of Use for more information on how they use data. If you participate in our surveys, we may collect personal information such as age, phone number, gender, demographic variables, lifestyle behaviors, attitudes, and other health information.
For purposes of administration and management of the BeWell Program, BeWell may access human resources information regarding University employees, including your employee ID, job type, union status, job location, gender, organization unit and department. We also collect personal information that you voluntarily submit to us whether directly on our website or when you otherwise contact us (e.g., by phone or email).
In addition, employee name, Employee ID, email address, BeWell participation, incentive, program and health assessment data will be shared with a third-party service partner who will merge such data with other healthcare claims data. The combined data is then de-identified and will be used by BeWell and their service partners for the purposes of evaluating and designing benefits, reporting, research, and publication (in aggregate form) on the health of the Stanford population and the effectiveness of the BeWell Programs and activities.
How We Use Your Information
We may use your personal information to administer, manage and evaluate the BeWell Programs, including for the following purposes:
(a) To evaluate your health results and suggest appropriate health promotion resources to you, on campus, with your medical plan, or through other providers.
(b) To allow you to access the BeWell website and health education materials and programs.
(c) To tailor health promotion surveys and programs for you and to provide information and initiatives related to health or wellness. For these purposes, your name, email address, Employee ID, SUNet ID, location, and department may be sent to an outside email service to send emails and track activity of these emails.
(d) To issue monetary rewards and to track program participation as part of the BeWell Employee Incentive Program.
(e) To solicit feedback about the BeWell Programs, evaluate the effectiveness of behavior change and health promotion programs, and suggest and plan future health programming and benefits design at Stanford University.
(f) To gain an understanding of the health and well-being of the Stanford University population as a whole, as well as subgroups, and to understand the factors that impact well-being.
(g) To apply for funding that will help promote health.
(h) To provide you surveys to evaluate our offerings.
Authentication and tracking logs will be used to produce usage statistics and identify potential website improvements. This information does not contain any personally identifiable information.
Your personal information is only used for the intended purposes as described above and only collected and processed based on a legitimate purpose and in compliance with legal and regulatory obligations. Your consent will be requested before we process your personal information for any additional purposes not described in this Privacy Notice.
Access and Data Transfer
Except as provided herein, BeWell will not share your personal information with third parties unless you have consented. We only share your personal information with third parties in connection with our programs and activities. BeWell Programs is hosted by Virgin Pulse digital platforms in the United States (US). By accessing the platform, Virgin Pulse will collect and only process your personal information for the purposes described above.
If you are located outside the US and you access and use the BeWell site or Virgin Pulse digital platform, then your personal information is transferred to the US. Please see Stanford’s Online Privacy Policy on how we protect your personal information and ensure lawful grounds are used for transferring of personal information to the US.
Minor Information
The BeWell website and Virgin Pulse digital platform are not intended to be used by persons under the age of 16. BeWell does not knowingly collect personal information from such persons through this website, BeWell Programs and activities or through Virgin Pulse digital platform. If BeWell becomes aware that a person under the age of 16 has provided personal information, we will take appropriate actions to stop processing and remove their personal information.
How We Protect Your Personal Information
BeWell is committed to protecting the security of your personal information. We maintain safeguards to protect the security, integrity, and privacy of your data. BeWell limits who has access to your personal information and provides access to only those who need it for legitimate reasons, as disclosed above, or as required by law. For more information, refer to the central Stanford Online Privacy Policy.
The BeWell website contains links to programs and websites outside Stanford, including Virgin Pulse digital platform. When following a link to an external website, the terms of that website’s privacy policy and terms of use will govern use of your personal information. Read Virgin Pulse’s Wellness Program Member Privacy Notice, Wellness Program Membership Agreement, and GINA/PHI Notice.
Your Choices
Your choice to use the BeWell website and participate in BeWell activities is completely voluntary. But if you choose not to use the BeWell website, you will be unable to participate in the BeWell Program.
Stanford University and BeWell is committed to facilitate exercising your rights as granted by applicable data protection laws such as the General Data Protection Regulation (GDPR). Please see the Stanford University Online Privacy Policy and specific section on exercising your rights regarding personal information Stanford has of you.
Reviewing and Updating Your Personal Information
You may access, and in some cases, edit your user information on the Virgin Pulse website, as described in their Wellness Program Member Privacy Notice.
You may also request removal of records from the Virgin Pulse platform by emailing PrivacyOfficer@VirginPulse.com or by logging into the digital platform and navigating to “Manage Your Data” on “My Profile” to submit this request. You may also submit any questions or concerns to the BeWell team by emailing bewell@stanford.edu. Please do not include any sensitive information or personal health information in an email.
Changes to This Privacy Notice
We may update this Privacy Notice periodically to reflect any material changes in our programs and practices. These changes will become effective when posted to our website at bewell.stanford.edu, as of the effective date listed below. Our use of personal information is subject to the version of the Notice in effect at the time such information is used.
Contacting Us
If you would like to send us a request, or if you have any other questions or concerns regarding this Privacy Notice, you may contact us by email at bewell@stanford.edu or call us at 650-721-2984.
Effective Date
This notice is effective as of January 4, 2023.