Effective date: September 22, 2026
Last reviewed: September 22, 2026
This Corporate Wellness and Screening Privacy Notice explains how Welgen Global Enterprises, LLC, doing business as Welgen One (“Welgen One,” “we,” “us,” or “our”), may collect, use, disclose, retain, and protect information when you participate in a corporate wellness, employee health, biometric screening, preventive health, disease-management, remote monitoring, or related program.
This notice applies to programs offered through Welgen One on behalf of an employer, group health plan, benefits administrator, insurer, program sponsor, or other organization.
This notice supplements Welgen One’s Privacy Policy and, when protected health information is involved, our Notice of Privacy Practices.
A particular employer, health plan, insurer, or program sponsor may provide an additional program notice describing the specific services, incentives, eligibility requirements, and information practices applicable to that program.
1. Program Purpose
Corporate wellness and screening programs may be designed to:
- Provide preventive health screenings
- Help participants understand potential health risks
- Connect participants with appropriate educational resources
- Encourage healthy behaviors
- Support disease prevention and health management
- Provide remote monitoring or patient engagement services
- Identify population-level health trends
- Help program sponsors evaluate and improve wellness offerings
A wellness screening is not necessarily a medical diagnosis and does not replace evaluation by a qualified healthcare professional.
2. Program Participation
Participation requirements depend on the specific program and the laws that apply to it.
When participation is described as voluntary, you may choose whether to participate, subject to any program-specific eligibility, incentive, or benefit terms disclosed to you.
Declining to participate in a voluntary wellness program should not result in unlawful retaliation, discharge, discipline, or denial of access to health benefits.
An employer or program sponsor may offer an incentive for participation or completion of certain activities when permitted by law. Any applicable incentive, alternative standard, deadline, or consequence of nonparticipation should be explained in the program-specific materials.
3. Information We May Collect
The information collected depends on the particular screening or wellness program.
Identification and Contact Information
We may collect:
- Name
- Date of birth
- Participant or employee identification number
- Email address
- Telephone number
- Mailing address
- Employer or sponsoring organization
- Health-plan or program information
- Preferred language and communication preferences
Health and Screening Information
Depending on the program, we may collect:
- Health-risk assessment responses
- Medical history voluntarily provided by the participant
- Medication and allergy information
- Height, weight, body mass index, or waist measurement
- Blood pressure, pulse, or oxygen saturation
- Blood glucose, hemoglobin A1c, cholesterol, triglycerides, or other laboratory results
- Lifestyle, nutrition, activity, sleep, tobacco-use, or stress information
- Screening results and risk categories
- Information from a connected device or remote monitoring platform
- Follow-up recommendations and participant communications
The exact measurements, tests, and questions used in a program should be disclosed through the applicable registration, consent, screening, or program materials.
Program Participation Information
We may collect or create records showing:
- Registration or enrollment status
- Attendance
- Completion of a screening or program activity
- Eligibility for an incentive
- Completion of an alternative standard
- Appointment and scheduling information
- Communication preferences
Website and Technical Information
If you register or participate through a website, application, portal, or connected device, we may collect limited technical information such as browser type, device type, Internet Protocol address, login activity, system performance, and security information.
Additional information about website technologies is available in our Cookie Policy.
4. Genetic Information and Family Medical History
Genetic information can include genetic test results, family medical history, requests for genetic services, participation in genetic research, and genetic information about a fetus or embryo.
Unless a program specifically and lawfully requests genetic information through a voluntary process with any required notice and authorization, you should not provide family medical history or genetic test information in a general corporate wellness questionnaire or screening form.
Welgen One will handle genetic information in accordance with applicable law, including confidentiality and disclosure restrictions where the Genetic Information Nondiscrimination Act applies.
5. How We May Use Information
Welgen One may use participant information to:
- Register participants and confirm eligibility
- Schedule and provide screenings or wellness services
- Verify participant identity
- Provide individual screening results
- Explain results and recommended follow-up
- Coordinate clinically appropriate services
- Communicate about appointments and program activities
- Administer incentives or confirm activity completion
- Process payment or insurance information when applicable
- Operate, secure, and improve the program
- Evaluate program participation and effectiveness
- Create aggregate, statistical, or de-identified reports
- Comply with legal, regulatory, contractual, and professional obligations
- Respond to safety concerns or suspected fraud
Welgen One will not use protected health information for employment decisions on behalf of an employer unless the use is specifically authorized or otherwise permitted by applicable law.
6. Your Individual Results
You may receive individual results through a secure portal, written report, in-person consultation, telephone call, or another approved communication method.
You are responsible for reviewing your results and following any recommendation to seek medical evaluation or follow-up care.
Screening results may identify a potential health concern but do not necessarily establish or exclude a diagnosis.
Seek prompt medical attention if your results or symptoms indicate a potentially urgent concern. Do not wait for a wellness program representative to contact you if you believe you need immediate care.
7. Information Provided to an Employer or Program Sponsor
Unless you provide a legally valid authorization or another law specifically permits or requires disclosure, Welgen One does not provide your employer with your individual medical history, screening measurements, laboratory values, diagnosis, medication information, or detailed health-risk assessment responses.
An employer or program sponsor may receive limited administrative information necessary to operate the program, such as:
- Whether you were eligible to participate
- Whether you registered
- Whether you attended or completed a required activity
- Whether you satisfied an incentive requirement
- Information necessary to administer a reasonable alternative standard
Administrative completion information should not include detailed medical findings unless disclosure is specifically authorized or otherwise permitted by law.
Welgen One may also provide an employer, group health plan, insurer, or program sponsor with aggregate or de-identified reports describing population-level results.
Aggregate reports may include information such as participation rates, general risk categories, or group-level health trends. These reports should not reasonably identify an individual participant.
Welgen One will use a minimum reporting group of [INSERT MINIMUM GROUP SIZE] participants before presenting segmented aggregate results, unless a different legally compliant threshold is documented in the applicable program agreement.
Categories may be combined, suppressed, or omitted when reporting a small group could reasonably identify a participant.
8. Important Employer Disclosure Exceptions
Individual information may be disclosed to an employer or program sponsor when:
- You provide a legally valid written authorization
- Disclosure is required by law
- The information concerns a work-related injury or workers’ compensation matter and disclosure is legally permitted
- The service is an occupational health, fitness-for-duty, drug-testing, or safety-related service and the permitted disclosure was explained in advance
- The employer is performing lawful group health-plan administration functions and applicable privacy requirements have been satisfied
- The information is needed to address a serious and imminent threat to health or safety and disclosure is permitted by law
If a program includes occupational health, workers’ compensation, fitness-for-duty, or mandatory employment testing, the program-specific notice should clearly explain what information may be reported to the employer.
9. Group Health Plan Programs
If a wellness program is offered as part of an employer-sponsored group health plan, individually identifiable health information collected through the program may be protected health information under HIPAA.
In that situation, information may be used or disclosed by the group health plan, Welgen One, and participating business associates as permitted by HIPAA, the plan documents, applicable agreements, and the relevant Notice of Privacy Practices.
An employer acting only as the plan sponsor may have limited access to identifiable health information. The employer may generally receive enrollment information, participation information, or summary health information for legally permitted plan-administration purposes, subject to applicable safeguards.
10. Programs Not Offered Through a Group Health Plan
Not every corporate wellness program is part of a group health plan, and not all health-related information held by an employer is protected by HIPAA.
Employment records are generally not protected by the HIPAA Privacy Rule merely because they contain health-related information.
Other federal or state laws, including disability, genetic-information, consumer-protection, medical-record, biometric-privacy, and data-breach laws, may still protect information collected through the program.
Welgen One will apply the legal and contractual safeguards appropriate to the structure of each program.
11. Laboratories, Vendors, and Other Service Providers
Welgen One may use laboratories, healthcare professionals, screening vendors, technology platforms, device suppliers, cloud providers, communication services, and other vendors to operate a program.
These organizations may receive information reasonably necessary to perform their assigned services.
Confirmed laboratory and service-provider relationships should be identified in program-specific materials when appropriate:
- Laboratory: [INSERT LABORATORY OR STATE “VARIES BY PROGRAM”]
- Screening vendor: [INSERT VENDOR OR STATE “WELGEN ONE”]
- Technology platform: [INSERT PLATFORM]
- Remote monitoring provider: [INSERT PROVIDER IF APPLICABLE]
When a vendor handles protected health information on behalf of a HIPAA-covered entity and HIPAA requires it, the vendor must enter into an appropriate Business Associate Agreement.
12. Other Permitted Disclosures
Welgen One may disclose information:
- To healthcare professionals involved in your care when permitted by law
- To health plans or insurers for payment and healthcare operations when applicable
- To public health authorities when legally permitted or required
- In response to a valid court order, subpoena, or other legal process
- To health oversight agencies or regulators
- To prevent or reduce a serious threat to health or safety
- For workers’ compensation purposes when legally authorized
- When you direct or authorize the disclosure
Uses and disclosures of protected health information are described more fully in Welgen One’s Notice of Privacy Practices.
13. Marketing and Sale of Information
Welgen One does not sell participant health information for monetary consideration.
Welgen One does not use protected health information for marketing when HIPAA requires authorization unless the required authorization has been obtained.
Participation in a wellness program does not automatically enroll you in unrelated marketing communications.
You may unsubscribe from promotional email communications using the link in the message. Transactional, clinical, appointment, security, and program-administration communications may still be sent when appropriate.
14. Incentives and Program Completion
A program may offer a financial or nonfinancial incentive for participation, completion of an activity, or satisfaction of a health-related standard when permitted by law.
Program-specific materials should explain:
- The incentive being offered
- The action required to qualify
- The applicable deadline
- Whether a reasonable alternative standard is available
- How to request an accommodation
- What completion information is reported to the program sponsor
When required by law, a reasonable alternative standard or waiver will be made available to a person for whom a health-related standard is unreasonably difficult or medically inadvisable.
Questions about an employer-provided incentive or benefits consequence should also be directed to the employer, group health plan, or benefits administrator.
15. Information Security
Welgen One uses reasonable administrative, technical, and physical safeguards designed to protect participant information from unauthorized access, use, alteration, loss, or disclosure.
Safeguards may include:
- Access controls
- Role-based permissions
- Encryption where appropriate
- Secure portals and transmission methods
- Workforce confidentiality obligations
- Security monitoring
- Vendor oversight
- Incident-response procedures
No electronic system, database, email service, mobile network, or internet transmission can be guaranteed completely secure.
Do not send detailed health information, laboratory results, Social Security numbers, or other sensitive information through ordinary email or a general website form unless Welgen One has specifically approved that method.
16. Data Retention
Welgen One retains participant information for the period reasonably necessary to provide services, administer the program, satisfy contractual obligations, maintain required healthcare and business records, resolve disputes, and comply with applicable law.
The general program retention period is [INSERT RETENTION PERIOD OR RETENTION SCHEDULE], subject to longer or shorter periods required for particular medical, laboratory, billing, contractual, or legal records.
Aggregate or de-identified information may be retained for a longer period when it no longer reasonably identifies an individual.
17. Your Privacy Rights
Depending on the program structure and applicable law, you may have the right to:
- Receive information about what is collected and why
- Access eligible health records
- Request correction or amendment of inaccurate information
- Request confidential communications
- Request restrictions on certain uses or disclosures
- Receive an accounting of certain disclosures
- Revoke a written authorization for future uses or disclosures
- Request an accessible format or language assistance
- File a privacy or nondiscrimination complaint
Some rights are subject to legal exceptions and verification requirements.
Revoking an authorization does not affect actions already taken in reliance on the authorization.
18. Correcting Your Information
Please notify Welgen One if your contact, eligibility, insurance, or program information changes.
If you believe a health record is incorrect or incomplete, you may request an amendment through the process described in Welgen One’s Notice of Privacy Practices.
Welgen One may deny an amendment request in circumstances permitted by law, but will provide an explanation and information about any additional rights.
19. Withdrawing From a Program
If participation is voluntary, you may generally withdraw from future participation by contacting Welgen One or the program administrator.
Withdrawal will not require deletion of information that must be retained for healthcare, laboratory, payment, contractual, legal, or compliance purposes.
Withdrawal may affect eligibility for an incentive or completion credit under the program’s disclosed terms. Contact the employer, health plan, or program sponsor for information about those consequences.
20. Emergencies and Medical Follow-Up
Corporate wellness and screening programs are not emergency-response services.
If you believe you are experiencing a medical emergency, call 911 or your local emergency number or go to the nearest emergency department.
Do not wait for a wellness program, employer, screening vendor, portal, or remote monitoring system to respond to an urgent medical concern.
If a screening result recommends medical follow-up, contact an appropriately qualified healthcare professional. Welgen One does not guarantee that an employer or program sponsor will monitor whether you obtain follow-up care.
21. Questions and Complaints
You may ask questions or submit a privacy complaint without unlawful retaliation or loss of otherwise available benefits.
For questions about Welgen One’s collection or use of information, contact:
Welgen Global Enterprises, LLC
Doing business as Welgen One
Attn: Privacy Officer
309 East Paces Ferry Road NE, Suite 400
Atlanta, Georgia 30305
United States
Privacy Officer: [INSERT NAME OR TITLE]
Email: info@welgenone.com
Telephone: 770-212-0015
Toll-free: 866-411-9354
Questions about employment decisions, program eligibility, benefit changes, or employer-provided incentives should also be directed to the employer, health plan, benefits administrator, or program sponsor identified in your enrollment materials.
If you believe protected health information was handled improperly, you may also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights at www.hhs.gov/hipaa/filing-a-complaint.
If you believe an employment wellness program violated federal employment discrimination law, you may contact the U.S. Equal Employment Opportunity Commission at www.eeoc.gov.
22. No Retaliation
Welgen One will not retaliate against you for making a good-faith privacy complaint, requesting access to eligible records, asking for language or accessibility assistance, or exercising another right protected by applicable law.
23. Changes to This Notice
Welgen One may update this notice to reflect changes in its corporate wellness programs, screening services, vendors, technology, reporting practices, or legal obligations.
The current version will be posted on our website with its effective date and most recent review date.