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Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy section supplements the Privacy Policy and applies to residents of Colorado, Washington, Oregon, and any other states where Accolade is subject to state data privacy laws. 

 

The Colorado Privacy Act (“CPA”), Washington “My Health My Data” Act (“WMHMDA”), Oregon Consumer Privacy Act (“OCPA”) and other state privacy laws provide certain residents (i.e., consumers) with specific rights regarding personal information. This section of the Privacy Notice describes those rights and how to exercise those rights. This section does not apply to publicly available information or to protected health information that is collected and governed by the privacy, security, and breach notification rules issued by the federal Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Availability Act of 1996 (“HIPAA”).  

 

Consumer Rights  

Description  

Access to Specific Information and Data Portability Rights  

Residents in Colorado, Washington, Oregon, and other states that have data privacy laws in which Accolade is subject to, have the right to request that Accolade disclose certain information to you about Accolade’s collection and use of your personal information over the past twelve (12) months. Once Accolade receives and confirms a verifiable consumer request from you, Accolade will disclose to you, to the extent permitted by law:   

 

  • The categories of personal information Accolade collected about you.   
  • The categories of sources for your personal information Accolade collected about you.   
  • Accolade’s business or commercial purpose for collecting your personal information.   
  • The categories of third parties with whom Accolade shares your personal information.   
  • If we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.   

   

You shall have the right to request that the information described above be provided to you in a portable and readily useable format, to the extent technically feasible (“data portability").   

   

Accolade does not sell your personal information.   

  

Deletion and/or Correction Request Rights  

You have the right to request that Accolade delete and/or correct certain of your personal information that Accolade collected from and/or related to you and retained, subject to certain exceptions. Because of the relationship between Accolade and your employer and/or your health plan carrier, Accolade cannot delete or correct/change your personal information provided by your employer, your healthcare provider and/or other entities that support your health benefits plan.  

 

To the extent that Accolade can delete or correct your personal information, once Accolade receives and confirms your verifiable consumer request, Accolade will delete and/or correct (and direct our service providers to delete) your personal information, unless an exception applies.  

 

We may deny your deletion request if retaining the information is necessary for us or our service providers to:  

 

  • complete the transaction for which we collected your personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, your employer, or your health plan carrier  
  • detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities  
  • debug products to identify and repair errors that impair existing intended functionality  
  • exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law  
  • engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent  
  • enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us  
  • comply with a legal obligation  
  • make other internal and lawful uses of that information that are compatible with the context in which you provided it  
  • Additionally, Accolade may deny your deletion and/or correction request if the information sought to be deleted is protected health information disclosed to us as part of your participation in an employer-sponsored group health plan and/or your health plan carrier through which you have purchased a health plan or other benefits.  

 

We may deny your correction request if, after considering the totality of the circumstances, we determine that the information is more likely accurate than not.  

Right to Appeal  

You have the right to appeal any declination to respond or failure to take action regarding your request to exercise your rights.  

To exercise your right to appeal, please submit a verifiable appeal request to Accolade by either:  

Exercising Your Access, Data Portability, and Deletion Rights  

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Accolade by either:   

   

  • Visiting the Data Subjects Rights Portal located here; or   
  • Calling the following toll-free number at 1 (888) 914-9661, and using PIN# 494 202 to identify that you are calling with respect to Accolade.