Teladoc Health Notice of Privacy Practices for US Providers' Personal Information

Effective Date: 10/29/2024

1. Introduction

Teladoc Health Medical Group (“Teladoc,” “we,” “us,” or “our”) respects the privacy of healthcare providers who engage with our platform, services, and tools (collectively, the “Services”). This Notice of Privacy Practices (“Notice”) outlines how we collect, use, disclose, and protect the personal information of healthcare providers, including both employed providers (W-2) and contracted providers (1099), in compliance with applicable data privacy laws, including relevant federal and state regulations. It is important that you read and understand this Privacy Notice. If you have questions or do not understand it fully, please seek additional information by contacting the Chief Privacy Officer at [email protected] or by contacting your HR Representative.

2. Scope

This Notice applies to the personal information collected from and about Providers who engage with Teladoc’s Services as part of their professional relationship with us. This includes both W-2 employed providers and 1099 contracted providers. This Notice does not, and is not intended to, alter the nature of the professional relationship between Teladoc and its Providers. It is not intended to classify 1099 contracted providers as employees of Teladoc for the purposes of employment law, tax law, or any other legal or regulatory requirements. This policy solely governs the use and protection of personal information and does not affect the classification status of contracted providers.

To the extent that you use any of Teladoc’s suite of health services, such as telehealth, chronic condition management, or expert medical services, or Teladoc’s websites, this Notice does not apply to the information that is collected during your use of those services as a member or consumer. To avoid doubt, the information collected during your use of those services as a member or consumer, if any, will not be accessed or used for purposes of your professional relationship with us. Refer to the Notice of Privacy Practices that is applicable for the services you are using in order to understand what Personal Information is collected and processed by Teladoc during the course of your use of those services.

3. Categories of Personal Information We Collect

We may collect the following categories of Personal Information about you:

Category	Examples
Identifiers	Real name, contact details (e.g., email address, phone number), license number, professional credentials, and other identifying information relevant to your professional relationship.
Categories of Personal Information described in Section 1798.80(e) of the California Civil Code	Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, financial information, medical information, health insurance information.
Characteristics of protected classifications under California or federal law	Age, race, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran, or military status.
Categories of Sensitive Personal Information under California Privacy Rights Act (CPRA)	Social Security, driver’s license, state identification card, passport number, financial account information, precise geolocation, racial or ethnic origin, or health information.
Biometric Information	Fingerprint, voice/video recording.
Internet or other electronic network activity information	Your access to and use of Teladoc’s communication systems, applications, and software including your access to and modification of the information contained therein (e.g. corporate, client, and member information). This may include your Teladoc email account if you have one, and applies whether you access such information, systems, applications, software, and communication systems through company issued equipment or your personal device. User logs and access control related information, Location information, including through GPS tracking technology on Teladoc-owned devices (e.g., laptops to locate and/or wipe lost or stolen laptops), or other devices owned by you which you use in connection with your professional relationship with Teladoc. Browsing history, search history, and information regarding interaction with an Internet website, application, or advertisements on Teladoc- provided devices. Details related to Providers’ calendars, including information shared with us through calendar integration services like Google Calendar, to facilitate consult scheduling and calendar syncing.
Geographic data	GPS tracking on Teladoc-provided devices as well as through swipe card records.
Audio, electronic, visual, thermal, olfactory, or similar information	Photograph, temperature, CCTV footage, voice/video recording.
Professional or employment-related information	Title(s), position description(s), working location(s), years of service, salary, work hours, vacation, and absences; copy of driving license (if relevant for your position); copy of passport or identity card, and information related to immigration and right-to-work (e.g., work permit / visa application information); travelling and travel expenses data; termination date and reason for termination. Employment history, qualifications, credentials, and areas of specialty.CV/resume details, professional history, and any information you provide to us on an application and during interviews, as well as information we gather from reference persons whose contact details you have provided to us, written or verbally, and background check reports. Information required for payroll purposes (e.g., bank account details, tax information); Information related to benefit entitlements and schemes such as insurance and stock options, e.g., details of participation and contributions made. Benefits information, compensation information. Emergency contact information, and names of dependents. Performance related information (e.g., assessments of your performance, objectives and goals, feedback, and tests results); information relating to misconduct, investigations, and disciplinary actions; attendance; qualifications and personal development information, and competence assessments; learning and development records, certificates, licenses, and vocational records; records of career and succession planning; ongoing background check reports and security data.
Education information	Degrees, schools attended, certificates, licenses, spoken languages, vocational records, and professional qualifications.
Inferences	Inferences drawn from any of the above types of information that may reflect your characteristics, behavior, intelligence, abilities, and aptitudes related to the purposes outlined in Section 4 below.
Personal Information that you provide directly to us either verbally or in writing.

4. Purposes for which Personal Information is Used

Teladoc collects, uses, and discloses your Personal Information in connection with your professional relationship with us and in order to comply with Teladoc’s legal obligations. We use, and may disclose to third parties who assist us with these functions, Personal Information for the following purposes:

Recruitment, interviewing, and vetting of candidates;
Background checks for professional relationship and client engagement services;
Performing ongoing sanction and exclusion checks, including those required by the Office of the Inspector General;
To verify professional credentials and ensure Providers meet regulatory requirements.
Onboarding and decisions about continued professional relationship or engagement;
Managing and documenting your professional relationship with Teladoc, attendance, and performance
Providing you with equipment, training, and support to carry out your duties and responsibilities;
Payroll and other compensation;
Administering and managing compensation and benefits;
Organization management and administration, including staffing management, financial planning, internal audits, and other administration;
To facilitate consult scheduling and management, including the use of calendar integration services such as Google Calendar, allowing for seamless appointment scheduling and notifications. For more information about the Google API Services User Data Policy that we must comply with, including the Limited Use requirements, please visit: https://developers.google.com/terms/api-services-user-data-policy. We recommend that you review and, if necessary, adjust your privacy settings on third-party websites and services before sharing information and/or linking or connecting them to other platforms, including our Services.
Administration of absences in accordance with company and statutory leave programs;
Traveling and expense reimbursement;
Responding to professional relationship verification inquiries;
Communicating with you. This may include facilitating communications to and between employees and contractors, and communications with other bodies (e.g., regulatory authorities). This also includes use of your photograph on internal methods of communication including email communications, ID cards, and through other global development activities such as on the Teladoc Intranet, during town hall meetings, and department meetings;
External marketing activities, including marketing photos, brochures, website content, videos, social media posts, and other related marketing activities;
Complying with legal obligations, including responding to requests from government agencies;
Reporting to appropriate government entities, including tax authorities and other governmental and regulatory agencies;
Ensuring network and information security, including preventing unauthorized access to our computer and electronic communications systems and physical locations
Administering our applications, software, and systems;
Preventing fraud, responding to legal process, and complying with federal, state, and local laws, as well as regulatory requirements;
Statistical, research, and analytical purposes to understand and improve provider satisfaction, improve products & services, and performance as necessary;
To support Teladoc Health’s Diversity, Equity & Inclusion (DEI) initiatives, which could include reviewing aggregate reporting to ensure equitable and inclusive practices, monitor trends and achieve organizational targets;
Any other purpose with your consent.

5. Your Rights Regarding Your Personal Information

Depending on your status (W-2 employee or 1099 contractor) and applicable state or federal law, you may have the following rights:

Right to Know

Providers may request information about the categories of personal information Teladoc collects about them, the sources of this information, the purposes for which it is collected, and the categories of third parties with whom the information is shared, as permitted under applicable laws and regulations.