Last Updated August 2018
These best practices are provided to help ensure that your wellness or population health program complies with applicable law and creates a positive experience that inspires healthy habits.
Participation in your program must be voluntary. This means that there must be no adverse employment consequences or discipline as a result of a participant’s choice to share, not share, limit sharing, or cease sharing any and all of their data with you.
You provide participants with notice of how their data will be used in your program, if it will be shared outside the program, who will have access to it, whether you will have access to individual or aggregate data, and the period of time you will retain the data. You will also explain to participants the rights they have over their data.
You limit the data you access from Fitbit to data that is necessary to provide your program, including any incentives, and you use participant data for the limited purposes of your wellness program.
Your wellness program must be compliant with all applicable laws, including the Americans with Disabilities Act and the General Data Protection Regulation, and must be designed to promote health or wellness, or prevent disease.
If your program incorporates incentives, Fitbit’s offering must be one component of an overall program which includes other reasonable alternatives, and it must not include penalties for non-participation.