Data Use Policy

Data Use Policy for Partner Organizations using www.hwcollab.org. Effective Date: August 19, 2024

1. Introduction

This Data Use Policy outlines the expectations and responsibilities of partner organizations, including workforce development organizations, educational programs, healthcare employers, and other approved entities (collectively referred to as “Partners”) when accessing and using user data through the Health Workforce collaborative digital platform. By accessing this data, Partners agree to comply with this policy to ensure the highest standards of data privacy and security.

2. Purpose of Data Access

• Authorized Use: Partners are granted access to user data solely for purposes directly related to career development, long-term engagement, tracking, and promoting relevant opportunities to the participants or students associated with their organization.
• Restricted Use: Data accessed through the Health Workforce Collaborative digital platform should not be used for any purposes outside the scope of the organization’s agreed-upon activities. This includes, but is not limited to, commercial exploitation, unrelated marketing activities, or non-approved research.

3. Data Security and Confidentiality

• Confidentiality Obligation: Partners must ensure that user data is kept confidential and only accessible to authorized personnel within their organization. All employees with access to this data must be informed of and comply with this Data Use Policy.
• Technical and Organizational Measures: Partners must implement appropriate technical and organizational measures to protect user data from unauthorized access, disclosure, alteration, or destruction. This includes, but is not limited to, the use of secure systems, encryption, and regular access audits.

4. Prohibition on Data Sale

• No Sale of Data: Under no circumstances may Partners sell, trade, or otherwise transfer user data to third parties for any commercial purposes. Data may only be shared with third parties if explicitly authorized by the Health Workforce Collaborative,  their digital platform provider Health WorkForce New York, and the user, and only for the purposes outlined in this policy.

5. Data Sharing and Reporting

• Aggregate Reporting: Any demographic information shared with evaluators, funders, or other third parties must be in aggregate form, ensuring that individual user identities remain protected.
• Compliance with Reporting Obligations: Partners may use user data to fulfill reporting obligations to grant funders, provided that such reporting complies with the aggregate reporting requirement and other confidentiality obligations outlined in this policy.

6. Participant and Student Rights

• Data Access Requests: Partners must comply with any requests from users to access, update, or delete their personal information. Such requests should be handled promptly and in accordance with applicable laws and regulations.
• Communication Preferences: Partners must respect user communication preferences, as managed through the Health Workforce Collaborative platform, and ensure that any communications sent are in line with the users agreed preferences.

7. Data Breach Notification

• Immediate Reporting: In the event of a data breach that compromises participant or student data, Partners must immediately report the breach to the Health Workforce Collaborative’s digital platform provider, Health Workforce New York, at [email protected] and take all necessary steps to mitigate the breach’s impact.
• Compliance with Laws: Partners must manage data breaches in compliance with all applicable data protection laws and regulations.

8. Compliance and Audits

• Regular Audits: Health Workforce Collaborative and their digital platform provider, Health Workforce New York, reserves the right to conduct regular audits of Partner data use practices to ensure compliance with this policy. Partners are expected to fully cooperate with such audits and provide any necessary information or access as required.
• Consequences of Non-Compliance: Failure to comply with this Data Use Policy may result in the suspension or termination of the Partner’s access to the Health Workforce Collaborative platform and potential legal action.

9. Amendments to the Data Use Policy

• Policy Updates: Health Workforce Collaborative and their digital platform provider, Health Workforce New York, may update this Data Use Policy from time to time. Any changes will be communicated to Partners, and continued use of the Health Workforce Collaborative platform constitutes acceptance of the updated policy.

10. Contact Information

• Questions or Concerns: For any questions or concerns about this Data Use Policy, please contact us at [email protected].