U.S. Privacy Policy and Notice
ComPsych and FMLASource are committed to maintaining the privacy of information related to individuals who utilize our services (“Participants”). Your personal information is treated as confidential, and we will not disclose your personal information to third parties without your permission, except as described in this Policy and Notice. We have implemented administrative, technical, and physical data security practices designed to protect the confidentiality and integrity of your personal information.
This Policy and Notice explain what personal information we may collect about you in order to provide services to you, how we may use the collected information, and the rights you may have related to the collection of your information. Should you have any questions or concerns about the information collected about you or your rights related to that information, please do not hesitate to reach out to us at Records@compsych.com.
Participants residing in certain states may have additional state specific rights related to the personal information we collect, pursuant to, and without limitation, the California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”), Nevada Privacy of Information Collected on the Internet from Consumers Act (“NPICICA”), Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”), Iowa Act Relating to Consumer Data Protection (“ICDPA”), the Oregon Consumer Privacy Act (“OCPA”)(effective July 1, 2024), Utah Consumer Privacy Act (“UCPA”)(effective December 31, 2023), Montana Consumer Data Privacy Act (“MCDPA”), Tennessee Information Protection Act (“TIPA”)(effective July 1, 2025), and the Indiana Consumer Data Protection Act (“Indiana CDPA”)(effective July 1, 2026). This list is not exhaustive and this Policy and Notice is intended to comply with all state specific consumer data privacy laws now in effect and implemented at a later date.
When ComPsych and FMLASource are delivering professional services, we are the Data Controller of the personal data that you provide to us.
Information Collected
To allow ComPsych to provide employee assistance programs and behavioral health, work-life, wellness and FMLASource to provide HR administration services (“Services”), we may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular Participant (“Personal Information”).
In particular we may collect the following categories of Personal Information for the purposes set out below:
| Personal Information Category | Types of information we may collect | How we may use the information collected |
|---|---|---|
| Identifiers | Your name, alias, postal address, email address, username, social security number or other similar identifiers | To identify you and authenticate your identity
To communicate with you and for any purpose related to the services provided to you |
| Personal Information Categories listed in the relevant state law | Your name, social security number, education, employment, employment history, postal address, email address and telephone numbers | To communicate with you and for any purpose related to the services provided to you
To allow us to manage our relationship with you, such as providing you with information we feel would be of interest to you or to facilitate responding to further requests or inquiries from you To inform you of new products or changes to products and services |
| Professional or Employment Related Information | Place of work, employment history, job title, leave of absence related information | To administer services to you |
| Sensory Information | Telephone recordings (FMLASource only) and transcripts, emails, letters, online chat or other records of communication with you | For quality assurance and training purposes
To assist in providing services to you To retain a record of communications with you To assist in resolving any disputes and improve your experience |
| Internet or other similar network activity | Login data, browser type and version, time zone setting and location | To personalize your website experience
To provide services tailored to you |
| Sensitive Personal Information Category | Types of information we may collect | How we may use the information collected |
|---|---|---|
| Health Information | Information related to your physical and/or mental health which we received in connection to your use of our services | To provide requested services to you |
| Protected classification characteristics under California or federal law | Age, marital status, gender | To provide requested services to you |
We may also collect and use your Personal Information for business and operational purposes, to address legal and regulatory requirements, including to enforce our legal rights, or as otherwise set forth in applicable laws. We obtain the categories of Personal Information listed above directly from you and indirectly from you, i.e., from your employer.
Personal Information does not include de-identified or aggregated consumer information. De-identified personal information may be used to report aggregate utilization of services to your employer or group health plan. Such reporting is anonymous, meaning that your name or other personally identifying information will never be disclosed to your employer or group health plan in these reports.
HIPAA
Protected Health Information (PHI) is subject to the Health Insurance Portability and Accountability Act (HIPAA) and is, therefore, outside the scope of this Privacy Policy and Notice. For information related to your privacy rights under HIPAA, please visit our HIPAA Privacy Notice at https://www.compsych.com/privacy/hipaa.
Data Subject Rights
As required by applicable state law, you have the:
- Right of Access: You have the right to know and be informed about the Personal Information that we collect about you. This includes the right to be informed about the categories of Personal Information collected, the purpose for which it is collected, and the third parties with which it is shared. Please find related information under the “Information Collected” and “Information Sharing” sections of this Policy and Notice. You may also contact us for information specific to you.
- Right to Portability: You have the right to request and obtain a copy the Personal Information collected about you in a portable format, or a representative summary.
- Right to Correct or Delete Personal Information: You have the right to request that ComPsych/FMLASource amend Personal Information that is inaccurate or outdated and delete any Personal Information about you that ComPsych/FMLASource has collected, subject to the limitations outlined in applicable state law.
- Right to Non-Discrimination. ComPsych/FMLASource do not discriminate against individuals on the basis of that individual’s exercise of their rights pursuant to applicable law.
- Since we do not sell or share your information with third parties (other than as necessary to provide you with services), the Right to Opt-out or Limit the selling or sharing of your Personal Information and the Right to Limit the disclosure of Sensitive Personal Information is not applicable.
Data Subject Requests
Requests related to your rights as enumerated above will typically be responded to free of charge, within 45 days of receiving your request unless the request is deemed excessive or otherwise inappropriate under applicable state law. In the event that additional time is needed to process your request, we will communicate this to you in writing. To make a request, you can contact us via email at Records@compsych.com or by calling 312- 660-1076.
We reserve the right to require information from you at the time of your request to verify your identity for security purposes.
We Do Not Sell Your Data
ComPsych and FMLASource do not sell, and have not sold in the preceding 12 months, Personal Information that we have collected to any third parties.
Information Sharing
We will not intentionally disclose your Personal Information to third parties without your permission except as indicated in this section and where required or permitted by law.
Personal Information may be provided to third party service providers related to the Services provided to you. We do not disclose, and have not disclosed in the preceding 12 months, personal information to third parties for cross-context behavioral advertising.
For absence management services, FMLASource may disclose to your employer and its third party employee benefit administrator any Personal Information you disclose to FMLASource in connection with the administration of your leave of absence.
Information Retention
Your information is retained for as long as is necessary to provide Services and as required under law.
Additional State Specific Privacy Rights:
California
California Residents please refer to the California Consumer Privacy Rights Notice.
Nevada
We do not sell your covered information, as defined under Chapter 603A of the Nevada Revised Statutes.
Virginia, Iowa, Montana, Colorado, Tennessee and Connecticut
Virginia, Iowa, Montana, Colorado, Tennessee and Connecticut residents:
- If we deny your rights request, you have the right to appeal that decision. We will provide you with the necessary information to submit an appeal at that time.
- Since we do not engage in targeted advertising or profiling as defined by your state’s law your right to opt out of such activity is not applicable.
Indiana
- Since we do not engage in targeted advertising or profiling as defined by your state’s law your right to opt out of such activity is not applicable.
Oregon
- Oregon residents have the right to obtain, at the option of ComPsych/FMLASource, “a list of specific third parties, other than natural persons, to which we have disclosed: (i) your personal data; or (ii) any personal data.”
ComPsych and FMLASource reserve the right to change our privacy practices at any time and any such change shall apply to all Personal Information ComPsych and/or FMLASource maintains, including information created or received by ComPsych and/or FMLASource prior to issuing a new Notice. If ComPsych materially changes its privacy practices, this Notice shall be amended.
Effective: July 1, 2023