HCIS 318 Week 4 Personal Health and Ethics Example

Step Counts, Sleep Scores and a Premium Discount: The Ethics of an Employer Wellness Program Built on Wearable Data, Seen by the IT Team Asked to Build It

[Student Name]

University of Phoenix

HCIS/318: Health Care Industry Terms for IT Professionals

Week 4 Assignment

[Instructor Name]

[Date]

The employer, the program and the design choices are composites written for a model paper; research findings and rules come from the sources listed.

A composite manufacturing company with 3,000 employees asks its IT department to build a wellness platform. Employees would connect a smartwatch or fitness band; the platform would collect daily steps, sleep scores and heart rate, and employees who reach step and sleep targets would earn a $600 annual discount on their health insurance premium. Leadership sees healthier workers and lower costs. The IT team, asked to design the data flows, sees a list of questions no one has asked. This paper examines the program's ethics from the team's point of view.

What the Law Covers

Whether HIPAA applies depends on how the program is set up. If it is offered through the company's group health plan, the plan is a covered entity and the wellness data it handles are protected. If the company runs it directly, outside the plan, HIPAA generally does not apply, and the data are held by an employer, not a health plan. If the program uses a consumer app vendor that is not a business associate, the Federal Trade Commission's Health Breach Notification Rule may require the vendor to notify users and the agency after a breach, which the rule defines to include unauthorized disclosure, not only hacking (Federal Trade Commission, 2024). Employment and disability laws also limit how employers may use health information and incentives.

Consent When Money Is Attached

Autonomy requires that people choose freely and knowingly. A $600 discount is presented as a reward, but for a lower-wage worker it functions as a penalty for not participating. Consent obtained under financial pressure is technically voluntary but ethically thin, and the thinner it is, the more carefully the program must limit what it collects and how it uses the data.

Fairness

Some employees cannot reach step targets because of disability, pregnancy, injury or caregiving schedules; night-shift workers score poorly on sleep measures designed for daytime sleepers. A program that rewards device-measured behavior shifts money from those with fewer health advantages to those with more. Fairness requires alternative ways to earn the reward, such as completing a health coaching session, and targets adjusted for shift work.

Surveillance

Sleep scores and heart rate reveal more than fitness. Changes can signal illness, pregnancy, stress or alcohol use. Continuous data from a device worn off duty extend the employer's view into employees' private lives. Susser (2020), writing about digitally targeted public health interventions, argued that using personal data to target and influence people raises ethical concerns about manipulation and privacy even when the aim is health. Those concerns apply with more force when the party collecting data also controls paychecks.

Reuse of Data

Data collected for wellness could later be used for other purposes: workforce analytics, insurance pricing or decisions about promotions. Employees would reasonably not expect that. Kim et al. (2017) found that California consumers' willingness to share electronic health data depended on their views about privacy, security and quality and, for research uses, on how much they valued control over their information. People share when they trust the purpose and keep some control.

Security of the Data Once Collected

Ethics also covers what happens if the data escape. A database of employees' sleep patterns and heart rates would be valuable to attackers and embarrassing if exposed. The team asked the vendor where data are stored, whether they are encrypted, who can access them and how quickly the vendor would notify the company of an incident. It also asked whether the vendor sells or shares de-identified data with third parties, a common practice among consumer wellness companies, and required that it not do so for this program.

Transparency in Plain Language

Employees cannot consent to what they do not understand. The team drafted a one-page notice in plain language that lists exactly which data are collected, who sees them, what the company receives, how long data are kept and how to stop participating. It tested the draft with a dozen employees from the plant floor and the office and rewrote two paragraphs that confused them.

Benefits That Deserve Weight

The program could help employees who want to be more active, and aggregate data might show the company where to invest, such as in safer walking paths or healthier cafeteria food. An ethical design keeps those benefits while removing the harms.

Recommendations From the IT Team

The team proposed seven design choices. Run the program through the group health plan with a business associate agreement, so HIPAA's protections apply. Collect only what the reward requires: a daily yes or no on the step target, not raw heart rate or sleep data. Keep individual data with the vendor and give the company only aggregate reports for groups of 50 or more. Offer an alternative path to the full discount that requires no device. Adjust sleep targets for shift workers. Write a clear, short privacy notice stating that data will never be used for employment decisions and will be deleted after the plan year. Allow employees to disconnect devices at any time, without losing the alternative path.

Raising Concerns Professionally

IT professionals are often told to build what is requested. The team framed its concerns as risks to trust, participation and legal exposure, and brought them to human resources and legal counsel with alternatives rather than objections alone. Leadership accepted five of the seven recommendations. The two it declined, aggregate reporting thresholds and deletion after one year, were modified rather than dropped: reports use groups of 25, and data are deleted after two years.

Conclusion

A wellness platform built on wearable data may be legal and still raise hard ethical questions about consent under financial pressure, fairness, surveillance and reuse. By limiting data, protecting individuals, offering alternatives and promising, in writing, how data will not be used, the IT team helped the company pursue its goal while respecting the people whose data made it possible.

References

Federal Trade Commission. (2024). Complying with FTC's health breach notification rule. https://www.ftc.gov/business-guidance/resources/complying-ftcs-health-breach-notification-rule-0

Kim, K. K., Sankar, P., Wilson, M. D., & Haynes, S. C. (2017). Factors affecting willingness to share electronic health data among California consumers. BMC Medical Ethics, 18, Article 25. https://doi.org/10.1186/s12910-017-0185-x

Susser, D. (2020). Ethical considerations for digitally targeted public health interventions. American Journal of Public Health, 110(S3), S290-S291. https://doi.org/10.2105/AJPH.2020.305758