This Privacy Policy explains how PRN Shift Connect (“PRN Shift Connect,” “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes Personal Information (as defined below) in connection with our PRN Shift Connect websites (the “Site”), the PRN Shift Connect desktop/mobile applications, and the related content, products, services, and other functionality offered on or through the online services (collectively, the “Services”).
A user of the Services is hereinafter referred to as a “User,” or collectively, the “Users.” Users can include individuals such as website visitors, professionals seeking shifts (“Professionals”) and representatives of facilities or agencies seeking talent (“Facilities”). Professionals are independent contractors who use the PRN Shift Connect marketplace to find and book shifts of their own choosing. Professionals are not employed by PRN Shift Connect.
In certain instances, when medical Facilities or healthcare agencies use our Services to submit, manage, or otherwise process protected health information, we have contractually agreed to act as a “Business Associate” under the Health Insurance Portability and Accountability Act and only process such information on behalf of and under the instruction of the respective Facility or agency, who is the “Covered Entity”. This Privacy Policy does not apply to such processing, and we recommend you contact the Covered Entity with any questions regarding the processing of your protected health information.
When we use the term “Personal Information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.
Sometimes we collect Personal Information automatically when an individual interacts with our Services, and sometimes we collect the Personal Information directly from an individual. At times, we may collect Personal Information about an individual from other sources, even before our first direct interaction with that individual.
We may collect the following Personal Information from you directly:
- Contact Information, including your name, your employer’s name (if applicable), address, phone number, email address, and communications preferences.
- Inquiry Information, including information provided in custom messages sent through our Site. We also may collect your information when you sign up to receive information or notifications from us.
- Professional Information, including name, email address, address, zip code, phone number, licensing information, Social Security Number, date of birth, gender, driver’s license number and information, other government-issued identification documents and numbers, taxpayer identification number, background check (including criminal history-related) information, the results of federal and state exclusion list screening (such as the OIG List of Excluded Individuals/Entities and the System for Award Management), physical and health-related information, COVID-19 screening and vaccination information, immunization records, tuberculosis screening results and other health screening records Facilities require, records verifying skills and competencies Facilities require, profile information including but not limited to preferences relating to shifts and facilities, professional information including prior roles, videotape, film, record, photograph, voice, or all related instrumental, musical, or other sound effects, selfie images and facial geometry derived from those images that we use to verify your identity and detect impersonation, account login credentials, bank account and payout information, records of the agreements and disclosures you have accepted, information you provide on boards or in chats, and any other information provided to us during your account sign-up process or through our Services. You may also choose to provide race, ethnicity and place of birth; we do not use this information to infer characteristics about you. Please note we utilize the third-party providers, including but not limited to Stripe, Invoiced, and Fazeshift, to process payments on our behalf. We also use third-party accounts-receivable, collections, billing and enterprise resource planning providers, and the payment processors they rely on, in connection with Facility billing. These vendors may collect and store personally identifiable financial information on our behalf. In addition, we may store or view data associated with your account stored by these vendors, which may include the last four digits of your credit card, debit card and/or bank account number.
- Facility Information, including facility/company name, related entities’ names, names of facility representatives, those representatives’ positions, address, email address, phone number, profile information, billing and payment information, in app chats, information about the Facility’s own personnel and schedules that the Facility chooses to upload to or maintain in the Services, and any other information provided to us during your account sign-up process or through the Services.
- Emergency Contact Information, including the name, relationship to you, and phone number of a person you designate to be contacted if you experience an emergency during or in connection with a shift. Providing this is your choice. We use it only for that purpose and, as described below, may share it in an emergency.
Personal Information Automatically Collected
As is true of many websites, we and our third-party partners may automatically collect certain information from or in connection with your device when visiting or interacting with our Services, such as the list below and in the sub-sections here:
- Device Data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser id, the URL entered and the referring page/campaign, date/time of visit, other user agent string data, the time spent on our Services, and any errors that may occur during the visit to our Services). Device Data may overlap with the other categories of data below.
- Analytics Data, including the path taken to our Services, through our Services, and when exiting our Services, usage and activity on or in connection with our Services, metrics on how many emails we send are actually opened and which attachments or links are opened, clicked, or viewed (such as via pixels, as described further below).
- Location Data of Professionals, including precise and coarse geographic location information, which we and/or our third-party providers collect, once enabled by the permissions setting on your device. This includes location information leading up to the start of shifts you book, between when you arrive at and leave those shifts, shortly after the shift ends, and when you search for shifts near you. We also use location data gathered when you arrive at and leave your shifts to verify the completion of those shifts in order to distribute your earnings. We may share your location information with third party service providers in order to provide these services.
- Cookies and Other Technologies. Like many websites, we and our third-party providers may use “cookies” that our Services use to collect and store information about Users. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We and our third-party service providers may also use other tracking technologies, such as “pixel tags,” “web beacons,” “clear GIFs,” SDKs, location-identifying technologies, or similar means in connection with the Services and HTML-formatted email messages to, among other things, track the actions of Users and email recipients and to automatically collect the Personal Information described in this section (and otherwise expanded upon in other sections). See the Control Over Your Information section below to learn more about how you may limit or disable cookies or certain other tracking technologies on your device.
- Timekeeping Data, including the times you record starting and ending a shift or break, records generated when you check in through the mobile app, the hours reflected on timesheets. We use this information to verify shift completion, to distribute your earnings, and to produce the records Facilities need for their own timekeeping and reporting.
- Communications Content, including the content of messages you exchange with Facilities and with our support teams, text messages, and calls with our support teams. Calls with our support teams may be monitored or recorded where permitted by applicable law. We review message content to provide support, to identify shift cancellations and scheduling changes, to make credential information you send us usable in your account, and to maintain the safety and security of the marketplace.
Personal Information Collected Through Other Sources
We also obtain Personal Information from third parties, which we often combine with Personal Information we collect either automatically or directly from you. For example, we may receive the same categories of Personal Information as described above from the following third parties:
- Your Employer / Company: When an individual interacts with our Services as an employee or representative of their company, we may receive their information from their employer or other employees at their company.
- Other Users: When you interact with other Users on the Services we may receive information you choose to share with them. For example, if you send a direct message to another User, we may receive the information in the message. We also may receive ratings and comments from other Users. For example, we receive Professional ratings from Facilities after shifts are completed.
- Facilities: Facilities provide us information about Professionals, including ratings, written endorsements and warnings, designations indicating that a Professional should not return to that Facility, assessments of skills and competencies the Facility requires, and reports of safety or conduct incidents the Facility says occurred at its site.
- Government and Regulatory Sources: We receive information from federal and state government sources, including licensing boards and federal and state exclusion lists such as the OIG List of Excluded Individuals/Entities and the System for Award Management.
- Clipboard Marketplace Sign-Up-Related Third Parties: When you sign up for a Professional account to access PRN Shift Connect's marketplace or seek a shift through PRN Shift Connect's marketplace, we may receive Personal Information from related third parties, such as websites and platforms containing information about PRN Shift Connect and opportunities to find shifts through our marketplace, references, background check providers, and recruiters.
- Licensing and Certifications: We may receive information from third parties in order to verify your licenses or certifications.
- Service Providers: Our service providers that perform services solely on our behalf, such as payment processors, background check and credentialing vendors, or surveys and certain advertising/marketing providers, collect Personal Information and may share some or all of this information with us.
- Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement Personal Information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual or obtain demographic information (e.g., preferences).
- Other Sources: We may also collect Personal Information about you that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.
Only authorized Clipboard staff have access to your Personal Information in its entirety. Other staff may have access to portions of this information if it pertains to their job duties.
PRN Shift Connect's Use of Personal Information
PRN Shift Connect uses Personal Information for the following general purposes:
- to fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to provide our products and the Services, and to process transactions,
- to manage our organization and its day-to-day operations,
- to determine whether you may sign up for an account to access PRN Shift Connect's marketplace as a Professional or Facility,
- to verify your identity, including through biometric identity verification where you have consented to it, and to detect impersonation,
- to verify the licenses, certifications, screenings, skills and competencies Facilities require of Professionals who book their shifts,
- to determine whether Professionals will arrive on time to booked shifts, and whether they are at the Facilities during shifts,
- to suggest and display nearby available shifts,
- for billing, payment, identification and authentication, and fraud prevention,
- to prepare and file tax information returns, and to make tax records available to you,
- to communicate with you, including via email, text message, social media and/or telephone calls, and to deliver administrative notices and communications relevant to your use of our products and the Services,
- to market our Services to individuals, including through email, direct mail, phone or text message,
- to administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Site,
- to facilitate User benefits and services, including customer support through our command center services,
- to contact, or enable a Facility, emergency responders or medical personnel to contact, the emergency contact you have designated, if you experience an emergency during or in connection with a shift,
- to detect, investigate, provide notice of or protect against error, fraud or other unlawful or criminal activity,
- for distribution to third-party contractors that provide services to PRN Shift Connect,
- to comply with legal obligations,
- to retain records where a law, regulation, licensing requirement or registration obligation applicable to us requires us to keep them,
- to defend, protect or enforce our rights or applicable contracts and agreements, including our Terms of Service, and
- as otherwise set forth in this Privacy Policy.
Clipboard’s Disclosure of Personal Information
We disclose Personal Information in the following ways: Facilities with which You Book a Shift: We may share information about your geographic location with Facilities in the manner described under “Location Data of Professionals,” above. In addition, we may share the following with a Facility at which you have booked a shift:
- identity and contact information, including your name, profile photo, any worker video clips you have provided, postal address, email address, phone number, gender, and date of birth;
- government-issued identification documents and identification numbers, including images of those documents where a Facility requires them;
- your professional licenses, certifications and qualifications, badges indicating that your credentials and screenings have been verified, and the status of skills and competency verifications the Facility requires;
- your background check results and the results of federal and state exclusion list screening;
- health and screening records the Facility requires, including physical examination results, tuberculosis screening and chest X-ray results, immunization records, and COVID-19 screening and vaccination information;
- your prior professional roles and work history, and your shift and facility preferences and availability;
- do not return history and related information;
- records of your activity in connection with that Facility, including shifts booked, transferred and cancelled, arrival and departure times, timekeeping punches;
- the rate applicable to a shift and the amounts payable for it;
- messages you exchange with that Facility through the scheduling app, and reports of safety or conduct incidents relating to your shifts at that Facility;
- credentials so that you can use charting or electronic health record systems the Facility uses; and
- in limited circumstances, your Social Security number or taxpayer identification number.
The categories above describe what we may share; what is actually shared depends on the Facility, the shift, and what the Facility is required to collect.
We limit sharing of Social Security numbers and taxpayer identification numbers with Facilities to circumstances where the Facility reasonably needs the information to identify you, or to meet a reporting requirement or other legal obligation that applies to it. Where the Facility does not need the full number, we mask all but the last four digits, and where the number is not needed at all we mask it entirely.
If you have provided emergency contact information, we may share your emergency contact’s name, relationship to you and phone number with a Facility, with emergency responders, or with medical personnel, where you experience a medical emergency, injury or other health event during or in connection with a shift, or where doing so is otherwise necessary to protect your health or safety.
- Timekeeping and Workforce Management Platforms: Where a Facility uses a third-party timekeeping, scheduling or payroll platform, or asks us to transmit labor files to a recipient it designates, we may disclose Professional identity, shift, hours-worked and rate information to that platform or recipient so the Facility can maintain its own records and satisfy reporting obligations that apply to it.
- Tax Authorities: We disclose taxpayer identification numbers and earnings information to the Internal Revenue Service and to state tax authorities, and to the providers that prepare and file information returns on our behalf, as required for tax information reporting.
- Other Users: We may share your Personal Information with other Users. For example, if you are a Professional who signs up for a shift at a Facility, we may share your information with that Facility, or with other Professionals who booked shifts at that Facility. Additionally, we may share the Personal Information and shift booking activity of Professionals with other Professionals.
- Customer Service and Communication Providers: We share Personal Information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
- Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as payment processing, website hosting, infrastructure provisioning, IT services, analytics services, administrative services, and background check and credentialing vendors. We use third-party technology providers, including automated services, to process documents, images, video and message content in connection with identity verification, credential and document review, content review, safety and customer support.
- Legal Obligations and Rights: We may disclose Personal Information to third parties, such as legal advisors and law enforcement:
- if required by law or if we are given reason to believe, in our sole discretion, that someone is causing injury to or interference with the rights of Users, the general public, or PRN Shift Connect,