Personalizing workplace health prevention without monitoring employees
Employees don’t all have the same needs, but their employer must not know their medical situation. A prevention platform can resolve this tension by strictly separating the individual journey from collective program management. Here are the design principles that protect both trust and usefulness.
By Rubens Valcy
Founder of MyTwin
Published on
Contents
Offering everyone the same program seems fair, but it rarely matches the diversity of ages, jobs, constraints and priorities. Conversely, asking the employer to select services for each individual would be intrusive and legally problematic. Personalization must therefore serve the employee, without making their medical profile visible to the company.
France’s data protection authority, the CNIL, states that an employer cannot know its employees’ health data. It also points out that health data is sensitive and that processing it is prohibited in principle, except in cases provided for by law. Consent does not settle every question in an employment relationship, where the imbalance between the parties must be taken into account.
Separating three spaces
The employee
- Accesses their own information
- Chooses whether to use a service
- Understands what will be collected
Individual results reserved for authorized people and professionals
The healthcare professional or provider
- Uses the information needed for support
- Works within their framework of responsibility and confidentiality
Does not pass medical details on to the company
The employer
- Deployment indicators
- Aggregated results: coverage, activation, satisfaction, waiting times, use of services
Small categories to be grouped or hidden
The employee’s space
Employees can access their information, choose whether to use a service and understand what will be collected. Individual results remain accessible only to the people and professionals authorized for that purpose.
The healthcare professional’s or provider’s space
Authorized professionals can use the information needed to support the employee, within their own framework of responsibility and confidentiality. They do not pass medical details on to the company.
The employer’s space
The employer sees deployment indicators and aggregated results: coverage, activation, satisfaction, waiting times or use of services. Categories that are too small must be grouped or hidden to limit re-identification.
Personalization by choice, not by assignment
A respectful approach offers several entry points: cardiovascular health, sleep, mental health, skin, pain or other priorities. Employees choose their own journey or receive guidance in a confidential space.
Participation must be genuinely voluntary. The International Labour Organization (ILO) stresses that health promotion initiatives should rest on information and free choice rather than coercion. Not taking part must have no consequences for employment, performance reviews or benefits.
Personalizing without stigmatizing
Words matter. A campaign titled “at-risk employees” can discourage people from using the program. Universal communication offering several options reduces individual exposure and normalizes the diversity of needs. Mental health interventions must be designed with particular attention to stigma and working conditions.
The World Health Organization (WHO) recommends addressing psychosocial risks through organizational interventions that target working conditions and the work environment. An individual stress management tool is therefore no substitute for analyzing workload, management or work organization. The two levels complement each other.
The safeguards to require from a provider
Companies should check the purpose of each processing operation, the list of data collected, the recipients, the retention period, the security measures, how rights can be exercised and the aggregation rules. The legal role of each party and the incident process must also be clarified.
Data minimization is a practical principle: collect only what is necessary. If program management only requires an overall usage rate, the employer has no need to know the reason for a consultation. If a site-by-site analysis creates small identifiable groups, it must be adapted or dropped.
Designing an inclusive experience
Personalization must not depend exclusively on a recent smartphone, a smartwatch or strong digital literacy. Human alternatives, accessible interfaces, several languages and support must be provided. Night shifts, mobile workers and industrial sites must not be forgotten.
Involving employees and their representatives from the design stage makes the program more relevant. INRS, France’s national institute for occupational health and safety, recommends involving employees and their representatives in risk assessment and in choosing actions. This co-design also helps surface fears of surveillance before launch.
MyTwin’s approach for employers
MyTwin for employers lets companies choose prevention modules, roll out a personalized journey and track aggregated information. For MyTwin, employers must not have access to individual medical information. The app or custom interface must reflect this separation in roles and access rights.
The individual journey is presented on MyTwin for patients. Companies that want to scope their project can contact us.
Frequently asked questions
No. Personalization can take place in a confidential space without passing the medical profile on to the employer.
No. Taking part in a health promotion offer must remain voluntary and free of undue professional consequences.
No. Small groups or cross-referencing can allow re-identification. Thresholds must be applied and breakdowns limited.
No. The WHO also recommends organizational interventions on working conditions.
Legal, data protection, occupational health, IT security and the relevant employee representatives must be involved, depending on the project.
Sources
- CNIL, accessed September 9, 2026, “Données sur la santé : un employeur peut-il les connaître ?”.
- CNIL, May 22, 2024, “Quelles formalités pour les traitements de données de santé ?”.
- World Health Organization, September 2, 2024, “Mental health at work”.
- INRS, October 17, 2023, “Évaluation des risques professionnels”.
- International Labour Organization, March 29, 2019, “Make healthy employees a priority”.
This article is provided for information purposes only. It does not replace advice, diagnosis or treatment from a healthcare professional.