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Max Researcher at Non-Profit Research Company has a contract from the ACME Widget Company to conduct research evaluating their workplace wellness program. Employees that participate in the program receive HealthySensors that monitor physical activity (e.g., steps, heart rate, calories burned) and are eligible for a 10% reduction in their premium contributions if they succeed in their activity and weight goals. Max receives IRB approval to consent employees to release HealthySensor data for the NIH-funded Piggyback Research Study (unrelated to the workplace wellness program). Therefore, at the time of program enrollment, employees register their HealthySensors and authorize ACME Widget Company (a third party entity) to access HealthySensor’s data, and some employees authorize Max Researcher to use the sensor data for her NIH study.

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