1. Transparency and Notice
Employers should be transparent about their reasons for offering a PHR to employees and all policies that apply to the PHR. Employers should provide an Information Policy Statement or Notice that clearly lays out the ways in which information in the PHR will be used and safeguarded. Employers should incorporate the Notice into their health benefit programs, and should make it available in a layered format—a short concise version to accompany a more detailed one. Employees should be informed of any updates to the policy.