GINA Title II separation

Last updated: 2026-05-27

The U.S. Genetic Information Nondiscrimination Act of 2008 (“GINA”) Title II prohibits employers from requesting, requiring, or purchasing the genetic information of employees, with limited exceptions. Vogelview’s corporate / enterprise product is designed so that employers cannot access an individual employee’s genetic information through the platform.

How separation works

1. Individual accounts only. Genetic data is uploaded by the individual employee using their personal Vogelview account. The employer does not see the upload, the parsed variants, or any individual finding.
2. Aggregate-only reporting. Corporate administrators only see fully aggregated, deidentified cohort metrics — never per-employee data. Cohort views are gated by a minimum-cohort size of 10 to prevent re-identification.
3. Distinct authorization. The Firestore security rules enforce that a corporate admin token has access only to corporateAccounts and aggregate analytics collections, never to uploads, reports, or parsedVariants of any user.
4. Audit trail. Every administrative action is logged with actor uid, action, and timestamp in auditLog. Admin attempts to access individual data are denied at the API layer.

What employers can see

• Seat license counts and billing.
• Aggregate engagement (upload counts, report-generation counts) at the cohort level (n ≥ 10).
• Anonymous usage patterns for benefits design.

What employers cannot see

• Individual employee names linked to genetic data.
• Variant lists, findings, or PRS scores at the individual level.
• Family member data uploaded under an employee’s account.
• Pharmacogenomic recommendations or medication lists.

Wellness program compliance

When Vogelview is offered as part of an employer-sponsored wellness program, the program must comply with the EEOC’s ADA/GINA wellness program regulations: voluntary participation, separate written consent, and prohibition of incentives that would render participation effectively involuntary. Vogelview provides this consent flow as a configurable step in corporate onboarding.

Reporting concerns

If you believe genetic data has been improperly accessed or used, email privacy@vogelview.health. You may also file a complaint with the U.S. Equal Employment Opportunity Commission (EEOC) at eeoc.gov.