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Corporate health programs with genetic analyses: voluntary, confidential, carefully planned

Reviewed by Dr. Daniel Wallerstorfer, molecular biologist and founder of Novogenia · Updated: 12 October 2026 · Reading time: 13 min

What a good program can achieve

How much does a workplace wellness program really achieve? One of the largest randomized trials on this question was run at a US warehouse retail company: 160 worksites, 32,974 employees. At 20 randomly selected worksites, employees were offered a program of eight modules on nutrition, physical activity and stress reduction, delivered by registered dietitians (Song & Baicker, JAMA 2019).

After 18 months, employees at these sites reported more often that they exercised regularly (69.8% vs. 61.9%) and actively managed their weight (69.2% vs. 54.7%). So a program can shift habits. Clinical measures such as cholesterol or blood pressure, health care spending and absenteeism showed no difference over this period – but on average, employees had completed only 1.3 of the eight modules. The logical conclusion: participation and support are the key.

This is where a genetic analysis can be a very personal starting point: employees learn something about their own body, not about the average. To turn that into change, support is needed – in a systematic review of 18 studies, simply communicating a DNA-based disease risk did not reliably change behavior (Hollands et al., BMJ 2016). Workshops, counseling and a working day that makes healthy choices easier close that gap.

The golden rule: the employer gets the invoice, not the result

Think of a sealed letter. The company pays the postage. But only the person it is addressed to may open the envelope. That is exactly how a genetic analysis works in a corporate health program. We know the principle from insurers that pay for analyses for their members: the member gets the results, the insurer only gets the invoice.

At Novogenia, there are two clearly separate routes:

The law requires this separation – in each country a little differently.

Germany: what the Genetic Diagnostics Act says about working life

Germany’s Genetic Diagnostics Act (Gendiagnostikgesetz, GenDG) explicitly applies to genetic examinations in working life (Section 2(1) GenDG). The rules are set out in Sections 19 to 22:

• No demanding, no using (Section 19): before or after employment begins, the employer may not demand that employees undergo genetic examinations or analyses. Nor may the employer demand that they disclose results, or receive or use such results.
• Occupational health screenings (Section 20): genetic examinations and analyses are prohibited within occupational health screenings (para. 1). Exceptions are narrow: gene product analyses for serious diseases that can arise at a specific workplace, as a lower priority than other occupational safety measures (para. 2), and by government regulation (para. 3).
• No discrimination (Section 21): the employer may not discriminate against employees because of their genetic traits – including when they refuse to undergo genetic examinations or to disclose results.
• Public service (Section 22): the rules apply accordingly, for example to federal civil servants and judges and to soldiers.

For medical analyses, the general rules of the GenDG also apply. Diagnostic genetic examinations may only be carried out by physicians, and predictive ones only by specialists in human genetics or physicians with an equivalent qualification (Section 7(1)). Consent must be explicit and in writing, given to the responsible physician (Section 8(1)). Genetic counseling is required before and after a predictive examination, unless the person waives it in writing (Section 10(2)). The result goes only to the person tested, communicated by the physician (Section 11(1)); it may be passed on to others only with explicit consent in written or electronic form (Section 11(3)).

What does this mean in practice? Never plan medical analyses as part of occupational health screening. Plan them as a voluntary medical service kept separate from the employer – and have the concept reviewed legally before you start.

Austria: the ban on use in the Gene Technology Act

Under Section 67(1) of the Austrian Gene Technology Act (Gentechnikgesetz, GTG), employers and insurers, including their agents and staff, are prohibited from collecting, demanding, accepting or otherwise using the results of genetic analyses of employees or job seekers. The ban also covers demanding or accepting body substances for genetic analysis. The exception in para. 2 applies only to insurers – not to employers.

One subtlety: the GTG defines a genetic analysis as a laboratory analysis that allows statements about carrier status, a disease risk, an existing disease or the course of a disease or therapy (Section 4(23) GTG). Whether a pure lifestyle analysis falls under this definition is not clearly answered by the text of the law. Our advice: plan every program as if Section 67 applies.

Two practical rules follow:

• Samples never go through the company: saliva samples do not pass through HR or any other part of the employer. Employees send their sample directly to the lab themselves.
• Medical analyses only through specialists: analyses of predispositions to disease (types 3 and 4) may only be carried out in approved facilities and only at the request of a specialist in human/medical genetics or the specialist responsible for the indication (Section 68(1) GTG). Personal data from such analyses may be passed on to other persons only with the explicit written consent of the person tested (Section 71(2) GTG).

GDPR: special data in a special relationship

Genetic data belong to the special categories of personal data. Processing them is prohibited (Art. 9(1) GDPR) unless an exception applies – for example explicit consent for specified purposes (Art. 9(2)(a)) or occupational medicine by professionals bound by professional secrecy (Art. 9(2)(h) and 9(3)). For genetic data, member states may introduce further conditions (Art. 9(4)) – the GenDG and the GTG are such national rules.

For employee data, Art. 88 GDPR allows member states to adopt more specific rules – with specific measures to safeguard dignity, legitimate interests and fundamental rights, particularly transparency (Art. 88(2)). Germany provides in Section 26(2) of the Federal Data Protection Act (BDSG) that the dependency inherent in employment must be taken into account when judging whether consent is voluntary, that consent must be given in writing or electronically, and that the employer must inform employees in text form about the purpose and their right to withdraw.

The delicate point is voluntariness. Consent must be freely given (Art. 4(11) GDPR); where there is a clear imbalance between the parties, that is doubtful (Recital 43). The European Data Protection Board is explicit in its Guidelines 05/2020: because of the dependency in an employment relationship, it considers it problematic for employers to process data on the basis of consent. Employees can only give free consent in exceptional circumstances – when it has no adverse consequences at all whether or not they consent.

The most elegant solution: the employer does not process any genetic data at all. Employees consent directly to the lab or partner; the company pays and stays shut out of the results. More on consent, roles and deletion periods in Genetic data and the GDPR.

Switzerland: stricter rules for the analysis itself

Switzerland explicitly regulates genetic tests outside medicine in the Federal Act on Human Genetic Testing (GUMG, in English HGTA). For a company program, there are therefore two layers of rules: one for the employer and one for the analysis itself.

What the employer may not do:

• No requiring, no using (Art. 37 GUMG): employers may neither require non-medical genetic testing nor request medically irrelevant genetic data, nor make use of any such data.
• Testing in connection with employment (Art. 38–40 GUMG): genetic testing prescribed in connection with employment may only identify characteristics relevant in the workplace, and the physician may only tell the employer whether the person can be considered for the intended activity. Neither the employer nor a physician engaged by the employer may require presymptomatic genetic tests – with a narrow exception to prevent occupational diseases and accidents (Art. 40).
• Only necessary data (Art. 328b of the Code of Obligations, OR): the employer may only process data about employees insofar as it concerns their suitability for the job or is necessary for performing the employment contract.

This leaves very little room in Switzerland for medical prevention analyses through a company physician. Be sure to have any such concept reviewed in advance.

What applies to the lifestyle analysis itself: analyses of physiological characteristics whose knowledge can influence lifestyle – such as eating behavior, physical activity and general well-being – count as tests of particularly sensitive characteristics (Art. 31(1)(a) GUMG, Art. 37(1) of the Ordinance on Human Genetic Testing, GUMV). Information on food intolerances or on an increased risk of sports injuries, by contrast, belongs to the medical field (Art. 37(2) GUMV). This means:

• Only authorized professionals prescribe: physicians, pharmacists, psychologists, druggists with a college of higher education diploma (HF) and – for physiological characteristics – nutritionists, physiotherapists (both with a university of applied sciences degree, FH), chiropractors and osteopaths (Art. 34 GUMG, Art. 40 GUMV).
• Sample in the professional’s presence: the sample must be collected in the presence of the prescribing person (Art. 34(3) GUMG). Self-testing kits may only be supplied for other tests such as hair or eye color (Art. 13 GUMG) – so a home kit is not an option for lifestyle analyses.
• Inform in writing: including about the lab performing the test and any companies and labs abroad involved (Art. 32 GUMG).
• Lab abroad only with consent: testing abroad requires, among other things, the written consent of the person concerned (Art. 36 in conjunction with Art. 29 GUMG).
• Data protection: genetic data are sensitive personal data (Art. 5(c)(3) of the Data Protection Act, FADP); where consent is required, it must be voluntary, based on appropriate information and explicit (Art. 6(6) and (7) FADP).

A program in Switzerland therefore needs an authorized health professional on board – for example a pharmacy, a medical practice or a nutritionist (FH) – who prescribes the analysis and is present when the saliva sample is taken. At a glance:

Seven steps to a corporate longevity program

1. Agree on goals and scope: what should the program achieve – and what not? Involve management, HR and, where they exist, the works council and the data protection officer early on.
2. Choose the analyses: lifestyle analyses on nutrition and weight, sports and performance, stress or skin. Medical analyses only if a suitably qualified company physician takes responsibility for them. In Switzerland, an authorized health professional also prescribes the lifestyle analysis.
3. Invite without pressure: explain openly what the analysis shows and what it does not. Participation is voluntary; anyone who does not take part faces no disadvantage.
4. Consent directly: employees register themselves and give their consent to the lab or partner – not to the employer.
5. Saliva sample: in Germany and Austria at home; the sample goes straight from the employee to the lab, never through the company. In Switzerland in the presence of the prescribing professional. The analysis takes 4 days.
6. Report to the person only: digitally via a secure portal, in up to 18 languages. The employer receives no individual results and no aggregated reports either.
7. Support instead of evaluating: workshops on physical activity, sleep and nutrition, voluntary one-to-one counseling by external professionals. Evaluate the program through anonymous feedback – never through genetic results.

Checklist before you start

• Participation is voluntary, and those who do not take part face no disadvantage of any kind.
• The employer does not demand analyses and receives no results, no samples and no reports.
• Employees give their consent directly to the lab or partner, explicitly and for specified purposes.
• Saliva samples go directly to the lab – in Switzerland collected in the presence of the prescribing health professional.
• Lifestyle and medical analyses are clearly separated; medical ones only through qualified physicians and never as part of occupational health screening.
• The information for employees explains what the analysis shows, what it does not and who sees which data.
• The concept has been legally reviewed for every country in which employees take part.
• The program promises no health outcomes and no cost savings.

How to launch an offer for companies with Novogenia is covered in Launching a longevity offer: partner models and process. Which analyses you may offer without a physician is explained in Who may offer genetic tests?

Frequently asked questions

Related: Genetic data and the GDPR · Who may offer genetic tests? · Launching a longevity offer

Note: This guide is general information for businesses and professionals and does not replace medical or legal advice. Novogenia longevity products are food supplements and not a substitute for a balanced, varied diet and a healthy lifestyle; statements in this guide are not promises of cure and not statements on the prevention, treatment or healing of diseases. Recommendations derived from genetic analyses are logical conclusions, not scientifically proven. Regulations can change; errors and changes excepted.