Public Online Privacy Statement
SIMPLICITYHEALTHPLANS Websites: September 16, 2006
Why is this Public Online Privacy Statement important to me? This statement explains how we handle information that we gather when you visit our public websites.
We will display a new date next to the Public Online Privacy Statement link on the Privacy Information page whenever this statement is updated or changed. We will also display a new date next to the Privacy Information link on the SIMPLICITYHEALTHPLANS.com home page whenever this statement or any of the privacy notices are updated or changed. You should check this statement periodically. When you choose to continue using our public* websites, you agree to the terms of the statement.
Your visit to our websites and any dispute over privacy is subject to this statement and our Legal Disclaimer/Conditions of Use including limitations of damages, application of the law of the State of Ohio and exclusive jurisdiction of Ohio.
If you have any questions or comments about this statement, please contact us by postal mail at:
- SIMPLICITYHEALTHPLANS Public Online Privacy Statement
- Attention: Tomas Brian
- 20600 Chagrin Blvd. Suite 450
- Shaker Heights, Ohio 44122
- Toll Free: 877-747-1113
- Fax: 216-283-7931
Do the sites that you link to have the same privacy practices? We can't guarantee that links to sites we don't own or control have the same privacy practices, so we can't assume responsibility for them. Be sure to read those privacy policies once you leave our public websites.
What types of information do you collect online? We've designed our public websites to capture two types of information: automatic tracking and individually identifiable personal information ("personal information"). The first allows us to see which topics interest you most; the second helps us service any accounts you may have with our businesses:
Automatic tracking information is gathered by following your "footsteps" online. Most Web browsers automatically provide this information to the sites they visit and display. We do not collect any additional data from your computer, and we do not compare data provided by your browser with any other data we maintain. The routes you - and other visitors - choose help us learn about the people who visit our sites. We use aggregate numbers to compile statistics, monitor trends and track site usage. We also use the information to make sure our technology is compatible with yours. We're then better able to offer content, products and services that match your needs.
Personal information can be anything you've provided through our public websites that identifies you or your accounts. For example: Your name, social security number, birth date, address and names of your dependents are types of personal information. We use this information to service your accounts and online transactions. It's our policy to send and receive individualized information through encrypted channels only.
To use our secure services, "cookies" must be enabled. Cookies are pieces of information that are stored in your computer when you visit a Web site.
How secure is my personal information online? When you submit your personal information through our secure Web forms, it is processed on our public websites and protected from unauthorized access by a secure firewall and security infrastructure. During transmission, your privacy is protected by Secure Socket Layer 128-bit encrypting software. Then when the information is received, we employ extensive physical, electronic and procedural safeguards to make sure it remains secure. We also conduct periodic reviews of our Web site security to ensure that our electronic safeguards remain up-to-date and effective. Sending personal information through links to email addresses, however, is not secure. Please read more about sending email.
What do you do with the information you collect about me on your public websites? We will not sell, rent or license the personal information you provide within our public websites unless you authorize it. But we may need to use it within the SIMPLICITYHEALTHPLANS family of affiliate companies or with a third-party vendor to perform administrative, technical, hosting, marketing or other functions that help us manage the sites while providing service to you. Our third-party vendors who process your personal information also subscribe to the privacy practices in this online statement. Except as noted above, we will not release personal information to any other party unless required to do so by government authorities or legal process or as otherwise permitted by law.
What if I don't want you to collect, use or distribute my information electronically? If you don't want us to collect, use or distribute information about you on our public websites, there are always traditional means of communication available. You can call us or send your questions, comments and specific information by regular mail.
What should I know about sending email? Remember that email messages can be viewed by other Internet users while in transit. Please do not email personal information unless you do so through a secure channel. We have a policy that prohibits us from communicating personal information through non-secure email. If you have personal information to communicate, please use the secure forms available on our public websites, contact your local customer service representative, or email us a request for your customer service representative to contact you.
Sometimes when I'm online, I encounter pop-up ads, unusual links or other behavior that I find annoying and distracting. What is SIMPLICITYHEALTHPLANS position on these pop-ups and links? This type of behavior is the result of "adware" and "spyware." "Spyware" is technology that tracks a site visitor's online behavior without his or her knowledge. "Adware" is software that displays advertising banners. Adware and spyware can be combined to track a person's preferences and distribute them to third parties. We do not use these technologies and urge site visitors to practice "safe computing" by verifying the source of online offers before downloading software or visiting other sites. For more information, visit One Look and search on the terms "spyware" and "adware."
Is there more information I should read? This statement explains how we handle the information we collect if you are a visitor on our public websites. But if you visit our secure* websites that are only accessible to individuals who have relationships with us through our businesses (for example, are covered by an Employer Sponsored health plan), or you contact us offline (for example, by phone) because you have a business relationship with us, please read the business notices from the main Privacy Information page. They explain more specifically how we treat your personal information and your rights regarding personal information.
How does this privacy statement apply to me if I'm not a U.S. customer? Your continued use of our public websites from within the European Union ("EU") or other non-U.S. country means that you are giving your consent to have your personal information processed outside the EU or other country in accordance with the protection described in our privacy pages.
* "Public" describes sites that do not require a password to access information. "Secure" describes sites that do require a password to log in before accessing information.
Standard Privacy Practices
This Notice is Effective October 15, 2007
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This notice describes how health information about you may be used and disclosed and how you can get access to this information. Please review it carefully.
SimplicityHealthPlans* is committed to maintaining and protecting the confidentiality of our members' personal information. We are required by federal and state law to protect the privacy of your Protected Health Information (PHI) and other personal information about you. In this Notice, we will refer to this information as "confidential information." We also are required to send you this Notice about our policies, safeguards and practices. When we use or disclose your confidential information, we are bound by the terms of this Notice or our revised notice, if we revise it.
How We Protect Your Privacy To help manage your health insurance benefits, SimplicityHealthPlans receives confidential information from you and from other sources such as your health care providers, insurers and your employer. The information we receive includes Protected Health Information (PHI) as well as your name and address. SimplicityHealthPlans will not disclose confidential information without your authorization unless it is necessary to provide your health benefits, help manage your benefit plan, to support SimplicityHealthPlans programs or services, or as otherwise required or permitted by law. When we need to disclose your confidential information, we will follow the policies described in this Notice to protect your privacy.
SimplicityHealthPlans locations that maintain confidential information have procedures for accessing, labeling and storing confidential records. Access to our facilities is limited to authorized personnel. We restrict internal access to your confidential information to SimplicityHealthPlans employees who need to know that information to conduct our business. SimplicityHealthPlans trains its employees on policies and procedures designed to protect your privacy. Our Privacy Office monitors how we follow those policies and procedures and educates our organization on this important topic.
How We Use and Disclose Your Confidential Information We will not use your confidential information or disclose it to others without your authorization, except for the following purposes:
Please note that should your coverage under your Employer Sponsored health plan terminate, we will continue to protect your confidential information. It will be used and disclosed only for the purposes described above and in accordance with the policies and procedures described in this Notice.
- Treatment. We may disclose your confidential information to your doctors, hospitals and other health care providers for their provision, coordination or management of your health care and related services - for example, for coordinating your health care with us or for referring you to another provider for care.
- Payment. We may use and disclose your confidential information to obtain payment of medical bills for your coverage and to determine and fulfill our responsibility to help manage your health plan benefits - for example, to make coverage determinations, administer claims and coordinate benefits with other coverage you may have. We also may disclose your confidential information to another health plan or a health care provider for its payment activities - for example, for the other health plan to determine your eligibility or coverage, or for the health care provider to obtain payment for health care services provided to you.
- Health Care Operations. We may use and disclose your confidential information for our health care operations - for example, to provide customer service and conduct quality assessment and improvement activities. Other health operations may include providing appointment reminders or sending you information about treatment alternatives or other health-related benefits and services. We also may disclose your confidential information to another health plan or a provider who has a relationship with you, so that it can conduct quality assessment and improvement activities - for example, to perform case management, disease management or health coaching.
- Disclosure to Persons Involved in Your Care. We may disclose confidential information about you or your child to persons who are involved in your or your child's care or payment for that care. For example, we might disclose confidential information about you to your spouse or confidential information about your child to your former spouse who is the parent of your child. We will disclose only the information that is relevant to the care or payment. Callers will be asked to provide identifying information and, if they are asking about a claim, they will have to show knowledge of that claim before we will answer their questions. You have the right to stop or limit this kind of disclosure by requesting a restriction on the disclosure of your confidential information as described below under "Right to Request Additional Restrictions."
- Disclosures to your Employer as Sponsor of Your Health Plan. We may disclose your confidential information to your employer or to a company acting on your employer's behalf, so that it can monitor, audit and otherwise administer the employee health benefit plan in which you participate. Your employer is not permitted to use the confidential information we disclose for any purpose other than administration of your health benefit plan. See your employer's health benefit plan documents for information on whether your employer receives confidential information and the identity of the employees who are authorized to receive your confidential information.
- Disclosures to SimplicityHealthPlans Vendors and Accreditation Organizations. We may disclose your confidential information to companies with whom we contract if they need it to perform the services we've requested — for example, vendors who help us provide important information and guidance to members with chronic conditions like diabetes and asthma. SimplicityHealthPlans also discloses confidential information to accreditation organizations such as the National Committee for Quality Assurance (NCQA) when the NCQA auditors collect Health Plan Employer Data and Information Set (HEDIS®)** data for quality measurement purposes. When we enter into these types of arrangements, we obtain a written agreement to protect your confidential information.
- Promotional Gifts. We may use your confidential information or disclose it to a mailing vendor so that we may provide you with a promotional gift of nominal value such as a pen or a calendar. We will not disclose your confidential information to other companies for their marketing purposes.
- Public Health Activities. We may disclose your confidential information for the following public health activities and purposes: (1) to report health information to public health authorities that are authorized by law to receive such information for the purpose of preventing or controlling disease, injury or disability; (2) to report child abuse or neglect to a government authority that is authorized by law to receive such reports; (3) to report information about a product or activity that is regulated by the U.S. Food and Drug Administration (FDA) to a person responsible for the quality, safety or effectiveness of the product or activity; and (4) to alert a person who may have been exposed to a communicable disease, if we are authorized by law to give this notice.
- Health Oversight Activities. We may disclose your confidential information to a government agency that is legally responsible for oversight of the health care system or for ensuring compliance with the rules of government benefit programs, such as Medicare or Medicaid, or other regulatory programs that need health information to determine compliance.
- For Research. Under very limited circumstances, your confidential information may be used and disclosed for research without an authorization - for example, an authorization would not be necessary if your name, street address and other identifying information were removed.
- To Comply with the Law. We may use and disclose your confidential information to comply with the law.
- Judicial and Administrative Proceedings. We may disclose your confidential information in a judicial or administrative proceeding or in response to a legal order.
- Law Enforcement Officials. We may disclose your confidential information to the police or other law enforcement officials, as required by law or in compliance with a court order or other processes authorized by law.
- Health or Safety. We may disclose your confidential information to prevent or lessen a serious and imminent threat to your health or safety or the health and safety of the general public.
- Government Functions. We may disclose your confidential information to the U.S. military or to authorized federal officials for purposes specified by federal law.
- Workers' Compensation. We may disclose your confidential information when necessary to comply with workers' compensation laws.
Uses and Disclosures with Your Written Authorization We will not use or disclose your confidential information for any purpose other than the purposes described in this Notice without your written authorization. For example, we will not supply confidential information to another company for its marketing purposes or to a potential employer with whom you are seeking employment without your signed authorization. You may revoke an authorization that you previously have given by sending a written request to our Privacy Office, but not with respect to any actions we already have taken.
SimplicityHealthPlans complies with state laws that place further restrictions on the disclosure of your Protected Health Information (PHI) without your authorization. For example, many states have laws that do not permit us to disclose a diagnosis of AIDS or mental illness. These laws have some limited exceptions.
Your Individual Rights
If you wish to make any of the requests listed above under "Individual Rights," you must complete and mail us the appropriate form. To obtain the form please visit our Web site at http://www.SimplicityHealthPlans.com/privacy/ and print the appropriate form. Or you can call Member Services at the toll-free number on your SimplicityHealthPlans ID card to request the appropriate form. Forms should be mailed to the address printed on the forms. After we receive your signed, completed form, we will respond to your request.
- Right to Request Additional Restrictions. You may request restrictions on our use and disclosure of your confidential information for the treatment, payment and health care operations purposes explained in this Notice. While we will consider all requests for restrictions carefully, we are not required to agree to a requested restriction.
- Right to Receive Confidential Communications. You may ask to receive communications of your confidential information from us by alternative means of communication or at alternative locations. While we will consider reasonable requests carefully, we are not required to agree to all requests.
- Right to Inspect and Copy your Confidential Information. You may ask to inspect or to obtain a copy of your confidential information that is included in certain records we maintain. Under limited circumstances, we may deny you access to all or a portion of your records. If you request copies, we may charge you copying and mailing costs.
- Right to Amend your Records. You have the right to ask us to amend your confidential information that is contained in certain records we maintain. If we determine that the record is inaccurate, and the law permits us to amend it, we will correct it. If your doctor or another person created the information that you want to change, you should ask that person to amend the information.
- Right to Receive an Accounting of Disclosures. Upon request, you may obtain an accounting of disclosures we have made of your confidential information. The accounting that we provide will not include disclosures made before April 14, 2003, disclosures made for treatment, payment or health care operations, and disclosures made earlier than six years before the date of your request, and certain other disclosures that are excepted by law. If you request an accounting more than once during any 12-month period, we will charge you a reasonable fee for each accounting statement after the first one.
- Right to Receive Paper Copy of this Notice. You may call Member Services at the toll-free number on your SimplicityHealthPlans ID card to obtain a paper copy of this Notice, even if you previously agreed to receive this Notice electronically.
- For More Information or Complaints. If you want more information about your privacy rights, do not understand your privacy rights, are concerned that we have violated your privacy rights or disagree with a decision that we made about access to your confidential information, you may contact our Privacy Office. You may also file written complaints with the Secretary of the U.S. Department of Health and Human Services. Please call our Privacy Office to obtain the correct address for the Secretary. We will not take any action against you if you file a complaint with the Secretary or us.
You may contact our Privacy Office at:
20600 Chagrin Blvd. Suite 450
Shaker Heights, Ohio 44122
Toll Free: 877-747-1113
We may change the terms of this Notice at any time. If we change this Notice, we may make the new notice terms effective for all of your confidential information that we maintain, including any information we created or received before we issued the new notice. If we change this Notice, we will send you the new notice if you are enrolled in an Employer Sponsored health plan to which SimplicityHealthPlans contracts services at that time. In addition, we will post any new notice on our Web site at http://www.SimplicityHealthPlans.com/privacy/ You also may obtain any new notice by calling Member Services at the toll-free number on your SimplicityHealthPlans ID card.
** "HEDIS" is a registered trademark of the National Committee for Quality Assurance (NCQA).
Reminder Regarding Access to Notice of Privacy Practices
The HIPAA Privacy Rule contains a requirement that every three years covered entities must notify their enrollees of where they can access the Notice of Privacy Practices. The Privacy Rule became effective in April 2003. The SimplicityHealthPlans Notice of Privacy Practices was updated in October 15, 2007 and reissued by mail to all SimplicityHealthPlans members of record. To fulfill the reminder requirement, SimplicityHealthPlans is sending the following reminder to all subscribers in October 15, 2007.
SimplicityHealthPlans is committed to maintaining and protecting the confidentiality of our members' personal and sensitive information. This is an important reminder of where you can access the Notice of Privacy Practices.
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) protects the privacy of your Protected Health Information (PHI). SimplicityHealthPlans is sending you this reminder as required by federal regulations governing the privacy of your Protected Health Information (PHI). SimplicityHealthPlans issued to you a Notice of Privacy Practices, which explains how SimplicityHealthPlans uses and discloses your Protected Health Information (PHI); your individual privacy rights related to your Protected Health Information (PHI); and how we protect your Protected Health Information (PHI). To obtain a copy of this Notice of Privacy Practices, you can call the number on your ID card and we will mail one to you, or go online to SIMPLICITYHEALTHPLANS.com and click on "Privacy" at the bottom of the page.
Gramm-Leach-Bliley Privacy Notice
IMPORTANT: The following notice is designed to comply with the Gramm-Leach-Bliley Act regulations. A separate notice designed to meet the requirements of the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule was provided to your employees either prior to April 14, 2003 or at the time they enrolled.
for Employer Sponsored plan members
At SimplicityHealthPlans, we’re committed to maintaining the confidentiality of your employees’ personal health and financial information (“personal information”). We have developed internal policies and procedures to comply with our Confidentiality Policy and with state and federal privacy laws. This notice answers some common questions about our confidentiality policies.
HOW DO WE PROTECT YOUR EMPLOYEES’ PERSONAL INFORMATION?
SimplicityHealthPlans employees and organizations that act on behalf of SimplicityHealthPlans are required to keep your employees’ personal information confidential. Here’s what we are doing to help ensure this policy is followed:
WHAT TYPES OF PERSONAL INFORMATION DO WE RECEIVE?
- We’ve established a SimplicityHealthPlans privacy program office, which is responsible for monitoring our compliance with confidentiality policies and for educating SimplicityHealthPlans employees on this important topic.
- Whenever possible, we provide only aggregate information that doesn’t identify any individual.
- If we need to share your employees’ personal information, we have policies and procedures that protect confidentiality.
- Our employees may not disclose personal information to other employees except when it is needed to conduct SimplicityHealthPlans operations.
- In accordance with the HIPAA Privacy Rule, we require business associates who receive personal information and act on our behalf or provide a service to us to sign an agreement in which they promise that they will use information only for the purposes for which it was provided.
- In some situations, we require a member’s written authorization before we disclose personal information. For example, we will not supply personal information to a potential employer with whom a member is seeking employment without the member’s signed authorization, and we will not supply personal information to another company for its marketing purposes.
- We restrict access to personal information about our members to employees, service providers, and companies that are involved in administering health care coverage and servicing our members. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard the personal information of our members.
We may receive personal information about your employees from you or from your employees at the time of enrollment. We also receive personal information needed for our vendors and us to manage your plan from your employees when they submit a claim or enrollment information. In addition, members may have been covered under another health plan, which may provide us with personal information to coordinate benefits. Lastly, we receive personal information from health providers and payroll deduction histories and other financial transactions from you or from a bank. The information we receive includes Protected Health Information (PHI) as well as names, addresses and social security numbers.
WHAT TYPES OF PERSONAL INFORMATION DO WE DISCLOSE, AND TO WHOM?
SimplicityHealthPlans will not release confidential information unless it is used by itself or its vendor business associates to manage the benefits plan or to support SimplicityHealthPlans programs or services, such as our care management and wellness programs. We may disclose Protected Health Information (PHI) or other types of information, including names addresses and social security numbers, to:
- Medical providers and plan sponsors
- Insurers that provide reinsurance or excess (stop loss) insurance to an employer or with whom we are coordinating benefits.
- QuickPayNet, Ltd, DBA SimplicityHealthPlans affiliated companies and business associates like Advocare, Inc, Anthem Partners Rx, Whole Health Management, Inc., Employee Benefit Management Corp, and other business associates required to manage the members health benefits, such as dental and vision plans.
- Regulatory agencies such as departments of insurance and accreditation organizations such as the National Committee for Quality Assurance.
- Courts or attorneys who serve us with a subpoena.
- Successor companies or claim administrators who assume responsibility for administering your benefit plan.
- Companies that assist SimplicityHealthPlans in recovering overpayments, paying claims or performing utilization review services.
- Other companies not affiliated with SimplicityHealthPlans that provide services to us when disclosure is permitted or required by law.
The forms* listed below are for submitting requests mentioned in the "SimplicityHealthPlans Notice of Privacy Practices.
If you need to submit a request, select the appropriate link to print a form.
Please note: SimplicityHealthPlans will not disclose confidential information without your authorization unless it is necessary for it or its business associates to manage your health benefits, administer your benefit plan, support SimplicityHealthPlans programs or services, or as otherwise required or permitted by law. We will not, for example, give your confidential information to a credit agency, a telemarketer or a prospective employer. We will not sell, rent or license the confidential information you provide to us including any information you provide within our public Web sites unless you authorize it. Our Privacy Notice that we have sent to all SimplicityHealthPlans members describes more fully how we use your information. You may also read a copy of the Privacy Notice on this Web site.