SENIOR HEALTH INSURANCE COMPANY OF PENNSYLVANIA (IN REHABILITATION) COMBINED HIPAA AND GLBA PRIVACY NOTICE
THIS NOTICE DESCRIBES HOW PERSONAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
This Privacy Notice is applicable to the long-term care insurance business of Senior Health Insurance Company of Pennsylvania (In Rehabilitation) (the “Company”). This notice refers to the Company by using the terms "us", "we", or "our".
Our goal is to provide you with high-quality services. To do that, we may collect and maintain Personal Information about you. We realize we have an important responsibility to protect the privacy and security of your Personal Information, and we do so by adhering to security measures that comply with federal law, and that incorporate reasonable technical, physical, and administrative safeguards. We are providing this Notice to give you a better understanding of our privacy and security policies. Uses and disclosures of Personal Information not described in this notice will be made only with your written authorization.
We use the term “Personal Information” in this Notice to mean any non-public, personally identifiable information about you that we may obtain or create in connection with administering your insurance. Personal Information also includes health information, which consists of information that can be used to identify you and that relates to your physical or mental health condition, the provision of health care to you, or the payment for such health care.
Information We Collect
We collect Personal Information about you from:
Information you provide in applications, claims forms and other forms you complete (for example, your Social Security number, age, occupation, and physical condition)
Your transactions with us and our affiliates and agents (for example, your claims history, eligibility information, and payment information)
Medical professionals and facilities that have provided services to you (for example, the type of services provided, the dates of service, and your medical history)
Uses and Disclosures of Your Personal Information
To provide services to you, we may obtain services from affiliates or nonaffiliated third parties, such as businesses providing underwriting support services, actuarial services, legal services, care coordination services, or data management services. We may disclose your Personal Information to persons providing such services. The purposes for which we may use or disclose Personal Information are described below. Please note that your policy is administered by Long Term Care Group, Inc.
For Treatment: We do not make treatment decisions, but we may disclose Personal Information to those who do. For example, we may disclose information regarding your benefits to doctors, hospitals, long-term care facilities, and other health care providers who take care of you.
For Claim Processing and Other Payment Related Purposes: We may use and disclose your Personal Information for benefit verification and claim processing purposes. For instance, we may use information regarding long-term care services you receive from service providers such as nursing homes, assisted living facilities, and home health care agencies to process and pay claims. Other examples of payment related purposes for which may use or disclose Personal Information include authorizing covered services, collecting premiums, and obtaining payment from reinsurers.
For Health Care Operations: We may use and disclose your Personal Information as necessary, and as permitted by law, for our health care operations which include underwriting, premium rating, customer service, reinsurance, compliance, fraud prevention and reporting, auditing, agent commission reconciliation, consumer wellness, and other activities related to the issuance, renewal, replacement, or continuation of your insurance coverage.
Family and Friends Involved in Your Care: We may from time to time disclose your Personal Information to certain family members, friends, and others who are involved in your care or in the payment of your care. If you are unavailable, incapacitated, or facing an emergency medical situation and we determine that a limited disclosure may be in your best interest, we may share limited Personal Information with such individuals without your written authorization. If you have designated a person to help prevent the unintentional lapse of your coverage, we will inform that person prior to terminating the policy for nonpayment of premium. We may also disclose limited Personal Information to a public or private entity that is authorized to assist in disaster relief efforts in order for that entity to locate a family member or other persons that may be involved in some aspect of caring for you.
Business Associates: We may contract with various individuals and/or entities, known as “business associates,” to perform certain functions on our behalf and at our direction, or to provide delineated services. They may include insurance agents, claim payment administrators, information technology providers, and others. We may disclose your health information to a business associate if the information is needed in order to provide a service to us. We enter into agreements with these business associates concerning the privacy and security of your health information and they are legally obligated under federal law to protect your information to the same extent that we are obligated to do so.
Required Disclosures: We may be required to disclose your information to the Secretary of the U.S. Department of Health and Human Services when the Secretary is investigating or determining our compliance with the HIPAA Privacy Regulations. We are also required to disclose to you most of your information in a “designated record set” when you request access to this information pursuant to the procedures set forth below.
Other Uses and Disclosures for Public Health, Government Oversight, or Similar Activities
We are permitted or required by law to make certain other uses and disclosures of your Personal Information without your authorization.
We may use or disclose your Personal Information for any purpose allowed or required by law.
We may disclose your Personal Information to law enforcement officials as allowed by law.
We may use or disclose your Personal Information for public health activities, such as permitted reporting of disease, injury, death and for required public health investigations.
We may disclose your Personal Information as required by law if we believe you to be a victim of abuse, neglect, or domestic violence.
We may disclose your Personal Information if required by law to a government oversight agency conducting audits, investigations (such as investigations into consumer complaints), or civil or criminal proceedings.
We may disclose your Personal Information if required to do so by a court or administrative ordered subpoena or discovery request.
We may use or disclose your Personal Information to prevent criminal activity, fraud, material misrepresentation, or material non-disclosure in connection with your coverage or application for coverage.
We may disclose your Personal Information to a coroner, medical examiner, or funeral director as allowed by law.
We may use or disclose your Personal Information to facilitate organ, eye, or tissue donation or transplantation.
We may use or disclose your Personal Information for research purposes as allowed by law but subject to certain privacy controls.
We may use or disclose your Personal Information to avert a serious and imminent threat to the health and safety of a person or the public.
We may use or disclosure your Personal Information for certain specialized government functions such as military and veterans’ activities, national security and intelligence activities, medical suitability determinations, and activities related to correctional institutions, and other custodial situations.
We may disclose your Personal Information to comply with workers compensation laws.
Rights That You Have
Your rights are explained below. Any written requests to exercise those rights should be directed to the individual at the address provided at the end of this notice.
Right to Access. You have the right to inspect and copy Personal Information we may use to make decisions. All requests must be made in writing and signed by you or your representative. We may charge a reasonable fee for copies and postage. You also have the right to request this information in electronic form if we maintain such information electronically.
Right to Confidential Communications. You have the right to request that we send communications of Personal Information to you by alternative means or to alternative locations if all or part of that information could endanger you. For example, you may ask that we contact you at work, rather than at home. We will try to accommodate reasonable requests.
Right to Amend. You have the right to request in writing that Personal Information we maintain about you be amended or corrected. We are not obligated to make all requested amendments but will give each request careful consideration. If we deny a request, we will explain the reason for our denial. All amendment requests, in order to be considered by us, must be in writing, signed by you or your representative, and must state the reasons for the amendment/correction request. If an amendment or correction you request is made by us, we may also notify others who work with us and have copies of the uncorrected record if we believe that such notification is necessary.
Right to an Accounting of Disclosures. You have the right to receive an accounting of certain disclosures made by us of your Personal Information. Requests must be made in writing and signed by you or your representative. The first accounting in any 12-month period is free; you may be charged a reasonable fee for each subsequent accounting you request within the same 12-month period. We will notify you of the cost involved and you may choose to withdraw or modify your request before any costs are incurred.
Right to Request Restrictions. You have the right to request restrictions on certain of our uses and disclosures of your Personal Information for payment, or health care operations by notifying us of your request for a restriction in writing. Your request must describe in detail the restriction you are requesting. We are not required to agree to your restriction request but will attempt to accommodate reasonable requests when appropriate and we retain the right to terminate an agreed-to restriction if we believe such termination is appropriate. In the event of a termination by us, we will notify you of such termination. You also have the right to terminate in writing any agreed-to restriction by sending such termination notice to us at the address given below.
Right to Revoke Your Authorization. If you have signed an authorization for uses and disclosures not related to payment or health care operations, you have the right to revoke that authorization in writing at any time, except to the extent that we have taken action in reliance of such authorization, or if other law provides us with the right to contest a claim under the policy or the policy itself. Note: your revocation will not prevent us from using collected information in conjunction with our fraud prevention program.
Right to a Paper Copy of this Notice. You have the right to a paper copy of this notice. You may ask us to give you a copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy.
Right to be Notified of a Breach of Health Information. You have the right to be informed if we or one of our business associates experience a breach of your unsecured health information.
If you believe your privacy rights have been violated, you can file a complaint with us by sending your written complaint to us at the address given below. You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services, Office for Civil Rights, by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting hhs.gov/ocr/privacy/hipaa/complaints. We will not retaliate against you for filing a complaint.
To file a complaint or to make a request as described in the section entitled "Rights That You Have," please send your written request to:
Senior Health Insurance Company of Pennsylvania (In Rehabilitation)
Attn: Privacy Officer
P.O. Box 64913
St. Paul, MN 55164
Requests should be directed to our Customer Service Department, and complaints should be sent to the attention of the Privacy Officer. Please be sure to include the following information:
your full name
date of birth
nature of your request or complaint.
A final word
We are committed to the security and confidentiality of your Personal Information. We maintain reasonable physical, procedural, and electronic security measures that meet applicable standards. If there is any breach of your unsecured Personal Information, we will notify you.
We do not sell your Personal Information but are required by law to inform you that any sale of Personal Information that constitutes “protected health information” as defined by federal law would require your written authorization. We may not use or disclose protected health information for marketing purposes without your written authorization, except for face-to-face communications and promotional gifts of nominal value. We also may not use or disclose psychotherapy notes without your authorization.
We are required by law to maintain the privacy of your Personal Information. We also are required to provide you with a copy of this notice and abide by its terms so long as it is in effect. We reserve the right to change any of our privacy or security practices and the terms of this notice, and to make the new notice effective for all Personal Information maintained by us. In the event of a material change, we will mail a revised notice to all of our policyholders.
If any law requires us to provide you with greater privacy protections than are stated in this notice, we will comply with that law.
We typically will retain your personal information for a period of time after the end of a customer relationship. In some cases, we may be required to retain certain information for a certain amount of time by law or by industry standard. We maintain the same standards of privacy and security after the customer relationship has ended as we do for current customers.
Please note that if you provide personal information to other financial services providers not affiliated with us, for example, independent insurance agents or mortgage brokers, their use of such information may not be governed by this privacy notice. You should review the privacy notice of such third parties to understand how they collect, use, and disclose such information.
For Further Information
If you would like more information about our privacy and security practices, please contact us by (1) calling Customer Service at 1-877-450-5824, (2) writing to us at the address above, or (3) emailing us at firstname.lastname@example.org.
Effective Date: 11/1/21