PRIVACY STATEMENT
Your Privacy is Important to Us
Windsor Health Plan, Inc. (“Windsor”) is required by law to protect the privacy of your personal identifiable and protected health information.
THIS NOTICE DESCRIBES HOW SUBMITTED MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
Windsor holds its employees and Business Associates to strict adherence to all State and Federal regulatory requirements for the protection of your personal identifiable and protected health information. Windsor is required by law to provide you this Privacy Statement which outlines how Windsor handles your information that is collected from this website. All Windsor employees must sign confidentiality agreements and our suppliers must sign a Business Associate Agreement for adherence to State and Federal law and regulatory mandates. In addition, Windsor employs various privacy and information security technologies to detect, prevent and to monitor for unauthorized access or disclosure to your protected health information. This Privacy Statement explains your rights as they relate to your information and our legal duties and privacy practices.
What Information We Collect
Windsor understands your concerns regarding the confidentiality of information you share with us. We collect information from you on applications, online forms and other correspondence and transactions with us. The types of information we collect may include your name, address, phone number and Social Security number. Under certain conditions we may also ask you and your covered dependents for medical history information. We also have access to your information through claims submitted to our company from healthcare providers, information provided by your employer if your coverage is through a group contract and from your agent.
How We Use and Disclose Your Information
Windsor is permitted by law to use your information for certain purposes including healthcare payment and healthcare operations. Examples of how we may use and disclose your information include but are not limited to:
· Treatment: Windsor may use and disclose your PHI for treatment. Information obtained from your physician may be used to dispense prescription medications to you.
· Payment: Windsor may use or disclose your information to pay claims for covered services or to provide eligibility information to your doctor when you receive treatment.
· Healthcare Operations: Windsor may use or disclose your information for activities like:
1) Underwriting, premium rating or other activities relating to the creation or renewal of a health insurance contract;
2) Quality assessment and improvement activities such as peer review and credentialing of providers;
3) Care and disease management activities; and
4) Data and information systems management.
As required by law: Windsor must allow the U.S. Department of Health and Human Services access to audit its records. In addition, Windsor may be required to release your information to comply with other laws including:
· To comply with legal proceedings, such as court orders or administrative order or subpoenas.
· To perform mandatory licensing, regulatory/compliance reporting.
· To law enforcement officials for limited law enforcement purposes.
· To federal officials for lawful intelligence, counterintelligence and other national security purposes.
· To Public Health Authorities for public health purposes.
Business Associates: Windsor may disclose your information to third parties that it hires to assist in the administration of your benefits. These third parties are called Business Associates, and they must agree in writing to protect and maintain the confidentiality and security of your information. Examples of a Business Associate are the doctors who do medical reviews and/or a vendor who prints claim notifications on the behalf of the Windsor Health Group.
To Plan Sponsors: If you receive insurance benefits through a group plan, Windsor may disclose to your Plan Sponsor, in summary form, claims history and other similar information. Such summary information does not disclose your name or other distinguishing characteristics. Windsor may also disclose to your Plan Sponsor the fact that you are enrolled in or dis-enrolled from the Plan. Windsor may disclose your medical information to the Plan Sponsor for Plan administrative functions that the Plan Sponsor provides to the Plan,if the Plan Sponsor formally signs a Business Associates Agreement with Windsor where the Plan Sponsor agrees in writing to ensure the ongoing privacy, and protection of your medical information. The Plan Sponsor must also agree not to use or disclose your medical information for employment-related activities or for any other benefit or benefit plans of the Plan Sponsor.
Other Uses and Disclosures: Other disclosures that Windsor may make:
· To your personal representative appointed by you or designated by law.
· To appropriate military authorities, if you are a member of the armed forces.
· To a family member, friend or other person, for the purpose of helping you with your healthcare or healthcare payment if you are in an emergency situation and you cannot give your agreement to Windsor to do this.
· To inform you of other health-elated benefits or services that may be of interest to you.
Uses and Disclosures with your permission: Windsor will not use or disclose your information for any purpose not outlined in this notice unless you provide Windsor your written authorization to do so.
To receive an authorization form, please contact our Customer Service at the telephone number on the back of your identification card or print one below.
Member Privacy & Confidentiality Rights
The following are your privacy and confidentiality rights as a member of Windsor health plans. Please note that all requests must be made in writing.
We have provided forms for processing your request. The appropriate forms are available at the bottom of this page. You also may call our Customer Service representatives at the telephone number on the back of your identification card to obtain a copy of this form. Hearing-impaired customers may contact us at TTY/TDD: 1-866-460-7617.
All completed forms and requests are to be mailed to:
Windsor Health Group
Attn: WHG Privacy/Security Officer
2219 Rimland Drive
Bellingham, WA 98227
Requests with incomplete information will not be processed and you will not be notified.
Additional Privacy Restrictions: You may request that Windsor place additional restrictions on the use and disclosure of your information to carry out treatment, payment or healthcare operations. By law, Windsor is not required to consent to your request for additional restrictions. Please use the form provided at the bottom of our website to submit your request. Be sure to provide all required information including your name, your birthday, the policy number under which you are covered, and a clear explanation of your request. Windsor will send a written confirmation regarding the disposition of your request.
Confidential Communications: Windsor is under no obligation to agree with any member requests for confidential communications from a different location other than the Member’s home of record. Windsor will assess each request and determine if:
1) Such a change in communication is necessary to avoid member endangerment;
2) Your request allows Windsor to continue collecting premiums and pay claims;and
3) Your request is reasonable.
Please use the form provided at the bottom of this page to submit your request. Please provide all required information including your name, your Social Security number, your group number, your birthday, the policy number under which you are covered, the full address of where you would like future communication to be sent and the reason for the request. The request will take ten (10) business days to process from the date received. If your request is approved, you will receive a letter confirming the activation of the alternate address. All communications regarding your information will be sent to the alternate address once this request has been made or until you notify us otherwise. Use of an alternate address cannot be applied to communications sent prior to processing your request.
Access to your information: You have a right to access your information used and stored by Windsor in its designated record set. The right to access excludes:
· Psychotherapy notes
· Information compiled in reasonable anticipation of, or for use in, a civil, criminal, or administrative action or proceeding; and
· Protected health information maintained by a covered entity that is:
(A) Subject to the Clinical Laboratory Improvements Amendments of 1988, 42 U.S.C. 263a, to the extent the provision of access to the individual would be prohibited by law; or
(B) Exempt from the Clinical Laboratory Improvements Amendments of 1988, pursuant to 42 CFR 493.3(a)(2).
Please use the form provided at the bottom of this page to submit your request for access to your records. Be sure to provide all required information including your name, your birthday, the policy number under which you are covered, the group number under which you are covered, your Social Security number, the information you would like to access and the dates of information you would like to see (if applicable).
Amend your information: You have the right to request an amendment of your information that is maintained in a designated record set. Windsor cannot amend information it did not create and will refer you to the provider of service if you are requesting an amendment to diagnosis or treatment information. Please use the form at the bottom of our website to submit your request to amend your records. Be sure to provide all required information including your name, your birthday, the policy number under which you are covered, the information you are requesting be amended, and an explanation as to why you believe the information is incorrect or incomplete. You have a right to an appeal if your request to an amendment is denied. These rights will be explained to you if your request is denied.
Disclosures: You have a right to an accounting of certain disclosures of your information made by Windsor and its Business Associates over the last six (6) years. Please use the form provided at the bottom of our web site to submit your request for an Accounting of Disclosures of your records. Be sure to provide all required information including your name, your birthday, the policy number under which you are covered, and a statement explaining your specific request.
Complaints: You have the right to complain if you believe your rights have been violated. You may use the form provided at the bottom of our web site to submit your complaint. Please provide all required information including your name, your birthday, the policy number under which you are covered, and an explanation regarding your complaint in as much detail as possible. You may file a complaint by contacting Customer Service at the telephone number on the back of your identification card, if you wish not to send it in writing. You also have the right to complain to the Secretary of the U.S. Department of Health and Human Services, Hubert Humphrey Building, 200 Independence Avenue, S.W., Washington, D.C. 20201. Federal law prohibits retaliation against you if you chose to file a complaint.
Contact Information: If you have questions or would like an additional copy of this notice, please contact Customer Service at the telephone number on the back of your identification card.
Links to Other Sites
Our web site may contain links to other websites, even though you may still see our logo; you are providing information to these other sites when you leave our site. We will notify you when you are leaving our site. We are not responsible for the privacy practices or the contents of such other websites. Please review the posted statement at the sites you go to from our site.
Email
All information and correspondence you share with us will be handled in the strictest confidence. Please do not email information to us that you consider confidential. If you wish, you may contact us instead via telephone at the Customer Service number located on your identification card.
Cookies and Other Methods of Collecting Information
Windsor uses various methods to collect certain other kinds of information that cannot be personally identified with you, including "cookies," "referrers," IP addresses, and environment variables. A "cookie" is an element of data that Windsor can send to your browser, which may then store it on your system. It can be used to provide you with a tailored user experience.
The Windsor site uses cookies. We treat any personally identifiable information with the same confidentiality as when you enrolled. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. Windsor does not require that you accept cookies. A "referrer" is the information passed along by a web browser that references the Web URL you linked from, and is automatically gathered by our Web server. This information is used by Windsor to identify broad demographic trends that may be used to provide information tailored to your interests. You will not be personally identified from this information.
Your computer uses IP addresses every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer so that data (such as the Web pages you request) can be sent to you. Our Web server automatically gathers them.
Windsor will not use your IP address to attempt to identify your personal information and you will remain anonymous. System Information we gather includes time, type of Web browser being used, the operating system/platform, and CPU speed. This information is sent automatically by your Web browser when you are connected to a Web site and is used by Windsor only for broad demographic statistics. You will not be personally identified from this information.
Effective Date
The effective date of this notice is September 30, 2011. Windsor is required to follow the terms of this notice until it is replaced. Windsor reserves the right to change this Privacy Statement at any time as allowed by law and will notify you of any changes as required by law. Windsor reserves the right to make the changes apply to all information that it maintains.
Privacy & Confidentiality Request Forms
· Request to Access Information
Your right to review records contained in Windsor Health Group’s designated record set.
· Request to Amend Information
Your right to request changes to be made to correct errors in your records or add information that has been omitted.
· Request an Accounting of Disclosures
Your right to see a list of certain disclosures made of your protected health information.
· Request to place restrictions on use/disclosure of Protected Health Information
Request special treatment for your protected health information.
· Request confidential communications
Request to receive information from Windsor Health Group at an alternate address.
· Request to revoke confidential communications
Request to revoke to receive information from Windsor Health Group at an alternate address.
· Request for an Authorized Delegate to act on your behalf
Request an authorized delegate to act on your behalf
· Request to Revoke an Authorized Delegate to act on your behalf
Request to revoke a current authorized delegate.
· Report a Violation of Your Privacy Rights
To report a violation of your privacy rights to Windsor Health Group or to the United States Office of Civil Rights.