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Hippa
Policy 
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INITIAL PRIVACY NOTICE OF
AMERICAN INSURANCE
NETWORK, INC.
May 2005
PURPOSE OF THIS INITIAL PRIVACY
NOTICE
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| The purpose of this notice is
to inform you of American Insurance Network, Inc. privacy policies and
procedures. We protect your nonpublic personal information (NPI) from
disclosures that are not allowed by law or restricted or disallowed in this
Initial Privacy Notice. AIN gives this Notice as a service to all valued
clients and to comply with the requirements of the law. |
| This Initial Privacy Notice
describes how AIN collects, discloses and protects the personal information we
gather about you. We may materially change our privacy policies and procedures,
and if we do we will notify you before we make any changes. We gather two types
of protected information about you: Nonpublic personal information (NPI) and
nonpublic personal financial information (NPFI). NPI includes any list,
description or grouping of clients that is derived using any personally
identifiable information that is not publicly identifiable. It includes the
medical, financial, and character information that we gather to provide you
with insurance as well as your name and address. |
| NPFI is the protected
financial information we gather about you. |
| OUR PRIVACY
POLICIES AND PROCEDURES |
| 1) During the course of
operation, we uncover & collect the following NPI about you: Name, address
(incl. phone/fax numbers), SSN, income, occupation, age, height, weight,
marital status, prior insurance history, medical history, controlled drug
history, current prescriptions, professional services, payment methods (i.e.,
credit card & bank information) as well as financial & investment
information. |
| 2) Categories of NPI we
disclose. We do not disclose or share your NPI with anyone unless allowed by
law. |
| 3) Categories of Affiliates and
Nonaffiliated Third Parties to whom we disclose NPI. |
| a) Affiliates. The law allows
us to share your NPI with affiliates: However, we do not share your NPI with
affiliates. |
| b) Nonaffiliated Third Parties.
The law allows us to share your NPI with nonaffiliated third parties under
certain circumstances. When it is lawful to do so we share your NPI with the
following categories of nonaffiliated third parties: We do not share your NPI
with nonaffiliated parties. |
| c) General Types of
Businesses. The law allows us to share NPI with non-affiliated third parties
whose only use will be in connection with the marketing of a product or a
service: However, we do not share your NPI with third parties for marketing
purposes. |
| 4) Former Customers. The law
allows us to share the NPI of former customers: However, we do not share the
NPI of former customers. |
| 5) Disclosure to an Affiliate
for Marketing Purposes. The law allows us to share your NPFI with our
affiliates to market insurance products or a service to you: However, we do not
share your NPFI with our affiliates. |
| 6) Opting Out of Disclosure to
Nonaffiliated Third Parties. The law allows us to share NPFI with nonaffiliated
third parties for marketing purposes: However, we do not share your NPFI with
nonaffiliated third parties for marketing purposes. |
7) Disclosures Made of NPFI
Protected by the Federal Fair Credit Reporting Act. The law allows us to share
non-transactional information you disclosed under the Fair Credit Reporting
Act: However, we do not share this information. |
| 8) How We Protect the
Confidentiality and Security of NPI. We protect and safeguard your NPI: Our
insurance office will monitor and ensure that during business hours no person
is unescorted or unmonitored within the office unless they are an employee or
business associate. Our insurance office will identify, monitor and control who
is authorized to possess keys or necessary codes for securing and entering the
office. Our insurance office will obtain written consent from all nonaffiliated
third parties who will have access to or receive NPI in the course of their
duties to us. Our insurance office will secure all physical data that contains
NPI. All files not in use will be filed. All file containers will be secured
when the office is closed or not occupied. Our insurance office will provide
controls on access to and authentication of persons using electronic data. Our
office will install, maintain, and update necessary virus protection, firewall
protection as needed. |
| 9) Your Right to Access, Copy
Review and Request Correction of NPI: You have the right to access, copy
review, and request correction of any NPI in our possession. You must make this
request to us in writing and we have 30 days to allow you to review your NPI.
If you believe that there is an error in the information, you may request in
writing that it be corrected. We have 30 days from receiving the request to
make the correction or to inform you as to why we will not make the requested
change and the reasons why. If you disagree with the refusal, you may supply us
with a concise statement why you disagree and it will be filed with your
NPI. |
| 10) Disclosure of NPI Under
Specific Exceptions. The law allows or requires us to disclose NPI in the
following situations: |
| a) With your written
authorization |
| b) To a non-insurance entity if
it is reasonably necessary for us to properly do our business and the other
entity agrees not to disclose the NPI. |
| c) To an insurance entity if
the disclosure helps the receiving party perform an insurance transaction for
you or if it is reasonably necessary to detect or prevent criminal activity,
fraud, or misrepresentation in connection with an insurance transaction. |
| d) To a medical professional in
order to: |
| 1) Verify coverage or benefits,
conduct operations or service audits. |
| 2) Inform a person a medical
problem they might not be aware of. |
| e) To the Department of
Insurance, law enforcement or other governmental entity including an
administrative or court order, or as is otherwise required or permitted by
law |
| f) To conduct actuarial or
research studies if there are proper safeguards. |
| g) To facilitate the sale of
whole or part of an insurance business. |
| h) To a person whose only use
will be for marketing a product or service. However please note: |
| 1) No medical or character
information may be disclosed. |
| 2) You may opt out of the
disclosure. |
| 3) The person getting the
information agrees to use it only for marketing purposes. |
| i) To an affiliate for an
insurance audit or marketing an insurance product or service: |
| 1) The information can only be
used by the affiliate and only for those purposes. |
| j) By a consumer reporting
agency if the information does not go to an entity. |
| k) To a group policyholder to
report claims experience or do an audit or to a certificate holder or
policyholder to inform them the status of an insurance transaction. |
| l) To a professional peer
review organization to review medical care. |
| m) To the government to
determine eligibility for health benefits. |
| n) To a lien holder, etc. or
any other having legal interest in an insurance policy to the extent that the
disclosure is needed to protect their interest. |
