Privacy Policy
MultiNational Underwriters® (MNU)respects individual privacy and values the confidence of its customers, employees, consumers, business associates, and others. Not only does MultiNational Underwriters® strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Privacy Policy (the "Policy") sets forth the privacy principles that MultiNational Underwriters® follows with respect to personal information transferred from anywhere in the world to MNU’s office in the United States.
A set of data protection principles are enforced to enable U.S. companies to satisfy any requirements that adequate protection is given to personal information transferred from any beginning source to the United States. MultiNational Underwriters® is recognized as providing adequate data protection, remains consistent with its commitment to protect personal privacy, and adheres to the Privacy Policy Principles.
SCOPE
This Privacy Policy (the "Policy") applies to all personal information received by MultiNational Underwriters® in the United States from anywhere in the world, in any format including electronic, paper or verbal.
DEFINITIONS
For purposes of this Policy, the following definitions shall apply:
"Agent" means any third party that collects or uses personal information under the instructions of, and solely for, MultiNational Underwriters® or to which MultiNational Underwriters® discloses personal information for use on MultiNational Underwriters’ behalf.
“Business Associate” shall include other Outside sources such as pharmacies or other affiliates of MultiNational Underwriters®.
“Individual” client shall include a person who qualifies as a covered individual or is an accepted personal representative of said person.
“Medical Provider” will include Extended Care Facilities, Home Health Care Agencies, Hospitals, and Physicians as defined in applicable Certificate Wordings for each plan of benefits.
"MultiNational Underwriters® (MNU)" means MultiNational Underwriters®, a Noel Group company, and is known as the Plan Administrator for Lloyd’s London, the largest and oldest insurance market in the world.
“Outside source” shall include any Individual client, Agent, Medical Provider or other Business Associate of MNU.
"Personal information" means any information or set of information that identifies or is used by or on behalf of MNU to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
“Privacy Rule(s)” shall mean the Standards for Privacy of Individually Identifiable Health Information.
“Protected Health Information” shall be limited to the information created or received by and Outside source from or on behalf of any Individual client.
"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, MNU will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
PRIVACY PRINCIPLES
NOTICE: Where MultiNational Underwriters® collects personal information directly from individuals, it will inform them about the purposes for which it collects and uses personal information about them, the types of non-agent third parties to which MNU discloses that information, and the choices and means, if any, MNU offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to MNU, or as soon as practicable thereafter, and in any event before MNU uses or discloses the information for a purpose other than that for which it was originally collected.
Where MultiNational Underwriters® receives personal information from outside sources, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
CHOICE: MultiNational Underwriters® will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For sensitive personal information, MultiNational Underwriters® will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
MultiNational Underwriters® will provide individuals with reasonable mechanisms to exercise their choices.
DATA INTEGRITY: MultiNational Underwriters® will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. MNU will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
ONWARD TRANSFER: MultiNational Underwriters® will maintain assurances from its agents and/or other involved parties that they will safeguard personal information consistently with this Policy. Where MNU has knowledge that an agent and/or other outside party is using or disclosing personal information in a manner contrary to this Policy, MNU will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION: Upon request, MultiNational Underwriters® will grant individuals reasonable access to personal information that it holds about them. In addition, MNU will take reasonable steps to permit individuals to correct, amend, or delete information that is clearly demonstrated to be inaccurate or incomplete except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.
SECURITY: MultiNational Underwriters® will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. To ensure that on-line transactions are protected, MNU uses advanced encryption technology through the use of 128-bit Secure Socket Layer, which is utilized by most popular browsers. This technology allows MNU to use advanced encryption tools to protect all important customer information transmitted between the outside source and the internal server. MNU treats credit card and other personal information with the highest standards of confidentiality and safety. In the unlikely event of a breach in security, there is no risk to you. In the event of credit card fraud, MultiNational Underwriters® will reimburse the customer the applicable funds allowed.
ENFORCEMENT: MultiNational Underwriters® will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that MNU determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the MNU Technical Services Department at the address given below. MultiNational Underwriters® will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between MNU and the complainant, MNU will agree to participate in the dispute resolution procedures of a panel established by appropriate data protection authorities to resolve disputes pursuant to these Privacy Principles.
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by MultiNational Underwriters® to these Privacy Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule or regulation.
INTERNET PRIVACY
MultiNational Underwriters® sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, healthcare professionals, business associates, and others. MNU recognizes the importance of maintaining the privacy of information collected online and maintains specific Internet Privacy Procedures which govern the treatment of personal information collected through web sites that it operates.
CONTACT INFORMATION
Questions or comments regarding this Privacy Policy should be submitted to the Technical Services Department of MultiNational Underwriters® by mail or e-mail as follows:
MultiNational Underwriters®
Attention: Technical Services Department
P.O. Box 863
Indianapolis, IN 46206
insurance@mnui.com
CHANGES TO THIS PRIVACY POLICY
This Policy may be amended from time to time, consistent with the requirements of the regulated Privacy Principles. A notice will be posted on the web page for MultiNational Underwriters® (www.mnui.com) for 60 days whenever this Privacy Policy is changed in a material way.
EFFECTIVE DATE: April 14, 2003
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