Plan Member Privacy Information Package

Transcription

1 Plan Member Privacy Information Package

2 This Privacy Information Package was developed to help you, as a group plan member, understand why Manulife s Group Benefits collects your personal information, how we use it, and with whom we may need to share it, from time to time. It is to be read in conjunction with, but does not replace, Manulife Financial s Statement of Privacy Principles and Practices ( the Policy ). At Manulife we recognize the importance of the personal information that you entrust to us every day. Without it, we wouldn't be able to properly administer our products and services. We realize how important it is to you that your personal information be protected. This is a responsibility we take very seriously and that is why we have made the protection of personal information a fundamental principle of our business. What is Personal Information? Generally, privacy legislation defines personal information as any information which can identify you or which relates to you as an individual. For example, personal information may include your: name, age, date of birth, weight, height, home address and phone number, medical records, income, etc. to name but a few. Consent It is important to understand the concept of consent. Manulife must obtain your consent before we can collect, use or share your personal information with anyone. We request your consent in writing at the time you enroll in a plan or file a claim for benefits, by having you sign the Authorization section of the enrolment or claim form. By signing the form, you are authorizing us to collect, to use, to maintain and to disclose your personal information in ways that may be explained on the form, verbally, or in other written format such as the document you are reading right now. We collect, use and share your personal information only for disclosed purposes related to the products and services we offer, and only with your consent, or as permitted or required by law. Your consent may be expressed in writing, or it may be given verbally, electronically, or through our or your authorized representative(s), such as your plan administrator. Your consent may also be implied or inferred from certain actions. For example, if you present your benefit identification card to your healthcare provider, instead of paying for the prescription or procedure directly, it is understood that you are giving your consent for the healthcare provider to provide your personal information to us, in order for us process the claim payment. Where a spouse or other dependant provides a receipt to the plan member, or uses a pay direct card, or otherwise submits a claim to the plan member s coverage, consent is implied for us to collect, use and disclose that information in processing the claim, including reporting the information to Manulife s plan member. Where a plan administrator completes enrolment administration on your behalf, your consent will be evidenced by the fact that you provided the information and your subsequent use of the coverage. In some cases, Manulife will be taking over coverage from a previous carrier and it may not be appropriate for us to re-enroll all plan members. In such a case, we will rely on the consent, which was provided to the previous carrier. In other situations, your consent may be provided verbally, such as when you or a family member calls one of our customer service representatives and authorize the release of certain information. Your consent may also be implied, such as where it would be reasonably expected or is necessary for the proper administration of your benefits but where it is difficult or impractical to obtain your written consent. There are also certain situations where the law states that consent won't be required, such as where information is required pursuant to a subpoena or Court Order, for purposes of investigation, where there has been a contravention of a federal or provincial law, or where the information is required in an emergency that threatens the life, health or security of an individual. 2

3 Withdrawing Consent Under the law, you have the right to withhold or withdraw your consent at any time. However, it is important to understand the implications of refusing to provide consent or withdrawing an existing consent. For example: Manulife may not be able to enroll you in your group benefits plan; Manulife may not be able to provide you with the products and services you have requested; Manulife may not be able to keep your coverage in force; Manulife may not be able to properly administer your group benefits coverage; and Manulife s payment of claims may be delayed or not paid at all. Special Considerations Family Coverage If you are a member of a Group Benefits plan and have family coverage, it is important for you and your family members to understand how personal information may be shared. Benefit statements and claim cheques, which may contain personal information about other family members, will automatically be sent to you as plan member. You must advise your family members that this information will be sent to you. As the plan member, please note that your spouse and/or dependants may have access to benefit coverage information or inquire on the status of claims through our customer service centre or our website. By virtue of having family coverage or sharing your Group plan contract number and plan member certificate number, you have provided implied consent to your spouse and/or dependant so that they may access coverage information and inquiry on the status of claims they have made. The same considerations apply to the secure website that we provide to plan members. We have security measures in place to help confirm the identity of a plan member when he or she first logs on to the system and creates a confidential password. Only those with the appropriate Group plan contract number, plan member certificate number, and password will be able to gain access to the system thereafter. Please note that once a plan member has created a password, anyone with the Group plan contract number, plan member certificate number and password will be able to log on to the system and view information about all family members. Therefore, it is important to understand that, by providing the password, you are effectively consenting to the release of information on behalf of all other family members. Electronic Claims Most pharmacists and many dentists, doctors, hospitals, and other medical service providers now have the ability to submit claims to us electronically. This is a major convenience for you. You don't have to pay for supplies or services out of your own pocket, you don't have to fill out a claim form and then wait for a cheque. Even for those providers who still require payment at the time service is rendered, the claim is still submitted electronically. Please know that by using your pay direct card or otherwise submitting a claim electronically through a hospital or other service provider, your consent to collect, use and share the information necessary to process that claim is implied through the act of using your pay direct card or submitting that claim. Collecting and Using Personal Information Personal information is required for the proper administration of your plan. We collect information from you and about you, only with your consent, or as required or permitted by law. We will tell you the purposes for which we need the personal information we collect. We will use fair and lawful means to collect your personal information. We will only collect information that is pertinent and consistent with the purposes of the collection. Whenever practical, we will collect the required information directly from you, or from you authorized representative(s), in completed applications and claim forms, through other means of correspondence, such as telephone, mail, or internet and through your business dealings with us. We try to collect the information directly from you, although there may be occasions where it must come from someone else. In those instances and with your consent, we may need to ask an independent source to verify or provide 3

4 supplemental information. These sources could include service providers we retain, your employer, your doctor(s), other healthcare providers or facilities. If your information is being collected by telephone, inbound and outbound calls may be recorded or monitored for the following reasons: To establish a record of the information you provide; To take or verify instructions from you; To maintain quality service levels; and To assist in staff training. If you are not comfortable with having your telephone calls recorded, you have the option of communicating with us in writing, instead. Where you have chosen to only communicate with us in writing, your written communications should request that any response to you be in writing, as well. We collect your personal information for purposes including: Adjudication and Payment of Claims Personal information may be used in the following ways within the adjudication and claims payment process: To determine if a claim is payable; In calculating amounts payable (such as if your spouse is insured by another insurer and benefits need to be coordinated); In the ongoing management of claims. Information is required to evaluate the initial claim and ensure continued eligibility for benefits over the course of the claim; In the ongoing management of the illness or disability and in developing rehabilitation plans or obtaining assistance with return-to-work planning; To establish if a certain medical condition did or did not exist prior to a certain date, which can sometimes be determinative of whether a benefit is payable or not; To contact other insurance companies to confirm amounts already claimed under a certain benefit where we are taking over a plan and we need to calculate how much room you have left in respect of a lifetime maximum; and To determine if you have collected or are collecting benefits under certain government-funded programs, such as Worker's Compensation, Automobile Accident Benefits, CPP Disability Pension, Government direct plans and others. Billing / Direct Deposit Personal information will be used to help ensure that your plan sponsor is being billed correctly, and is paying the appropriate monthly premiums over the lifetime of the plan. It will also be necessary for the continuing collection of monthly premiums for any optional coverage purchased. Where claim payments are to be paid by direct deposit to your account or where you have purchased optional coverage available under a plan and premiums need to come out of your account on a monthly basis, we will need to obtain the appropriate banking information from you. Enrolment Personal information will be used to enroll you on our systems and establish appropriate benefit entitlements and corresponding benefit coding, as well as applicable maximums and deductibles. If your plan sponsor administers the plan, they would collect your personal information directly from you and then forward the information to us. For example: plan member information such as date of birth, type of coverage you are applying for, coordination of benefits (if applicable), family information, salary information etc. Identification Basic personal information is required to identify you as an individual and, together with your contact information, enable us to maintain your records, pay your claims, and correspond with you. For example: name, address, telephone number, plan number, certificate number, etc. With your consent, we may also use your Social Insurance Number (SIN) as a unique identifier, such as your certificate number. Medical Underwriting Where medical underwriting is required, for example where additional or optional coverage is requested, you may be required to provide evidence of insurability. Operational Audits Audits, which may be undertaken from time to time, include random quality assurance underwriting and claims audits. These audits attempt to confirm that appropriate information is being requested and collected so that claims may be properly assessed, and that such information is being used and applied in accordance with our internal underwriting guidelines and claim administration practices. Claims audits are done to ensure that claims are being paid (or denied) in accordance with 4

5 the terms of the policy and within internal adjudication standards. Any discrepancies can be used to help improve procedures, with the ultimate goal always being to the improvement of benefit and service delivery. We may also conduct claims audits of outside healthcare and service providers, such as hospitals, dental offices, medical equipment retailers, etc. We do this to compare certain personal information in our records to those of our service providers. The service providers will then be informed of any discrepancies and required to explain or substantiate them. Disclosure of Personal Information Generally, the disclosure of your personal information will be restricted to those who have a need for, and the right to, the information. In order to effectively administer your benefit plan, it may be necessary to share your personal information with parties outside of Manulife. Some of the outside parties or the reasons that we most often find we need to share personal information with might include: Audits By Plan Sponsors and Appointed Consultants - Manulife s processes and records may become subject of an audit initiated by a plan sponsor or an appointed auditor. Actual data is used, and this may include personal information that we may have collected from you. We "depersonalize" the information before it is made available (where possible) by removing name, address and specific birth date. Where an audit is carried out on behalf of a plan sponsor, we request that it be conducted by a qualified independent third party and require such party to sign a confidentiality and audit protocol agreement. This agreement requires that Plan Sponsors and/or Auditors do not release findings which identifies personal member data. Audits are conducted on site (where applicable). We only release audit information that is reasonably necessary for the audit. Plan Sponsors / Brokers (Employers & Agents) - We provide claims reports to brokers to share with their clients, the plan sponsors. These reports do not identify individuals personally and contain aggregate information. We do not share medical information or diagnoses with your employer. In other situations it may be necessary to disclose information to the plan sponsor for plan administration purposes. These purposes may include: Reporting on the status of a disability claims (necessary for the plan sponsor to facilitate a plan member s return to work); Requesting information on an application for optional coverage (necessary for the plan sponsor to withhold the appropriate premium); and Reporting fraud or other criminal activity by an insured. Change of Insurers - Where a benefit plan is being moved from Manulife to a replacement carrier at the request of the plan sponsor, certain personal information will need to be transferred to the new carrier so that benefits can continue to be properly administered without significant interruption. Collection Agencies, Credit Bureaus, etc. - Where a group member owes Manulife money and all efforts to recover the debt have been unsuccessful, we may retain a collection agency to attempt to reclaim the funds, in which certain personal information would have to be provided. We may also be required in certain instances to contact a credit bureau, to which details of the unpaid debt would be provided. Financial Institutions - We may need to share certain personal information (excluding claims information) with your financial institution so that we set up direct deposit claim payments or pre-authorized withdrawals where you have purchased optional coverage and monthly premiums are payable. Investigative Agency - We may need to independently determine a claimant s activity level for the purpose of assessing eligibility for certain benefits, primarily disability benefits, and may need to retain the services of a private investigative firm in order to do this. Minimal personal information about the claimant may be shared with the firm so that the investigation can be properly carried out. Medical Information Bureau (MIB) - Where an application for Optional Life coverage is made, we would likely share some of the information in the application with the MIB, which is used by most insurance companies in Canada to exchange diagnostic or standardized medical condition information on individuals applying for insurance. Other Insurers - We may sometimes need to share information with other insurance companies to determine eligibility for benefits or adjudicate claims, the most common being where spouses are each covered under group plans by different insurers and benefits need to be properly coordinated. 5

6 Our Re-insurer - A re-insurer is essentially another insurance company who pays a percentage of the claims we pay in exchange for a premium they charge to us. Because of this, the re-insurer will want to be sure that the claims we are paying are valid, and will frequently request details regarding claims, which we must share with them. Pharmacists - Your Pharmacist may be able to detect when an insured submits prescriptions to one or more pharmacies in the same relative time frame for prescription drugs which could cause a dangerous interaction or which would not otherwise normally be prescribed together. Police and Other Government or Quasi-Government Agencies - There are numerous different situations where we may be required by law or otherwise to disclose personal information to Police or certain other government or quasi-government agencies, such as provincial workers compensation boards, provincial health insurance plans, the Canada Pension Plan, the Canadian Customs and Revenue Agency and many more. Physicians and Other Healthcare Providers and Hospitals, Clinics and Other Medical Facilities - We may need to share personal information with your physician or other healthcare provider or with a Hospital or Clinic whom you have recently visited for treatment so that we can confirm your eligibility for certain benefits or provide certain information so that a claim may be adjudicated. Please note, unless otherwise instructed by you, generally it is our practice to release all sensitive medical information to you through your doctor or medical practitioner. Regulatory Bodies Manulife works with professional associations, colleges and regulatory bodies to uphold high standards of professionalism and integrity for all regulated businesses. It may be necessary to provide these regulatory bodies with personal information in the course of an inquiry or complaint. Manulife may also be subject to financial and other types of audits by insurance regulatory bodies from time to time. As with other types of audits, we attempt to depersonalize the information as much as possible ahead of time. However, in many cases, regulators will insist that personal information remain intact in order to obtain accurate, representative results. Service Providers We may use service providers to provide us with various services such as printing, mail distribution, information technology, administration, marketing (which would include market research and promotional services), paramedical, claims adjudication, investigation and reinsurance. Where personal information is provided to our service providers, we will require them to protect the information in a manner that is consistent with our privacy policies and practices. Third Party Administrators (TPA) - Some Group Benefits plans are set up in such a way that the enrolment and ongoing administration of the plan, or the adjudication and payment of claims under the plan, or both, are carried out by an outside party normally referred to as a Third Party Administrator (TPA), as chosen by the plan sponsor. A TPA may require personal information in order to properly carry out the duties for which it has been appointed, and where reasonably necessary we will provide (or obtain your consent where applicable to do so) the information we have under our control to the TPA for this purpose. TPA s are required to comply with applicable privacy laws and to protect the confidentiality of the information. For more information please contact the Group Benefits Customer Service Centre at A copy of Manulife Financial Canadian Division Statement of Privacy Principles and Practices ( the Policy ) is available on our website at or upon request through your Plan Sponsor. The Manufacturers Life Insurance Company, 2005 Group Benefit products are offered through Manulife Financial (The Manufacturers Life Insurance Company). Manulife Financial and the block design are registered service marks and trademarks of The Manufacturers Life Insurance Company and are used by it and its affiliates including Manulife Financial Corporation. GL3815E (08/2005)