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The Cincinnati Life Insurance Company Notice of Privacy Practices

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW THIS NOTICE CAREFULLY.

Federal regulations under the Health Insurance Portability and Accountability Act of 1996 require The Cincinnati Life Insurance Company to provide you with a notice that explains our privacy practices and outlines your rights with regard to the health, Medicare supplement or long-term care insurance you purchased from us. The notice does not change, diminish or limit your coverage in any way.

OUR PRIVACY PLEDGE
To provide you with the products and services you request, it is necessary to collect some personal information about you. The Cincinnati Life Insurance Company believes that information personal to you should be respected and protected. Additionally, we are required by law to maintain the privacy of our policyholders’ personal
health information.

We share personal health information only as necessary to carry out treatment, payment and health care operations for the products and services you request and as permitted by law. If our privacy practices change, we will send you a revised notice if you still have an insurance policy with us. Additionally, you may request a copy of our notice at any time by mailing a request to the address at the end of this notice.

The terms of this Notice of Privacy Practices apply to The Cincinnati Life Insurance Company. The information provided in this notice applies to all persons, including all of your covered dependents, covered under the health, Medicare supplement or long-term care insurance you have purchased from us.

USES AND DISCLOSURES OF YOUR PERSONAL HEALTH INFORMATION
We will not use or disclose your personal health information except in the following circumstances:

Your Authorization. We will use or disclose information if you have signed a form authorizing the use or disclosure and then only in accordance with such authorization. You have the right to revoke that authorization in writing at any time.

Disclosures for Treatment. We will make disclosures of your personal health information as necessary for your treatment. For instance, a doctor or health facility involved in your care may request your personal health information that we hold in order to make decisions about your care.

Uses and Disclosures for Payment. We will use and disclose your personal health information as necessary for payment purposes. For example, we may use information regarding your medical procedures and treatment to process and pay claims, to determine whether services are medically necessary or to otherwise preauthorize or certify services as covered under your policy. We may also forward such information to another health plan which may also have an obligation to process and pay claims on your behalf.

Uses and Disclosures for Health Care Operations. We will use and disclose your personal health information as necessary, and as permitted by law, for our health care operations which may include credentialing health care providers, peer review, business management, accreditation and licensing, utilization review and management, quality improvement and assurance, enrollment, underwriting, reinsurance, compliance, auditing, rating and other functions related to your policy. We may also disclose your personal health information to another health care facility, health care professional or health plan for quality assurance and case management, but only if that facility, professional, or plan has or had a patient relationship with you. We may also disclose some personal health information to your agent in order to facilitate the payment of a claim or process a transaction that you request.

Family and Friends Involved In Your Care. With your prior approval, we may disclose your personal health information to designated family, friends and others who are involved in your care or in payment for your care in order to facilitate that person’s involvement in caring for you or paying for 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 health information with such individuals without your approval. We may also disclose limited personal health 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.

Long-Term Care or Medicare Supplement Insurance. If you have purchased long-term care or Medicare supplement insurance and have designated a person to receive information regarding payment of the premium on your policy, we will inform that person when your premium has not been paid. We also use a third-party administrator to process applications and claims under our long-term care policies, but require it to appropriately safeguard the privacy of your information.

Outside Business Associates. Certain aspects and components of our services are performed through
contracts with outside persons or organizations, such as auditing, accreditation, actuarial services, legal services, third party administrators, etc. At times it may be necessary for us to provide portions of your personal health information to one or more of these outside persons or organizations who assist us with our health care operations. In all cases, we require these business associates to appropriately safeguard the privacy of
your information.

Communications With You. We may communicate with you regarding your claims, premiums or other matters connected with your policy. If such communication places you in danger, you have the right to request to receive communications regarding your personal health information from us by alternative means or at alternative locations. For instance, if you wish messages to not be left on voice mail or sent to a particular address, we will accommodate such request if reasonable. You must make such request in writing and may send it to the address provided at the end of this notice.

Other Health-Related Products or Services. We may, from time to time, use your personal health information to determine whether you might be interested in or benefit from treatment alternatives or other health-related programs, products or services which may be available to you under your policy. For example, we may use your personal health information to identify whether you have a particular illness and contact you to advise you that a disease management program to help you manage your illness is available to you as a policyholder. We will not use your information to communicate with you about products or services which are not health-related without your written permission.

Other Uses and Disclosures. We are permitted or required by law to make certain other uses and disclosures of your personal health information without your authorization.

  • We may release your personal health information for any purpose required by law, such as:
    • for public health activities
    • if we suspect child abuse or neglect or if we believe you to be a victim of abuse, neglect or
      domestic violence
    • to the Food and Drug Administration if necessary to report adverse events, product defects or to participate in product recalls
    • to a government oversight agency conducting audits, investigations or civil or criminal proceedings
    • if required to do so by a court- or administrative-ordered subpoena or discovery request
    • to law enforcement officials as required by law to report wounds and injuries and crimes
    • to coroners and/or funeral directors
  • We may release your personal health information to your plan sponsor; however, your plan sponsor or must certify that the information provided will be maintained in a confidential manner and not be used for employment-related decisions or for other employee benefit determinations or in any other manner not permitted by law;
  • We may release your personal health information if necessary to comply with your request to arrange an organ or tissue donation or to arrange for a transplant for you;
  • We may release your personal health information if you are a member of the military as required by armed forces services; we may also release your personal health information if necessary for national security or intelligence activities; and
  • We may release your personal health information to workers' compensation agencies if necessary for your workers' compensation benefit determination.

YOUR RIGHTS
Access to Your Personal Health Information.
You have the right to copy and inspect much of the personal health information that we retain on your behalf. All requests for access must be made in writing and signed by you or your representative. We reserve the right to charge you a reasonable copying fee if you request a copy of the information. We also reserve the right to charge for postage if you request a mailed copy. You may obtain an access request form by making a written request to the address listed at the end of this notice.

Amendments to Your Personal Health Information. You have the right to request in writing that personal health information that we maintain about you be amended. We are not obligated to make all requested amendments but will give each request careful consideration. 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 request. If an amendment you request is made by us, we may also notify others who work with us and provide copies of the uncorrected record and amendment if we believe that such notification is necessary. You may request an amendment by sending a written request to the address listed at the end of this notice.

Accounting for Disclosures of Your Personal Health Information. You have the right to receive an accounting of certain disclosures of your personal health information made by us after April 14, 2003. Requests must be made in writing, be signed by you or your representative and sent to the address listed at the end of this notice. The first accounting in any 12-month period is free; we reserve the right to charge a fee of $25 for each subsequent accounting you request within the same 12-month period.

Restrictions on Use and Disclosure of Your Personal Health Information. You have the right to request restrictions on certain of our uses and disclosures of your personal health information for treatment, payment or health care operations by notifying us of your request for a restriction in writing. A restriction request form can be obtained by making a written request to the address listed at the end of this notice. 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 or orally, any agreed-to restriction to sending such termination notice by sending a written request to the address listed at the end of this notice.

Complaints. If you believe your privacy rights have been violated, you can file a complaint in writing to the address listed at the end of this notice. You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services in Washington, D.C., in writing within 180 days of a violation of your rights. There will be no retaliation for filing a complaint.

EFFECTIVE DATE
This Notice of Privacy Practices is effective April 14, 2003.

FOR FURTHER INFORMATION
For questions, to request an item described in this notice or to receive further assistance, please contact us at:

The Cincinnati Insurance Companies
Attn: Regulatory & Consumer Relations – Privacy
P.O. Box 145496
Cincinnati, Ohio 45250-5496
Phone: 888-744-2170 (toll free) or 513-603-5992
E-mail: privacy@cinfin.com