Independence Administrators Website Privacy Policy
Independence Administrators (IA) Website Privacy Policy and IA Website Terms and Conditions of Access
Overview
This section provides the details of Independence Administrators’ (“IA’s”) Website Privacy Policy and IA’s Website Terms and Conditions of Access.
Please read this Website Privacy Policy (“Privacy Policy”) in its entirety to understand how IA will handle: (i) the privacy of personal information that you provide through the Website or through the use of the online IA Web portals (e.g., the Personal Health Record and the Personal Health Profile), and (ii) the disclosure of certain paid claims data to participating providers rendering services to you. Unless otherwise specified, this Privacy Policy does not describe how IA may handle your personal information in offline settings.
IA may use and disclose the information that you provide through this Website or through the Web portals or certain data regarding claims paid on your behalf (“Claims Data”) only for purposes permitted or required by law, for purposes described in this Privacy Policy, or for purposes which you might authorize. If you do not wish IA to use or disclose information that you provide through this Website as described in this Privacy Policy, you should disconnect from this Website.
IA also has developed Terms and Conditions of Access describing your responsibilities when using this Website and/or the IA Web portals. Please read the Privacy Policy and the Terms and Conditions of Access carefully. You will be asked to accept the Privacy Policy and the Terms and Conditions of Access before using this Website. IA may revise and update the Privacy Policy and the Terms and Conditions at any time. Therefore, please periodically review the Privacy Policy and the Terms and Conditions of Access posted at this Website.
IA Website and IA Web Portal Privacy Policy
Welcome to the Independence Administrators (“IA”) Website. Our publicly-accessible Website and the Web Portals accessible therein are designed to make it easier for visitors to manage their health information and learn about the services, programs and products provided by Independence Administrators. If you are currently an individual who is a member of a plan administered by IA you also may choose to register for IA’s Web portal if applicable. A web “portal” is a Website that allows two-way interaction and can collect information from the visitor or provide information to the visitor. After registration, for example, these portals allow you to access information about certain benefits or programs, claims information, or health information. In addition, certain individuals eligible for special health programs may be able to register to access the consumer web portal. As with all online resources, we appreciate that visitors to our Websites are concerned about the privacy of personal information. This Privacy Policy discloses IA’s policy for collecting, using and disseminating information through its Websites and Web portals.
1. The IA Personal Health Record Web Portal
Your personal health record (“PHR”) is your voluntary online resource to store, maintain, track, and organize your health information in a centralized private and secure location. The information in your PHR is secured and confidential. IA does not review the contents of your PHR, except as may be necessary to provide the service (for example, we may incidentally review your data while fixing a technical issue) or as required by law.
You may add information, such as notes, comments, and prior medical history, into your PHR at any time. A version of your PHR can be printed and shared with your health care providers if you choose to do so. However, as more fully explained immediately below, you should expressly advise your health care provider or other person/entity with whom you share this information that: the PHR is not a complete medical record and the PHR is not intended to be medical advice or instructional for medical diagnosis or treatment.
2. Collection of Personal Information from Site Visitors to IA’s Website
When you visit www.ibxtpa.com (including the IA Web portal through which you access your PHR), IA may collect and/or track: (1) your home server domain names, your email address, your type of computer, the files downloaded, the search engine used, operating system, and type of web browser; (2) the email addresses of visitors who communicate with IA via email; (3) information knowingly provided by the visitor in online forms, surveys, email, contest entries, and other online submissions (including demographic and personal profile data), and (4) aggregate information on pages accessed by a visitor.
To better serve you, we use “cookies” to customize your browsing experience. Cookies are simple text files stored by your browser, and they provide a method of distinguishing among visitors to our sites. We use “cookies” to store a randomly generated tag on your computer such that when you revisit our sites, we may recognize the visitor by the Internet cookie and customize the visitor’s experience accordingly. The cookies created on your computer by using our sites do not contain personally identifiable information. You may refuse a cookie, or delete the cookies file from your computer at any time by using any one of a number of widely available methods. However, you should be aware that if you disable the “cookies” feature of your browser, you may not be able to use the portals within our site.
When a visitor performs a search on our Website, we may record information identifying the visitor or linking the visitor to the search performed. IA also may record limited information for every search request and use that information only to solve technical problems with the service and to calculate overall usage statistics.
3. Use of Online Personal Data Collected Through IA’s Website
When you access the Website (including the IA Web portal by which you access your PHR), you may choose to give IA online personal information about you. “Online personal information” is any information or data you provide through this Website that is individually identifiable, such as a name, address, postal address, email address, birth date, phone number, race, ethnicity, language, gender identity, sexual orientation information and other personal information including health information that you voluntarily provide to IA. It also may include other information that we collect about you that is associated with your name or address, such as your email address. You may provide that information to us on our registration page, if you email us, or at some other point during your online interaction.
IA may use the online personal information for a number of different reasons, including editorial and feedback purposes, health care marketing and promotions, performing a statistical analysis of visitor usage, product development, content improvement, to protect our rights or property, or to customize the content and layout of our site. Aggregate data that does not identify individual users may be used for internal purposes or provided to third parties.
Personally identifiable information that visitors voluntarily provide to IA, online or offline, may be added to our databases and used for future communications, which may include Website updates, new products and services, the confirmation of transactions through the portals, upcoming events, or health reminders, and for other purposes in accordance with applicable state and federal law.
Online personal information may or may not be individually identifiable health information that is also protected by the federal HIPAA privacy law (“the HIPAA Privacy Rule”). Where online personal information also constitutes individually identifiable health information under the HIPAA Privacy Rule, the provisions of this Privacy Rule also will govern IA’s permitted uses and disclosures of the online personal information. IA does not use race, ethnicity, language, gender identity and sexual orientation information for underwriting, rate setting, denial of services, coverage or benefits determinations.
4. Disclosure of Online Personal Data Collected Through the IA Website to Third Parties
Unless otherwise authorized by a visitor, IA will not sell, rent, license, or disclose personally identifiable information collected through the IA Website to unaffiliated third parties. Under the HIPAA Privacy Rule, however, IA is permitted to disclose individually identifiable health information to business associates who perform various functions or provide services on their behalf. To perform these functions or to provide services, business associates will receive, create, maintain, use, or disclose individually identifiable health information that has been provided to or made available to the business associate by IA, but only after we require the business associates to agree in writing to contract terms designed to safeguard your information.
IA has contracted with certain third party vendors such as WebMD to serve as its business associate to provide services in connection with IA’s Web portals. Except as set forth above, IA will not release personally identifiable information to any party unless required to do so by government authorities or legal process in accordance with applicable law, in order to protect our rights or property, or in conjunction with an acquisition of all or part of our company. Laws that permit disclosure of your personally identifiable information as part of healthcare operations might include activities such as Wellness Programs.
5. Wellness Programs and Health Support Programs
Wellness and health support programs are intended to help Plan Members to improve their overall health. They are not intended to replace professional medical advice. Information on Plan Member participation in these programs may be used by IA and our clients for aggregate reporting and outreach purposes.
When appropriate, IA may share protected health information (or “PHI”) with third party vendors with which IA has a contract to administer benefits or provide health support services as IA’s business associates. Such vendors are required to sign a contract with IA to maintain the privacy of protected health information as required by law. IA also may share information with treating providers to improve the health care of Plan Members. Providers also must follow all legal confidentiality requirements for PHI.
In addition, when appropriate, we may confirm your enrollment in these programs or in certain preventive health activities, but not your individual responses or final results, with your employer or health and welfare fund (“fund”), for the purpose of an incentive program or corporate wellness planning. For example, we may inform your employer or fund that you completed a “Health Risk Assessment or Personal Health Profile” but will not disclose your answers. We may inform your employer or fund that you attended 10 sessions of a weight management program but not disclose whether you lost any weight. Your individual responses also will not be shared with your employer or fund or their broker/consultant.
6. Links from Independence Administrator’s Website to Other Websites
IA’s Website occasionally includes links to other organizations’ websites for your convenience in locating health-related information, services, and products. Please be advised that when you link to these other sites, you are leaving IA’s Website and that these other sites are maintained by organizations over which IA may have no control.
Accordingly, a link on any of these sites does not constitute endorsement of the content, viewpoint, policies, products, or services provided or advertised on that site. These other third party sites may have their own terms and conditions and privacy policies or no policy at all. Once you link to a website not maintained by IA, you are subject to any terms and conditions of that site, including, but not limited to any privacy policy. The IA Privacy Policy and the Terms and Conditions of Access do not apply to the sites of such other third parties. IA does not guarantee that you will receive an alert that you are leaving an IA Website and linking to other third-party websites. It is your responsibility to determine when you have left an IA Website.
Certain products, services or treatments referred to on other sites that have a link on our site, may not be covered under certain plans administered by IA. Plan Members should refer to their benefits contract/member handbook for complete details of the terms, limitations, and exclusions of coverage. In addition, certain providers may not be network providers. Please refer to our provider directory or call IA to make certain the professional listed is a network provider.
Certain health information and tools accessible to registered Plan Members on the Plan Member web portal may be provided in combination with third party vendors from which IA licenses or purchases services. IA may customize these tools to serve Plan Members with IA plan coverage administered by IA. An example of this is the portion of our Member website supported by the company WebMD, which is a business associate of IA (and, therefore, is bound by the use and disclosure restrictions of the HIPAA Privacy Rule for information that constitutes PHI). A partial list of these services provided by WebMD includes the Provider Finder, Hospital Comparison Tool, Personal Health Record, and Personal Health Profile. The WebMD sections of the Website have an additional Privacy Policy that governs the collection, use and disclosure of any PHI provided to WebMD through its website. A visitor can tell they are on a WebMD-supported tool because the bottom of the webpage will be labeled “WebMD Health Services Group, Inc.”
7. Security Measures
IA has implemented numerous security features to prevent the unauthorized release of or access to personal information. For example, all IA employees are required to certify their understanding that personal information is considered confidential, that it is important to safeguard personal information, and that IA will take appropriate action against any employee who fails to acknowledge these facts or adhere to the requisite security standards of conduct.
The IA web portal uses 256-bit encryption to help keep information secure. You will not be able to view certain pages of our site unless your computer has 256-bit encryption. You should also be aware that despite these and other security measures implemented by IA, no security process is completely foolproof. We will continually assess our security procedures and modify them to protect your information and we ask that our visitors take the appropriate measures to protect their information.
If you register for our Web Portal, you will have the opportunity to receive or create a password to access view or submit personal information. Visitors who register to use the Web Portal should not divulge their password to anyone, and IA will never ask for your password in an unsolicited phone call or email. When you are finished with applications that are password-protected, you should exit the page.
You should be aware that the confidentiality of any communication or material transmitted to/from IA via this site or email cannot be guaranteed. IA is not responsible for the security of information transmitted via the Internet. Visitors who prefer to communicate with IA in another manner other than through our site can write to us via regular mail at: Independence Administrators, 602 Office Center Drive, Suite 350 Fort Washington, PA 19034.
8. Opt-out Right
Visitors may opt out of having certain personally identifiable information, i.e. PHI, used by IA or its affiliates for health-related marketing or other health-related promotional communications by contacting IA via regular mail or email at the addresses above. This opt-out right does not apply to IA’s collection of the type of web browser of visitor to IA’s site or the sharing of PHI permitted under the HIPAA Privacy Rule for treatment or health care operations as part of wellness and health support programs as described above.
In sections of the Plan Member website that are “WebMD Health Services Group, Inc.” visitors may customize their preferences regarding receipt of email health reminders and other electronic communications. This is done by accessing the “settings” tab.
9. Access to and Ability to Correct Online Personal Data.
Upon request via regular mail or email, IA provides visitors a summary of any personally identifiable information retained by IA regarding the visitor. You will also be able to see personal information retained by IA through the Plan Member Web Portal. Plan Members may seek to modify, correct, change, or update information that IA has collected by contacting us via regular mail or email at the addresses above. Some visitors may also be able to update their information via the Plan Member portal. Although you may provide individually identifiable health information on this Website, the information is not a medical record, and is not, under the HIPAA Privacy Rule, considered information we maintain in a designated record set. Such information, however, will be treated as PHI, as discussed in this Privacy Policy.
10. Collection of Online Personal Data From Children.
Although parents are free to seek information available on this Website concerning the health of their children, no person under 18 years old is permitted to use this Website. IA does not direct this Website to children under the age of 18 years or knowingly collect personal information from children under 18. Adults should not assist minors in accessing the Site. When visitors enter personal information on our Website, the visitor is representing to us that he/she is an adult over 18 years old.
To the extent that IA is able to determine the age of visitors by their submissions to or communications with IA’s site, IA will not knowingly (1) collect or post information from individuals under age 18 without their parent’s or guardian’s consent, or (2) provide any personally identifying information collected from children, regardless of its source, to any third party for any purpose whatever unless otherwise permitted by law.
More specifically, if registration is required for any services on the IA Website, and a visitor submits information to IA’s Website through such a registration process that indicates that such visitor is a child, the child’s parent or guardian will be alerted to the child’s registration and will be provided instructions on how the parent or guardian can delete the child’s registration, if so desired. No information collected through IA’s Website from visitors who identify themselves as children will knowingly be used for any direct marketing or promotional purposes. If there are no age restrictions on a contest that requires registration, and if a child wins, notification and prizes will be sent to the parents or guardians identified in the initial registration process.
11. Independence Administrators’ Right to Contact Visitor.
IA reserves the right to contact Website visitors regarding account status and changes to the Plan Member handbook, the Privacy Policy, or any other policies or agreements relevant to those who visit the Website.
12. Independence Administrators’ Right to Change Privacy Policy.
IA reserves the right to change this Privacy Policy at any time. Consequently, you should refer back to this Privacy Policy regularly as it might be amended from time to time.
Terms and Conditions of Access
Independence Administrators (“IA”) provides you with access to its Website and Plan Member Portal (collectively, the “Portal”), subject to the following Terms and Conditions of Access (“Terms and Conditions”).
We may update these Terms and Conditions at any time and without notice. Unless stated otherwise, changes will be effective when they are posted on our website at www.ibxtpa.com. The Terms and Conditions are in addition to those policies and procedures that are posted on our website at www.ibxtpa.com under the Legal Information section and under our Website Privacy Policy, which are incorporated herein by reference.
By logging on to the Portal, activating your password and creating a user identification, you agree to be bound by these Terms and Conditions as well as the policies and procedures posted on our Website under the Legal Information section and under our Website Privacy Policy. If you do not wish to be bound by these Terms and Conditions, policies and procedures posted on our Website under the Legal Information section, and IA’s Website Privacy Policy, you should disconnect from this Website immediately.
1. THE CONTENT OF THE PORTAL IS NOT INTENDED IN ANY WAY TO BE A SUBSTITUTE FOR PROFESSIONAL MEDICAL ADVICE.
ALWAYS SEEK THE ADVICE OF YOUR PHYSICIAN OR OTHER QUALIFIED HEALTH PROVIDER WITH ANY QUESTIONS YOU MAY HAVE REGARDING A MEDICAL CONDITION. NEITHER THE CONTENT NOR ANY OTHER SERVICE OFFERED BY OR THROUGH THE PORTAL IS INTENDED TO BE RELIED ON FOR MEDICAL DIAGNOSIS OR TREATMENT. NEVER DISREGARD MEDICAL ADVICE OR DELAY IN SEEKING IT BECAUSE OF SOMETHING YOU HAVE READ ON THE PORTAL! IN AN EMERGENCY, CALL 911 OR YOUR LOCAL EMERGENCY ASSISTANCE NUMBER.
2. IA reserves the right to terminate access to the Portal at any time and for any reason.
Your access will be terminated automatically when your benefits are no longer provided by IA and its subsidiaries or affiliates. IA reserves the right at any time to modify or discontinue, temporarily or permanently, the Portal (or any part thereof) with or without notice. You agree that IA will not be liable to you or to any third party for any modification, suspension or discontinuance of the Portal.
3. IA has created certain security procedures, including the use of passwords and user identification numbers, to assist in keeping your information confidential.
You agree to provide us with accurate, current and complete information about yourself as requested and to maintain and promptly update your information to keep it accurate, current and complete.
4. You are responsible for maintaining the confidentiality of the password and are responsible for all activities that occur under your password.
You agree to immediately notify IA of any unauthorized use of your password or other breach of security, and to exit from your account at the end of each session. IA cannot and will not be liable for any losses and/or damages arising from your failure to comply with these provisions. Except where expressly authorized by law, you certify that you are not using another person’s password or user identification to access the Portal. You agree not to falsely state or otherwise misrepresent your affiliation with a person or entity to obtain access to a Portal. You also agree not to copy or disseminate, electronically or otherwise, personal or confidential information found on the Portal.
5. You agree that IA, in its sole discretion, may terminate your password, user identification (or any part thereof) or use of the Portal for any reason, including, for lack of use or if IA believes that you have violated the Terms and Conditions.
You agree that IA will not be liable to you or any third party for any termination of your access to the Portal.
6. The information provided on the Portal is provided as an accommodation and it is not intended to serve as formal notice or publication as may be required under law or by contract.
While IA uses its best efforts to maintain the accuracy and reliability of information available through the Portal, we cannot guarantee the accuracy of the claims information or that all claims will be found by using the “search” feature of the Portal. You understand and agree that IA, except as expressly required by law, assumes no responsibility for the timeliness, deletion, mis–delivery or failure to provide any information on the Portal.
7. IA has agreements with various entities, which we call our “business associates,” to provide services in connection with the Portal.
Our relationships with business associates are based on the type of service they are to provide.
8. YOUR USE OF THE PORTAL IS AT YOUR SOLE RISK. THE PORTAL IS PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS.
IA EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON–INFRINGEMENT. YOU EXPRESSLY UNDERSTAND AND AGREE THAT IA WILL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES FOR ANY REASON RESULTING FROM THE USE OF THE PORTAL.
9. You agree to release and hold IA and its subsidiaries and affiliates,
and their directors, officers, agents, principals or other partners, and employees, harmless from any claims, demands, damages, losses, liabilities, costs and expenses, including reasonable attorneys’ fees, made by any third party due to or arising out of your use of the Portal, your violation of these Terms and Conditions, your communication of inaccurate or incomplete information, and/or your violation of law.
10. IA will not release and/or disclose personally identifiable information to any party, including our third party vendors, unless required to do so by government or legal authorities or unless such release and/or disclosure is in accordance with applicable law and IA’s Privacy Policy.
You understand and agree that the party receiving personally identifiable information may use the personally identifiable information in accordance with applicable law.
11. You understand that you may access the websites of third parties through the Portal.
You understand and agree that the websites of third parties will have their own policies and procedures (including a privacy policy) to which you will be subject. These websites are maintained by the third parties that IA does not control. IA recommends that you read the policies and procedures (including the privacy policy) of the websites of third parties that you access.
12. In some instances, you will be notified when you leave IA’s Portal and access the websites of third parties. However, IA does not guarantee that you will receive such a notice before accessing the websites of third parties.
You understand and agree that it is your responsibility to determine when you have accessed the websites of third parties and to be aware when the policies and procedures (including the privacy policy) of third parties are applicable.13. The Portal may include or provide links to other websites on the Internet including, but not limited to, links to our business associates’ web pages.
These other websites may provide opinions, recommendations, or other information from various individuals, organizations or companies. IN PROVIDING LINKS TO THE WEBSITES OF THIRD PARTIES, IA DOES NOT INVESTIGATE THE CONTENT OF SUCH INFORMATION AND DOES NOT ENDORSE, GUARANTEE OR WARRANT THE ACCURACY OF SUCH INFORMATION OR NECESSARILY SUBSCRIBE TO ANY SUCH OPINIONS OR RECOMMENDATIONS. TO THE EXTENT THAT YOU MAKE USE OF ANY LINK TO ANY OTHER WEBSITE ON THE INTERNET, YOU UNDERSTAND AND AGREE YOUR USE OF THE WEBSITES OF THIRD PARTIES IS AT YOUR SOLE RISK. THE WEBSITES OF THIRD PARTIES ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. IA EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON–INFRINGEMENT. YOU EXPRESSLY UNDERSTAND AND AGREE THAT IA WILL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES FOR ANY REASON RESULTING FROM YOUR USE OF THE WEBSITES OF THIRD PARTIES.
14. You understand that Pennsylvania law requires that any person knowingly and with intent to defraud any insurance company or other person files an application for insurance or statement of claim containing any false information or conceals for the purposes of misleading, information concerning any material fact thereto commits a fraudulent insurance act, which is a crime and subjects such person to criminal and civil penalties.
Links to other websites
Independence Administrators occasionally provides links to other entities on its websites for your convenience in locating health-related information, services, and products. Please be advised that when you link to these other sites, you are leaving Independence Administrators’ website and going to websites maintained by organizations that Independence Administrators does not control. Accordingly, a link does not constitute endorsement of the content, viewpoint, policies, products, or services provided or advertised on that website. Once you link to a website not maintained by Independence Administrators, you are subject to the terms and conditions of that website, including, but not limited to its privacy policy.
Certain services/treatments referred to in other sites may not be covered under your benefit plan. Please refer to your benefit contract for complete details of the terms, limitations, and exclusions of your coverage.