Privacy and Legal

Health Privacy Practices Notice for the Oxford Life Family of Companies*


Our Policy Regarding Privacy of Your Health Information Effective as of September 23, 2013


We are required by law to maintain the privacy of your protected health information, to provide you with notice of our legal duties and privacy practices with respect to your protected health information, and to notify affected individuals following a breach of unsecured protected health information.

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

This Notice describes how we may use and disclose your protected health information to carry out treatment, payment or health care operations, and for other purposes that are permitted or required by law. It also describes your rights to access and control your protected health information. “Protected health information” is information about you, including demographic information, that may identify you and that relates to your past, present or future physical or mental health or condition and related health care services. If the practices described in this Notice are acceptable to you, there is nothing you need to do. If you would like to request that we not share information, we may honor your written request in certain circumstances described below. If you have any questions about this notice, please contact our Privacy Officer at:

Oxford Life Insurance Company
Privacy Officer
2721 North Central Avenue
Phoenix, Arizona 85004

We are required to abide by the terms of this Notice. We may change the terms of our Notice at any time. The new notice will be effective for all protected health information that we maintain at that time and for information that we receive in the future. If we make a material change to this Notice, we will provide you with the revised Notice (or information about the material change and how to obtain a revised Notice) in our next annual distribution. You may also obtain a copy of our Health Privacy Practices Notice by accessing our website www.oxfordlife.com, calling us at 888-757-3732 and requesting that a revised copy be sent to you in the mail or via e-mail, or by writing to our Privacy Officer at the address indicated on page 1 of this Notice. You have the right to obtain a paper copy of this Notice from us, upon request, even if you have agreed to accept this Notice electronically.

1. Uses and Disclosures of Protected Health Information for Treatment, Payment and Health Care Operations. Your protected health information may be used and disclosed by us and others outside of our company that are involved in your care and treatment for the purpose of providing health care services to you.

The following are examples of the types of uses and disclosures of your protected health care information that we are permitted to make. These examples are not meant to be exhaustive, but to describe the types of uses and disclosures that may be made by our company.

Treatment: Your protected health information will be used, as needed, to pay for your health care services. This may include activities that we may undertake before we approve or pay for the health care services your health care providers recommend for you, such as making a determination of eligibility or coverage for insurance benefits, pre-certification of certain services, reviewing services provided to you for medical necessity, and undertaking utilization review activities.

Payment: We may share your protected health information with providers for payment purposes. We may share your protected health information with third party “business associates” that perform various activities (e.g. collecting and transmitting health care claims billing information, re-pricing of health care claims, independent medical reviews/evaluations) for our company. Whenever an arrangement between our company and a business associate involves the use or disclosure of your protected health information, we will have a written contract that contains terms that will protect the privacy of your protected health information.

Healthcare Operations. We may use or disclose, as needed, your protected health information in order to support the business activities of our company. These activities include, but are not limited to, quality assessment activities; underwriting, premium rating, and other activities relating to the creation, renewal or replacement of a contract of health insurance or health benefits; ceding, securing, or placing a contract for reinsurance of risk relating to claims for health care (including stop-loss insurance and excess of loss insurance); conducting or arranging for medical review, legal services, and auditing functions, including fraud and abuse detection and compliance programs; business planning and development, such as conducting cost-management and planning-related analyses related to managing and operating our company, including development or improvement of methods of payment or coverage policies; business management and general administrative activities; and nominal gifts or face-to-face marketing activities. However, we are prohibited from using or disclosing protected health information that is your genetic information for underwriting purposes.

We may disclose your protected health information to claims examiners who are being trained to handle claims similar to yours. We may also use medical information to evaluate the performance of our staff in handling your medical claims. We may use or disclose your protected health information, as necessary, to contact you to discuss your eligibility for health care insurance, enrollment, and payment of health care services provided to you.

We may use your health care claim information for actuarial analysis. We may use health care claim information to estimate the amount of funds we will need to pay future health care claims. We may also provide the health care information when requested by governmental regulatory agencies.

Your name and address may be used to send you information regarding your policy, including changes to your policy, as mandated by various federal and state laws.

Group Plan Administration. We may disclose your health information to your health plan sponsor for plan administration. For example, if your employer contracts with us to provide health insurance coverage, and we provide your company with certain statistics to help obtain premium bids or for analyzing whether to modify, amend or terminate the group health plan.

Potential Impact of Other Legal Restrictions. In some situations, we may be required to comply with a state privacy law or other federal law (in addition to the federal HIPAA privacy regulations) that provide greater privacy protections. For example, certain information regarding HIV/AIDS, mental health, communicable diseases or certain records regarding alcohol or drug abuse may be subject to additional restrictions.

2. Other Permitted and Required Uses and Disclosures That May Be Made Without Your Consent, Authorization or Opportunity to Object. We may use or disclose your protected health information in the following situations without your consent or authorization. These situations include:

Required By Law. We may use or disclose your protected health information to the extent that the use or disclosure is required by law. The use or disclosure will be compliant with the law and will be limited to the relevant requirements of the law. If the applicable law requires, we will notify you of any such uses or disclosures.

Public Health: We may disclose your protected health information to a public health authority for public health activities and purposes if law permits the public health authority to collect or receive the information. We may also disclose your protected health information, when directed by a public health authority, to a foreign government agency that is collaborating with the public health authority.

Health Oversight. We may disclose protected health information to a health oversight agency for activities authorized by law, such as audits, investigations, and inspections.

Abuse or Neglect. We may disclose your protected health information to a public health authority that is authorized by law to receive reports of child abuse or neglect. In addition, we may disclose your protected health information, consistent with applicable federal and state laws, if we believe that you have been a victim of abuse, neglect or domestic violence to the governmental entity or agency authorized to receive such information.

Legal Proceedings. We may disclose protected health information in the course of any judicial or administrative proceeding, in response to an order of a court or administrative tribunal (to the extent such disclosure is expressly authorized), and in response to a subpoena, discovery request, or other lawful process.

Military Activity and National Security. When the appropriate conditions apply, we may use or disclose protected health information of individuals who are Armed Forces personnel (1) for activities deemed necessary by appropriate military command authorities; (2) for the purpose of a determination by the Department of Veterans Affairs of your eligibility for benefits, or (3) to foreign military authority if you are a member of that foreign military services. We may also disclose your protected health information to authorized federal officials for conducting national security and intelligence activities, including for the provision of protective services to the President.

3. Other Permitted and Required Uses and Disclosures That May Be Made With Your Consent, Authorization or Opportunity to Object. We may use and disclose your protected health information in the following instances. You have the opportunity to agree or object to the use or disclosure of all or part of your protected health information. If you are not present or otherwise not able to agree or object to the use or disclosure of the protected health information, then we may, using professional judgment, determine whether the disclosure is in your best interest. In this case, only the protected health information that is relevant to your health care will be disclosed.

Others Involved in Your Healthcare. Unless you object, we may disclose to a member of your family, a relative, a close friend or any other person you identify, your protected health information that directly relates to that person’s involvement in your health care or in payment related to your health care. If you are unable to agree or object to such a disclosure, we may disclose such information as necessary if we determine that it is in your best interest based on our professional judgment. Unless you object or instruct otherwise, all Explanations of Benefits (EOBs) will be addressed to the primary insured.

Communication Barriers. We may use and disclose your protected health information if, using professional judgment, we determine that you intended to consent to use or disclosure under the circumstances.

4. Uses and Disclosures of Protected Health Information Based upon Your Written Authorization. We may engage in other uses and disclosures of your protected health information that are not described above upon receiving your written authorization, unless otherwise permitted or required by law. You may revoke an authorization, in writing, at any time for future uses and disclosures of protected health information. However, a revocation will not be effective to the extent that we already have used or disclosed information in reliance on the authorization.

5. Your Rights. Following is a description of your rights with respect to your protected health information and a brief description of how you may exercise your rights.

Inspect and Copy Your Protected Health Information. You may inspect and obtain a copy of protected health information about you that is in a designated record set for as long as we maintain the protected health information. A “designated record set” contains medical and billing records and any other records that we use for making decisions about your health care coverage. However, under federal law, you may not inspect or copy psychotherapy notes; information compiled in reasonable anticipation of, or use in, a civil, criminal, or administrative action or proceeding; and protected health information that is subject to law that prohibits access to the protected health information. Your request must be in writing and sent to our Privacy Officer at the address indicated on page 1 of this Notice. We may request sufficient identification prior to releasing any information to you. A decision to deny access may be reviewable, and you may have a right to request that our decision to deny access be reviewed. Please contact our Privacy Officer if you have questions about access to your medical record. California, Connecticut, Georgia, Illinois, Maine, Massachusetts, Minnesota, Montana, Nevada, New Jersey, North Carolina, Ohio, Oregon, Virginia & Wisconsin residents may inspect and copy their applicable records in person after sending a written request and providing sufficient identification. Residents in other states may make a written request to inspect and copy their applicable records in person.

Request a Restriction of Your Protected Health Information. You may ask us to not use or disclose any part of your protected health information for the purposes of treatment, payment or healthcare operations. You may also request that any part of your protected health information not be disclosed to family members or friends who may or may not be involved in your care. Your request must be in writing, your request must state the specific restriction requested, your request must state to whom the restriction applies, and your request must be sent to our Privacy Officer at the address indicated on page 1 of this Notice.

We Do Not Have to Agree to a Restriction. We are not required to agree to a restriction that you may request. In the event that we do agree to the requested restriction, we may not use or disclose your protected health information in violation of that restriction unless it is needed to provide emergency treatment.

Alternative Means of Receiving Confidential Communications. If you believe that disclosure of all or part of your protected health information could endanger you, then you have the right to request that we send and/or receive confidential communications by an alternative means or through an alternative location. We will accommodate your reasonable requests. We may require that you provide us with a specific alternative address and/or method of contact, and any other specific information we need to accommodate your reasonable request. We will not request an explanation from you for the request, however, your request must state that the disclosure of all or part of your protected health information could endanger you. Please make your request in writing to our Privacy Officer at the address indicated on page 1 of this Notice. Washington state residents are not required to state that disclosure of all or part of their protected health information regarding reproductive health, sexually transmitted diseases, chemical dependency and mental health may endanger them as part of the restriction request. Washington state residents only are not required to state that disclosure of all or part of their protected health information could endanger them.

Amend Your Protected Health Information. You may request an amendment to your protected health information in a designated record set for as long as we maintain this information. Your request must be in writing, provide a reason to support the requested amendment, and send the request to our Privacy Officer at the address indicated on page 1 of this Notice. In certain cases, we may deny your request for an amendment. If we deny your request for an amendment, you have the right to submit a statement of disagreement to us and we may prepare a rebuttal to your statement. We will provide you with a copy of any rebuttals prepared in response to your statement of disagreement. Please contact our Privacy Officer at the address indicated on page 1 of this Notice if you have questions about amending your medical record.

Receive an Accounting of Certain Disclosures. You have a right to request and receive an accounting of certain disclosures of your protected health information that we have made. You have the right to receive specific information regarding disclosures or your protected health information. The right to receive an accounting does not include any disclosures we have made for purposes of treatment, payment or healthcare operations as described in this Notice. Nor does the right to receive an accounting include any disclosures that we may have made to you, to family members or friends involved in your care, or for notification purposes. The right to receive this information is subject to certain exceptions, restrictions and limitations, such as, but not limited to, not receiving information in excess of a 6-year period (you may request a shorter timeframe). Your request must be in writing, state that you are requesting an accounting of disclosures subject to an accounting, state the time period for which you are requesting an accounting, and must be sent to our Privacy Officer at the address indicated on page 1 of this Notice. California, Connecticut, Georgia, Illinois, Maine, Massachusetts, Minnesota, Montana, Nevada, New Jersey, North Carolina, Ohio, Oregon, Virginia & Wisconsin residents only: You are entitled to an accounting of all disclosures of your recorded personal medical information within 2 years prior to the request.

Complaints. You have a right to complain to us you believe your privacy rights have been violated by us. You may file a complaint with us by notifying our Privacy Officer at the address indicated on page 1 of this Notice. You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services. We will not retaliate against you for filing a complaint.

* The Oxford Life® Family of Companies includes: Oxford Life Insurance Company®; North American Insurance Company®; Christian Fidelity Life Insurance Company®; and Oxford Life Insurance Company® in its capacity as third party administrator for certain Medicare supplement insurance policies issued by Celtic Insurance Company and USAble.

FINANCIAL INFORMATION PRIVACY NOTICE - Our Policy Regarding Privacy of Your Financial Information


Privacy Overview as Related to Customers

The Oxford Life Family of Companies values the trust and confidence that you, our customer, have placed with us. We are dedicated to the responsible management and protection of your personal financial information. We collect personal financial information in order to serve our customers and to administer our business. Customers are defined as those individuals with whom we have entered into a continuing relationship, such as when an insurance policy is purchased.

This notice explains our Privacy Policy with respect to the collecting and disclosure of your personal financial information.

Personal financial information means information that identifies an individual personally, is not otherwise available to the public and is obtained in connection with providing an insurance product or service to the individual. This includes personal financial information such as, credit history, income, financial benefits, policy or claim information. Personal health information such as individual medical records or information relating to an illness, injury or disability would also be considered to be personal financial information.

Personal financial information may be obtained from the customer, from customer-related transactions and from third parties such as a consumer-reporting agency. We also may collect personal financial information such as name, address, income, payment history or credit history from applications or transactions.

We may share personal financial information with our affiliates, including agents, insurance brokerage companies, businesses hired to carry out services for us, and third party administrators.

In order to serve our customers and to efficiently administer our business, we may share personal financial information with unaffiliated third parties. These third parties may include software companies, agents, insurance brokerage companies, service providers and administrators and other parties as permitted or required by law. We may also share personal financial information with other unaffiliated third parties who are working with us by marketing our products or services or offering our products or services under a joint agreement between us and one or more companies.

Our employees have access to personal financial information while performing their jobs. This includes paying claims, underwriting, advising customers about our products or services and while developing new products.

We use both manual and electronic security measures to protect the confidentiality and integrity of personal financial information and to guard against unauthorized access to it. Security techniques we use include, but are not limited to, user authentication, encryption, computer firewall protection, locked files and detection software programming.

We are responsible for identifying the information that must be safeguarded, providing the necessary protection for the data and allowing access to such data only to those who must use it while performing their jobs. Our Privacy Policy is very important to us, as it protects you, our customer.

We will continue to follow this policy with respect to personal financial information even after a customer relationship has ended.

Our Privacy Policy is subject to change at any time. We will notify our customers of any changes at least annually.

Online (Website) Privacy

When you visit our public website, we do not gather any non-public personal financial information. We do track number of visitors without any retention of personal data. When you send us an e-mail, we do gather the data you provide as contained in the e-mail. Such data is available only on a limited basis, and only to those individuals whose responsibilities include processing and responding to such e-mails.

We want you to understand how we protect your privacy. If you have any questions about this notice, please contact us. When you write to us please include your name, address, and policy number. Send your privacy questions to: Oxford Life Privacy Officer, 2721 N. Central Ave., Phoenix, AZ 85004.

Fraud Notice


Insurance fraud is costly to both consumers and insurance companies. According to the Coalition Against Insurance Fraud, insurance fraud costs Americans at least $80 billion a year – that’s nearly $800 for each family.*

Insurance fraud occurs when a person knowingly presents, helps present, or causes to be presented to any insurer or its producer, or prepares with the knowledge or belief that it will be so presented, a written or oral statement, including a computer-generated document, an electronic claim filing, or other electronic transmission, that contains materially false or misleading information, or a material and misleading omission, concerning:

  1. An application for the issuance of a policy,
  2. The rating of an insurance policy,
  3. A claim for payment, reimbursement, or benefits payable under an insurance policy to an insured, beneficiary or third party,
  4. Premiums on an insurance policy, or
  5. Payment made in accordance with the terms of an insurance policy.

Oxford Life® has procedures in place to protect you from insurance fraud. Prior to making changes to your policy or paying a claim, we will require identification, a notary seal or a signature guarantee. These procedures will ensure that changes and payments are being made and requested by the proper parties, protecting your policy from potential fraud.

Any person who knowingly submits a false statement in an application or files a claim containing false or deceptive statements with intent to injure or defraud the insurer may be guilty of insurance fraud and may be subject to civil fines and/or criminal penalties including imprisonment under state law.

*http://www.insurancefraud.org/80_billion.htm

IRS Approval of Oxford Life as a Non-Bank Trustee


OxfordLife Non-Bank Trustee
Non Bank Trustee Letter