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

As your insurer, Pan-American Life Insurance Company (“Pan-American Life”) may collect certain health information from you, either from your insurance application for coverage or from yourself or your provider for reimbursement of medical expenses, and for other purposes that are permitted or required by law.

We understand that medical information about you and your health is personal. We are committed to protecting medical information about you and will use it to the minimum necessary to accomplish the intended purpose of the use, disclosure, or request of it.

USES AND DISCLOSURES OF YOUR MEDICAL INFORMATION
Pan-American Life is permitted or required by law to use or disclose your medical information without your consent or authorization for the following purposes:

• TREATMENT
  When and as appropriate, we may use and disclose your health information to a physician or other health care provider providing treatment to you.

• PAYMENT
  When and as appropriate, we may use and disclose your health information to process or pay claims, or to collect payment from third parties, such as other health plans or providers, for the care you receive. We may also disclose information regarding your coverage or your medical information to other health plans to coordinate payment of benefits.
  
  
• HEALTH CARE OPERATIONS
  When and as appropriate, we may use and disclose your health information for our own health care insurance operations. These purposes include (i) to conduct quality assessment and improvement activities, (ii) for underwriting, premium rating or related functions to create, renew or replace health insurance or health benefits, (iii) review and auditing, including claims submissions for stop loss (or excess loss), compliance reviews, medical reviews, legal services and compliance programs, (iv) business planning and development including cost management and planning related analyses and formulary development, (v) business management and general administrative activities of Pan-American Life administered health plans, including customer service and resolution of internal grievances.

• HEALTH RELATED SERVICES
  When and as appropriate, we may use and disclose your health information to contact you about health related products and services that may be of interest to you.

• BUSINESS ASSOCIATES
  We may use and disclose your health information to business associates to assist Pan-American Life with its payment or health care operations. In all cases, Pan-American Life contractually requires these business associates to appropriately safeguard the privacy of your information.

• PLAN SPONSOR
  We may, under certain conditions, use and disclose your health information to a plan sponsor for statistical, renewal or quotation purposes. However, your plan sponsor is not permitted to use such information for employment purposes.

OTHER USES AND DISCLOSURES
We may use or disclose your health information as authorized by law as follows:

• for any purposes as required by law;
• for public health activities, such as required reporting of certain diseases;
• as required by law if we believe you to be a victim of abuse, neglect, or domestic violence;
• to health oversight agencies;
• in response to court and administrative orders and other lawful processes;
• to law enforcement officials as required by law;
• to coroners and/or funeral directors consistent with law;
• if necessary to arrange an organ of tissue donation from you or a transplant for you;
• to avert a serious threat to health or safety;
• to the military and to federal officials for lawful intelligence, counterintelligence, and national security activities;
• to correctional institutions regarding inmates; and
• as authorized by and to the extent necessary to comply with state worker’s compensation laws.

Uses and disclosures other than those described in this Notice will require your written authorization.  You may revoke your authorization at any time, but you cannot revoke your authorization if we have already acted on it.

YOUR RIGHTS

You have the following rights regarding the medical information that we maintain about you:

• RESTRICTIONS

You have the right to request restrictions on certain uses and disclosures of your protected health information; however, Pan-American Life is not required to comply with such requests. We will make every effort to do so; however, to request restriction, you must send a written request and tell us:

• What information you want to limit
• Whether you want to limit our use, disclosure or both
• To whom you want the limits to apply, e.g. disclosures to your spouse

• RECEIVING CONFIDENTIAL COMMUNICATION

You have the right to request that Pan-American Life communicates with you in a certain way if you feel the disclosure of your health information could endanger you. For example, you may ask that Pan-American Life only communicate with you at a certain telephone number or by email. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

• ACCESS

You have the right to inspect and obtain a copy of your medical information that may be used to make decisions about your benefits under the Plans.  If you request a copy of the information, we may charge a fee for the costs of copying, mailing, or other supplies associated with your request.   We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to medical information, you may request that the denial be reviewed. If we do not maintain the health information, but know where it is maintained, you will be informed of where to direct your request. A request to inspect and copy records containing your health information must be made in writing.

• AMENDMENT

If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for us.  You also must provide a reason that supports your request.

We may deny your request for an amendment if it is not in writing or does not include a reason to support the request.  The request also may be denied if your health information records were not created by Pan-American Life, if the health information you are requesting to amend is not part of Pan-American Life’s records, if the health information you wish to amend falls within an exception to the health information you are permitted to inspect and copy, or if Pan-American Life determines the records containing your health information are accurate and complete.

• DISCLOSURES

You may request details regarding any disclosures of your medical information while it has been in our possession. You must submit your request in writing.

You must make any of the requests described above to the Privacy Officer listed in the Contact section below.

BREACH NOTIFICATION

Pursuant to changes to HIPAA required by the Health Information Technology for Economic and Clinical Health Act of 2009 and its implementing regulations (collectively, "the HITECH Act") under the American Recovery and Reinvestment Act of 2009 ("ARRA"), this Notice also reflects federal breach notification requirements imposed on the Plans in the event that your "unsecured" protected health information (as defined under the HITECH Act) is acquired by an unauthorized party.

We understand that medical information about you and your health is personal and we are committed to protecting your medical information. Furthermore, we will notify you following the discovery of any "breach" of your unsecured protected health information as defined in the HITECH Act (the "Notice of Breach"). Your Notice of Breach will be in writing and provided via first-class mail, or alternatively, by e-mail if you have previously agreed to receive such notices electronically. If the breach involves:

• 10 or more individuals for whom we have insufficient or out-of-date contact information, then we will provide substitute individual Notice of Breach by either posting the notice on the benefits website or by providing the notice in major print or broadcast media where the affected individuals likely reside.

• Less than 10 individuals for whom we have insufficient or out-of-date contact information, then we will provide substitute Notice of Breach by an alternative form.

• Your Notice of Breach shall be provided without unreasonable delay and in no case later than 60 days following the discovery of a breach and shall include, to the extent possible:

• A description of the breach.
• A description of the types of information that were involved in the breach.
• The steps you should take to protect yourself from potential harm.
• A brief description of what we are doing to investigate the breach, mitigate the harm, and prevent further breaches.
• Our relevant contact information.

Additionally, for any substitute Notice of Breach provided via web posting or major print or broadcast media, the Notice of Breach shall include a toll-free number for you to contact us to determine if your protected health information was involved in the breach.

Pan-American Life will adhere to all state and federal laws or regulations that provide additional privacy protection.

If you have any questions or concerns about Pan-American Life privacy practice, please contact us at:

In the Continental United States:
Pan-American Life Insurance Group
Attn: Privacy Officer
601 Poydras Street, Suite 1530
New Orleans, LA 70130

Email: privacy@palig.com

Telephone: 1-877-939-4550

In Puerto Rico:
Pan-American Life Company of Puerto Rico
Attn: Compliance Department
P.O. Box 364865
San Juan, Puerto Rico 00936

Email: privacy@palig.com

Telephone: 787-620-1414

This notice is provided on behalf of the following Pan-American Life Insurance Group member companies and their subsidiaries:

Pan-American Life Insurance Company, Pan-American Assurance Company and Pan-American Life Insurance Company of Puerto Rico

This notice was last revised on October 1, 2018. We reserve the right to change this notice at any time to comply with applicable laws or to reflect our updated business practices. If we change it, we will post the current notice on this page. Any changes to this notice will be effective as of the day they are posted. By using our site, you consent to our privacy practices.