These privacy policies and procedures implement our obligation as an insurance officeto protect the “nonpublic personal information” that we create, receive or maintain onconsumers or customers. Throughout the policy, we refer to information that can identifyyou as a specific individual, such as your name, phone number, email address, SocialSecurity number or credit card number, as "personal information." Further, personalinformation includes any information involving your health or medical history.
1. No use or disclosure: Our insurance office will not use or disclose nonpublicpersonal information except as these Privacy Policies & Procedures or our annualprivacy practices notice permit, require or as permitted by law.
2. Medical Information Privacy: Our office will not disclose or share medical or otherspecified information at any time as defined by law with out an expressed writtenconsent from the consumer/customer. A consumer/customer may at any time revoketheir consent to disclose or share information by written notice. The revocation will beplaced in the consumer/customers file and notations made in any electronic records.
1. We do not sell, trade or give away your personal information to anyone.
2. We do not disclose your personal information to third parties, unless one of theThe following limited exceptions apply.o Insurance Companies and Licensed Agents. If you submit an applicationfor an insurance product offered by us, then we will disclose your personalinformation to your chosen insurance company to process yourapplication.o Legal Obligations. We may disclose or report your personal informationwhen we believe, in good faith, that the disclosure is required or permittedunder law, for example, to cooperate with regulators or law enforcementauthorities or to resolve consumer disputes.Outside of these exceptions, we will not share your personal information withthird parties.
3. We collect personal information in the normal course of business in order toprocess your insurance application and to serve you better.Providing you with a quote or processing your application. We may use yourpersonal information to get in touch with you when necessary to process yourapplication or to provide you with a quote. For example, emails will be sent toyou throughout the application process to inform you of the status of yourapplication and to seek additional information that is requested as part of theapplication.
4. We gather anonymous information about you for our internal purposes, and wemay share this anonymous information with third parties.o Anonymous information is any information that does not personally identifyyou, including aggregate demographic information such as the number ofvisitors to our website from a particular state.o We use anonymous information primarily for marketing purposes and toimprove the services we offer you.
We may use "Cookies," "Internet Protocol" addresses or other numericcodes to gather anonymous information. For a more detailed discussionon cookies, please see below.
4. Notice of Privacy Procedures: Our office will provide an initial and annual PrivacyPractices Notice to each customer as required by law and to all consumers beforedisclosure of any nonpublic personal financial information to nonaffiliated third partiesfor marketing purposes. We will promptly revise our Privacy statement to reflect thesechanges.Practices Notice when there is a material change to our use or disclosure of nonpublicpersonal information, nonpublic personal financial information, legal duties, consumersor customers rights or to other privacy practices that render the statements in that noticeno longer accurate.The notices are available upon request.
Opt-out notice: Each customer/consumer will receive their initial privacy practicesnotice prior to disclosure and or sharing of their nonpublic personal financial informationwith nonaffiliated third parties for marketing purposes as required by law. Additionallythey will receive an opt-out notice a minimum of 30 days, before any sharing ordisclosure of nonpublic personal financial information with any nonaffiliated third partyas required by law. A consumer may exercise the right to opt-out at any time bycompleting our opt-out form and returning it to us.
Our insurance office will include thecompleted opt-out form in the consumer’s physical file and make the appropriatenotation and changes to their electronic records. Our insurance office will not share ordisclose any customer / consumer nonpublic personal financial information with anyperson except as allowed under the law or with written consent once we receive acompleted opt-out notice.
A consumer/customer may at any time revoke their opt-out by written notice. Therevocation will be placed in the consumer/customers physical file and notations made inany electronic records.
5. Distribution of Our Notice: Each customer will receive his or her initial privacypractices notice from this office no later than the delivery of an insurance policy, serviceor financial product. Each customer will receive a notice annually on a date establishedby us, which reflects our current privacy practices. This annual privacy noticesupersedes all prior initial or annual notices.
6. Minimum Necessary Disclosure: Our office will make reasonable efforts to protectconsumer/customer privacy by disclosing or sharing the minimum necessary nonpublicpersonal information to accomplish the intended function, transaction, or service.
7. Customer / Consumer Rights: Our insurance office will honor customer’s andconsumer’s rights regarding their nonpublic personal information.a. Access---Our insurance office will honor requests in writing to view and copycustomer / consumer records that are reasonably identified, reasonably locatable and retrievable.
We will with in 30 days of receipt of the request contact the customer /consumer and inform them of the nature and substance of the recorded information andmake arraignments for them to view the information and make copies for them for whichwe will charge $.10 per page plus $30 per hour for staff time.b. Amendments---Customers/consumers have the right to request an amendment,correction or deletion to their nonpublic personal information held by us. Our office will,within 30 days of such request, inform the customer/consumer of our decision toamend, correct, or delete or our decision to not amend, correct or delete.
If we decide toamend, correct or delete we will notify the customer/consumer in writing.c. If we decide not to make any changes the customer/consumer has a right to submit inwriting a concise statement setting forth what the customer/consumer thinks is thecorrect, relevant or fair information and why they disagree with our refusal to amend,correct, or delete nonpublic personal information in their file. Our office will put thisstatement in the customer’s/ consumer’s file. In the future if we share or disclose anynonpublic personal information from the file we will also furnish a copy of thecustomers/consumers request to amend, correct, delete, our letter informing them of ourdecision and their response.
The rights granted in this section do not extend to information about thecustomer/consumer that relates to and is collected in connection with or in reasonableanticipation of a claim or civil or criminal proceeding involving them.8. Privacy Officer: Our insurance office will designate one person to be the privacyofficer. He or she will have primary responsibility for privacy and security issues. He orshe will also be the contact for all complaints involving privacy or security matters.9. Staff Training: Our insurance office will train all members of our workforce in these
Privacy Policies & Procedures, as needed and appropriate for them to carry out theirfunctions. All members of our workforce will acknowledge in writing within a reasonabletime of employment their receipt and training on these Privacy Policies & Procedures.10.
Data Safeguards: Our insurance office will develop, implement, annually reviewand maintain reasonable and appropriate administrative, technical and physicalsafeguards to ensure the integrity and confidentially of the nonpublic personalinformation we hold and maintain.
a. Physical Access--- Our insurance office will monitor and ensure that during normalbusiness hours no person is unescorted or unmonitored within the office unless they are
Privacy Statement an employee or a business associate with whom we have a contract that appropriatelylimits their use and disclosure of nonpublic personal information held or maintained bythis office. Our insurance office will identify, monitor and control who is authorized toposses and who possess keys or the necessary codes for securing and entering theoffice. Upon any termination of employment keys will be collected and codes changedto maintain the security of the office.b. Business Associates: Our insurance office will obtain a written contract from allnonaffiliated third parties who will have access to or receive nonpublic personalinformation in the course of their duties for us. This contract will provide for appropriatesafeguards and limit their use and disclosure of the nonpublic personal information weshare or disclose to them.c. Physical Data: Our insurance office will secure all physical data that containsnonpublic personal information. All files not in use will be filed. No files will be left out ofthe filing containers over night.
All file containers will be secured when the office isclosed or not occupied.d. Electronic Data: Our insurance office will provide controls on access to andauthentication of persons using electronic data. Our office will install, maintain, andupdate necessary virus protection, firewall protection and software updates as needed.All employees who must have access to electronic data will have their own unique userID and unique password. These will be controlled and changed periodically by thePrivacy Officer as needed for employee terminations, updates, new software, etc. Ouroffice will ensure that floppies, CDs, DVDs, zip drives, hard drives, electronic tape, offsite storage etc. are included in the access and authentication procedures. We willensure that the intentional destruction of data is done using a secure method.e. Employee training: Our office will provide annual training on the Privacy Policiesand Procedures for protecting the electronic data or form of nonpublic personalinformation we hold or maintain. We will document the time, date, persons inattendance and subjects covered.
11. Annual Security Assessment: Our insurance office will do an annual Cal-GLBAPrivacy and Security Gap Assessment to ensure these policies and procedures arebeing performed and working as intended. Our Security Officer will initiate theassessment.