OnlineNavigator privacy policy

revised 5/14/2012

OnlineNavigator's role is to provide health plan enrollment advice through a consultative process in relation to an individual's overall personal financial planning considerations. This service normally requires the collection, retention and distribution of private information including personal, health and financial information as part of our regular business procedures.

The term "private information" used here in a generic sense is meant to incorporate the terms "private personal information", "protected health information" and "personal financial information" as defined and controlled under various privacy laws. This privacy statement expands and explains the treatment of each of these items as it affects your privacy at OnlineNavigator.

Private personal information is defined by the federal government as the combination of an individual's name with at least one of the following: 1) social security number, 2) credit card information or 3) financial account information. State laws may use a similar or slightly different definition. While we do not normally have access to credit card information or financial account information, the federal government does require a navigator to report the user's social security number. Private personal information is used only to provide the specified service and then treated in the same manner as all other electronic data and communications as described below.

Protected health information - Health information privacy is primarily controlled by a federal law know as HIPAA that defines and controls the handling of "protected health information". OnlineNavigator is not a covered entity as defined by HIPAA as determined by guidance published by the Centers for Medicare and Medicaid Services. Private health information that is not controlled by HIPAA is protected in the same manner as other private information.

Personal financial information - Financial information is controlled by various state and federal authorities as well as industry self-regulatory groups. Our primary governing body on the handling of private financial information is the American Institute of Certified Public Accountants. Additional information is available in this article titled "Code of professional conduct for a Certified Public Accountant acting as navigator".

Business financial information - Businesses typically need to reveal financial information to a navigator and an insurance company in order to determine eligibility for coverage of its employees and determination of tax subsidies for the employer. Our primary governing body on the handling of private financial information is the American Institute of Certified Public Accountants. Additional information is available in this article titled "Code of professional conduct for a Certified Public Accountant acting as navigator".

Data security and management - OnlineNavigator uses secure data management services for the handling of all private information. While the risk of data security cannot ever be entirely eliminated, we believe that these secure cloud-based data services provide the highest level of protection commercially and practically available to protect your private information.

Our internal control of data security meets or exceeds the industry standards of the financial advisory industry, specifically those addressed by the AICPA TTI II statement in 2011. We do not meet the HIPAA data security standards required of health care providers, accountable care organizations or health insurance companies.

Affiliated company privacy policies - Each of the independent insurance companies, accountable care organizations, health plans or third party plan administrators listed on our Web pages or referred through our service has its own privacy policy for handling data in its operations which, in general, are far more extensive than the procedures and policies at OnlineNavigator. We encourage users to be aware of the privacy policies of each company providing any related service.

Experience and track record - We have not received any customer complaints or any report of customer concerns regarding the online privacy procedures or other data security issues with regard to OnlineNavigator or its predecessors or affiliates including Freedom Benefits, OnlineAdviser or any of the independent companies or health plans referred through our service. Given this experience record dating back to 1997, we have no reason to believe that any material weakness in the privacy policy or procedures exists in our operations or those of any affiliated company.

Changes to privacy policy - Privacy concerns are a high priority evolving issue for virtually every segment of the health care, financial service and consumer regulatory industries. Updates to our privacy policy are expected as industry standards evolve.

Privacy concerns - If you have any questions or concerns about privacy issues at OnlineNavigator.org please contact our privacy officer Tony Novak.