Cigna International Health Services Data Protection Notice
Cigna International Health Services collects personal data, including medical data, in order to carry out its functions as an insurance broker and claims handler, provide membership services and comply with certain statutory obligations. All personal data are treated with the utmost confidentiality and with appropriate levels of security. This Notice describes our data protection procedures. Please review it carefully.
Cigna International Health Services BVBA (“CIHS”), with registered office located at Plantin en Moretuslei 299, 2140 Antwerp, Belgium, and with enterprise number 0414.783.183 (Register of Legal Entities Antwerp) (FSMA: 13799 A-R) and being part of the Cigna Corporation, is committed to the responsible management, use and protection of personal data of our customers, individual members, beneficiaries, providers and partners. Any personal data processed by CIHS is subject to the terms of this Notice, which supplements the Cigna Online and Mobile Privacy Notice, the Cigna Cookie Notice and any other applicable notices made available to you.
Personal Data Processed
The data collected by CIHS include:
- Name, address, email address and birth date;
- Financial and health information;
- Credit or debit card number;
- CIHS ID;
- Password and PIN;
- Medical claims status and information;
- Plan information, including benefits and coverage;
- Eligibility information; and
- Other personal data supplied by our customers, individual members, beneficiaries, providers and partners.
Personal data includes medical data which we collect upon consent (art. 7, § 2a of the 1992 Belgian Personal Data Protection Act) and in accordance with insurance law requirements.
How We Use Personal Data
We use personal data for the following purposes:
- Transactions. We use personal data to complete transactions and respond to your requests, for example, to process claims or insurance payments, provide plan information, search for health care providers, ensure that you obtain the services and treatment you may need or allow you to view and print your CIHS ID card.
- Communications. We use personal data to send administrative information to you, for example, information regarding changes to our terms, conditions and policies, to provide you with a quote for one of our products or to send you surveys. Except as permitted by law, we will not use your personal data for marketing purposes without your prior authorization.
- Customer Service. We use personal data to provide and improve customer service, including the use of chat or similar features available through our services.
- Conducting our business. We use personal data to perform analysis audits and to develop new products, enhance, improve and modify our services, identify usage trends, support and/or improve the clinical programs or services we offer you, assist you in managing your health, determine the effectiveness of our promotional campaigns and continue to operate and expand our business activities.
- Research. We may use your personal data for research and analytics purposes, but only according to and as allowed by law.
- Compliance with the law and legal process. We may use and disclose your personal data to take any action that we believe to be necessary or appropriate: (a) to investigate, prevent and detect insurance fraud and other illegal activities; (b) under applicable laws, including laws outside your country of residence; (c) in a judicial or administrative proceeding or in response to a valid legal order; (d) in compliance with a court order or other process authorized by law, to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (e) to enforce our terms of service and privacy notices; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you and others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
- Other. We use personal data for other purposes specifically disclosed at the time when we collect your personal data.
How We Disclose Personal Data
We may need to disclose your personal data if they are necessary for the following purposes:
- Health care operations. We share personal data with our partners as required to provide customer service, support and/or improve the programs or services we offer you, assist you in managing your health and support other health plans, insurers or health care professionals. As applicable, this may include regional health and insurance in order to provide technical and operational support to offer high quality health care, to process applications and payments and handle claims. A list of these providers will be sent to you upon your request. Please contact us at the below address and we will arrange to send you a copy.
- Payment. We may share personal data with your plan sponsor, administrator, financial and health service providers to obtain payments, including premiums for your coverage, make coverage determinations, coordinate benefits with other coverage you may have and otherwise determine and fulfill our responsibility to provide your health benefits, for example, to administer claims.
- Disclosures to your employer as sponsor of your health plan. Where required and permitted by law, we may disclose your personal data to your employer or to a company acting on your employer’s behalf, so that the entity can monitor, audit and otherwise administer the employee health plan in which you participate. Your employer is not permitted to use the personal data we disclose for any purpose other than administration of your benefits.
- Communications. We may disclose your personal data to encourage you to purchase or use a product or service that is not part of the health care services and benefits we provide when we meet with you in person, as permitted by law, or provide you with a promotional gift of nominal value.
- Health oversight activities. Where required by law, we may disclose your personal data to a government agency that is legally responsible for oversight of the health care system or for ensuring compliance with the rules of government benefit programs.
- Disclosures to service providers and vendors. We may also disclose personal data to service providers, including for claims handling on our behalf.
Sharing with Affiliates. In addition, we share some personal data with Cigna Corporation and other affiliates to provide customer service, support and/or improve the programs or services we offer you including the handling of claims, and support another health plan, insurer or health care professional who has a relationship with you for activities such as case management, care coordination and quality improvement activities. A list of affiliates who may access or receive personal data can be found here4. Note that personal data may be shared with recipients located in countries that provide different legal protection for personal data.
How We Protect Your Privacy
We understand the importance of protecting your personal data. We restrict access to your personal data to authorized workforce members who need that information for legitimate purposes such as your treatment, payment purposes and/or health care operations. We maintain technical, physical and administrative safeguards to ensure the privacy and confidentiality of your personal data. Our Compliance & Privacy Officer monitors how we follow the policies and procedures and educates our organization on this important topic.
Your Individual Rights
You have the following rights regarding the personal data that we collect and/or maintain about you
- Right to access your personal data. You may ask to access any personal data we maintain about you.
- Right to correct your personal data. You have the right to ask us to correct your personal data contained in our electronic or paper records if you believe it is inaccurate. If we determine that the personal data is inaccurate, we will correct it if permitted by law.
Actions You May Take
If you have questions about your privacy rights, or wish to request access to or correction of your data, you can contact us at the following address or send us an email at firstname.lastname@example.org.
Cigna International Health Services BVBA
Attn: Compliance & Privacy Officer
Plantin en Moretuslei 299
Notice Availability and Duration
Notice availability. A copy of this Notice is available for you to view, print and/or download on our website.
Right to change terms of this Notice. We may change the terms of this Notice at any time. If we change this Notice, we will update the Notice on our website and, if you are enrolled in a Cigna Global Healthcare Business Plan at that time, we will send you the new Notice, as required. In addition, you can obtain a copy of the new Notice upon request when you call the International Service Centers or from our website
Effective date. This Notice is effective as of 2 February 2015. This Notice was last updated on 2 February 2015.