Sterling Thompson
Privacy Policy

Sterling Thompson Company
Notice of Privacy Practices
Effective April 1, 2014

In compliance with certain applicable laws, the Gramm-Leach-Bliley Act (GLBA) and the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Sterling G. Thompson Company (“SGT”) has adopted these policies. SGT acknowledges clients’ privacy rights as specified in these laws, and has adopted policies and procedures to ensure your privacy rights are protected.

This notice describes how nonpublic personal financial information (NPFI) and protected health information (PHI) about you may be used and disclosed and how you can access this information. In this notice, we explain how we protect your NPFI and PHI, hereafter known as “confidential information”, and how we will allow it to be used and given out (“disclosed”). We are required to provide you with a copy of this Notice of Privacy Practices upon request. We must follow the privacy practices described in this notice while it is in effect.

Our Commitment Regarding Your Confidential Information:
SGT is committed to protecting your confidential information; we understand the importance of your confidential information and follow strict policies (in accordance with state and federal privacy laws) to keep your information private.

Confidential Information We Collect:
• Confidential information including demographic data that can reasonably be used to identify you, including your name, address, phone number, date of birth, marital status, sex, social security number and medical information, including information about your transactions with us, claim history and premium payments.
• Confidential information that relates to your past, present or future physical or mental health, the provision of health care to you, or the payment for that care.
• Confidential information regarding current or prospective clients we obtain about them on applications or other forms.
• Confidential information about your insurance transactions with us, our affiliates, or others.

How We Use (Disclose) Your Confidential Information
• We collect and use confidential information we believe is necessary to underwrite your policies, process your claims, ensure proper billing, and service your accounts.
• We share confidential information as necessary to handle your claims and to protect you against fraud and unauthorized transactions.
• We may provide confidential information to you in order to supply you with information about your insurance
• We do not sell your confidential information.
• We do not provide confidential information to persons or organizations outside SGT for marketing purposes.
• We may share your confidential information with others that perform administrative services for us.
• We may provide confidential information that we collect to third-parties involved in the underwriting, processing, servicing and marketing of your SGT insurance products. We will not provide this information to any other third party for purposes other than set forth above
• We will not provide your confidential information to any third party unless we have a written agreement that requires such third party to protect the confidentiality of this information and use it only for the purpose for which it was shared.
• When we provide your confidential information to any third party, we will provide only a limited data set, or if needed, the minimal amount of information that we deem is necessary.
• We do not disclose any confidential information about you to anyone except as permitted by law, as required by the law or the courts, for public health and safety activities or to avert a serious threat to the health and safety of others.
• We may provide confidential information to you if you request to inspect your confidential information.
• We may disclose your confidential information to someone who has the legal right to act on your behalf.
• We may provide confidential information to the extent necessary to comply with laws related to workers’ compensation or similar programs.
• We must obtain your written authorization for any disclosures of your confidential information for purposes other than those listed above, including disclosures of psychotherapy notes or for marketing purposes.
• If you authorize us to share your information, you may revoke your authorization at any time, except to the extent that we have taken action upon it.

How We Protect Your Confidential Information
Your privacy is a high priority for us and it is treated with the highest degree of respect. We collect and use confidential information we believe is necessary to administer our business and to provide you with customer service. However, we want to emphasize that we are committed to maintaining the privacy of this information in accordance with law. All individuals with access to confidential information about our customers are required to follow this policy.
• SGT has policies that restrict access to confidential information about our clients to those employees who have a need for that information to provide products and services to the client. Access must be granted to those entities to enable them to provide the excellent service you have come to expect from SGT.
• We maintain administrative, technical, and physical safeguards that comply with state and federal standards to protect your confidential information.
• If we become aware that an item of confidential information may be materially inaccurate, we will make a reasonable effort to re-verify its accuracy and correct any error as appropriate.
• If we believe your confidential information has been breached, you will receive a written notification of the suspected breach.

Your Rights
You have the following rights. To exercise these rights, you must make a written request to our Privacy Officer, and we must act upon your written request within 60 days.
• You have the right to inspect confidential information in your file and request that we amend it in your file.
• You have a right to obtain a copy of your confidential information that we use or maintain in your file or electronic health record. We reserve the right to charge a reasonable cost-based fee to provide such information to you or your specific designee.
• You have the right to an accounting of certain disclosures of your confidential information for up to six years prior to the date of the request.
• You have the right to request that we place restrictions on the way we use or disclose your confidential information. We shall inform you within 30 days of our decision to honor your request. We shall agree to any request to restrict the disclosure of your confidential information if the disclosure is for carrying out payment or health care operations and you have paid the provider in full, out of your pocket.
• We communicate information on products and services, which may contain confidential information, to our clients. Clients who believe that this practice may endanger them may request that we communicate with them using a reasonable alternative means or location.

Our Duties
• SGT is required to abide by the terms of this Notice, and reserves the right to change the terms of this notice at any time, provided that applicable law permits such changes. These revised practices will apply to your confidential information regardless of when it was created or received. Before we make a material change to our privacy practices, we will provide you with a revised Notice of Privacy Practices.
• Where multiple state or federal laws protect the privacy of your confidential information, we will follow the requirements that provide the greatest protection.

Questions and Complaints
If you need more information about our privacy practices, or a written copy of this notice, please contact:

Privacy Officer
Sterling G. Thompson Co.
545 South Third Street, Suite 300
Louisville, KY 40202
(502) 585-3277

You may complain if you are concerned that we may have violated your privacy rights, or you believe that we have inappropriately used or disclosed your confidential information. The complaint must be filed in writing and sent to:

Privacy Officer
Sterling G. Thompson Co.
545 South Third Street, Suite 300
Louisville, KY 40202
FAX (502) 585-3306

You may also submit a written complaint to:

Region V, Office of Civil Rights
U.S. Department of Health and Human Services
233 N Michigan Ave, Ste 240
Chicago, IL 60601
Voice mail: (312) 866-2359 Fax: (313) 866-1807

We support your right to protect the privacy of your confidential information. We will not take action against you if you file a complaint.