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Consumer Privacy Regulation
Questions & GLB Act |
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What is the relationship between
Paul Revere and UnumProvident Corporation?
The Paul Revere Life Insurance Company is a subsidiary of UnumProvident Corporation. If
you would like to learn more about this relationship, please visit www.unumprovident.com
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What is GLB?
GLB refers to the Gramm-Leach-Bliley Act of 1999. This federal act primarily addresses
financial services industry reform and includes a section (Title V) relating to consumer
privacy. The purpose of Title V is to address how personal, nonpublic financial
information is shared and to safeguard consumers. Insurance companies are considered a
"financial institution" and must comply with the GLB Act.
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I think my state has different
laws for insurance, so what does UnumProvident do for customers living here?
Each state regulates the way insurance business is conducted in that state. The GLB Act
directs that each state must have insurance laws that provide for the minimum level of
consumer privacy practices contained in the GLB Act. UnumProvident's consumer information
handling practices are designed to comply with all states' privacy requirements.
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What was UnumProvident
Corporation's previous privacy policy and has it changed as a result of the GLB Act?
UnumProvident has always maintained a high level of confidentiality over customer data, so
the GLB Act does not substantially impact the way UnumProvident does business.
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What is considered
"nonpublic personal information"?
"Nonpublic personal information" refers to any personally identifiable
information regarding a person's financial affairs or health. For example, financial
information would include any information that may be found on a credit report. Also, an
example of health information would include information about a person's physical, mental,
or behavioral condition that might be found on a doctor's report used for underwriting or
claims management.
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With whom is this "nonpublic
personal information" shared?
UnumProvident only shares consumer information as permitted by law and only as needed to
service your insurance contract. This includes sharing of information with our affiliate
organizations like GENEX, which assist in providing rehabilitation services to claimants.
The other situations in which UnumProvident would share information are with contracted
parties such as, producers and credit reporting agencies who assist us in servicing your
policy.
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What safeguards are taken to
ensure that this "nonpublic personal information" is protected?
Only authorized employees handle consumer information in the servicing of your policy.
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How often will customers be
receiving a "Notice of Privacy Practices"?
The law requires UnumProvident to inform its customers of our information handling
practices each year. UnumProvident fulfills this obligation by mailing its customers a
copy of its privacy notice annually.
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If I don't want to receive the
notice can I have it stopped?
At this time, we must send you this privacy notice annually.
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I know that UnumProvident
administers my policy that is from another company (for example, William Penn, Equitable,
Protective). How does UnumProvident handle customer information that belongs to another
company?
UnumProvident observes the same stringent privacy practices over all of the customer data
it administers. We do not share customer information except as permitted by law. In
administering business for other insurance companies we are acting on their behalf and
will provide you with a copy of that company's privacy notice. Upon request, we will also
provide you with a copy of UnumProvident's Privacy Notice.
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May I request that UnumProvident
not share my information with non-affiliated third parties (opt-out)?
The GLB Act requires us to give you the opportunity to "opt-out" so that you may
instruct us not to share your information with non-affiliated third parties for reasons
that are unrelated to insurance functions or outside of certain marketing exceptions.
Because we do not share your information with non-affiliates for those purposes, we are
not offering an opt-out.
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May I request that UnumProvident
not share my information with affiliates?
Most of UnumProvident's insurance affiliates share common claims payment information as
well as other customer support service systems. Under the GLB Act, we are permitted to
share information with our affiliates without offering an opt-out.
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The last bullet of
UnumProvident's Notice of Privacy Practices states, "The law also permits us to share
this information with companies that perform marketing services for us, or other financial
institutions that have joint marketing agreements with us." What does this mean?
The GLB Act allows us to share your nonpublic personal financial information, without
offering an opt-out, for certain marketing purposes. Those purposes include:
- Sharing with Non-Affiliates
We may share information with non-affiliated third parties if the third party is marketing
our insurance products and services and we have an agreement with the third party. The
agreement must include a provision that prohibits the third party from using or sharing
the information for any reason other than the purpose for which we gave the information to
the third party.
- Sharing with Other Financial Institutions
We may share information with other financial institutions, such as banks and insurance
companies, to market financial products and services; however, we must have a "joint
marketing" agreement with the other financial institution. The agreement must include
a provision if the third party is marketing our insurance products and services and we
have an agreement with the third party. The agreement must include a provision that
prohibits the third party from using or sharing the information for any reason other than
the purpose for which we gave the information to the financial institution.
- Sharing with Affiliates
The GLB Act also allows us to share information with our affiliates for marketing
purposes.
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Why am I receiving this
privacy
notice?
The federal government deemed that it was in consumers' best interest to receive this
information. We are required to provide this Privacy Notice to our customers when a policy
is issued (the customer relationship is established) and once every 12 months.
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Do I need to sign or return
anything?
No, you do not need to sign or return anything to UP. This notice is for your information
only. No action is needed. Please file the privacy notice along with your insurance policy
for future reference.
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Do customers of
group policies
receive the privacy notice?
A large number of UnumProvident's group policies are issued to employers, who are the
legal owners of the policy. UnumProvident is required to provide the
privacy notice to the
policy owner, so the employer, or the organization to which the group policy was issued,
receives a copy of the privacy notice. Insureds or participants (certificate holders)
covered under a group policy do not receive privacy notices individually. However, any
individual may obtain a copy of UnumProvident's privacy notice in several ways: (1) by
requesting a copy from their employer, or the organization to whom the
group policy was
issued, or (2) by visiting www.unumprovident.com.
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What work has been done by
UnumProvident for the GLB Act?
UnumProvident established a project team to address the new privacy regulations in early
2000. The team consisted of representatives from all areas of the company. A plan has been
developed to ensure the company's compliance by July 1, 2001, as required.
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What are examples of
"information that may not be directly related to" my transaction with
UnumProvident?
"Information that may not be directly related to" your transaction with
UnumProvident could include information that is developed by outside parties, such as
where you have worked in the past, previous medical conditions, or credit history.
Information that is directly related to your transaction could include whether you have
paid your premium, the benefits under your policy and information regarding your claim.
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What is the Fair Credit Reporting
Act and why is it mentioned in the GLB privacy notice?
The Fair Credit Reporting Act is a federal law that has been in effect for years. Like
GLB, it addresses the sharing of consumer information. We are currently required to
mention the Fair Credit Reporting Act in our GLB privacy notice.
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