Privacy Policy

At RealLife HR, protecting confidential employee information is of paramount importance.   A copy of our privacy policy is provided below for your information.

RealLife HR Notice of Privacy Practices ("Notice")

This Notice Describes How Medical Or Other Health Information About You May Be Used And Disclosed, And How You Can Get Access To This Information.

Please Review This Notice Carefully.

If you have any questions about this Notice, please contact our Privacy Contact who may be reached c/o RealLife HR Member Services, 10150 York Road, Hunt Valley, Maryland, 21030 USA.

RealLife HR is strongly committed to protecting the confidentiality of your personal identifiable health information.  This Notice will let you know about the various ways we use and disclose your personal identifiable health information and describe your privileges and our obligations with respect to the use or disclosure of such information.  RealLife HR collects some information from you that may be subject to the Health Information Portability and Accountability Act ("HIPAA") which is called protected health information ("PHI"), and other information that is not subject to HIPAA ("non-PHI").

HIPAA imposes numerous requirements on covered entities concerning the use and disclosure of PHI.  PHI is health information that can identify a specific individual.  It includes, for example, information about the health care received by an individual and the amounts paid for such care.  This Notice will tell you about the ways in which we may use and disclose your PHI and non-PHI, certain obligations we have regarding the use and disclosure of PHI and non-PHI, and your rights with respect to your PHI and non-PHI.

It is important to recognize that health information held by and contained in the employment records of your employer is not covered by this Notice and is not subject to HIPAA, but may be subject to other laws.  In addition, your health care providers may have different policies or notices regarding their use and disclosure of your PHI and non-PHI, so we encourage you to review their policies.

You, your spouse and/or your dependents may participate in health plans available to you through your employer, union or other plan sponsor ("Plans").  Your Plan will provide its own Notice, which you should review carefully.

Section I
Collection of PHI and non-PHI

RealLife HR collects PHI and non-PHI about you from various sources including, but not limited to, the following:

• Information about your transactions with us, our business partners and our suppliers;
• Information we receive from our server logs from your browser, including your IP address, cookie information, the type of browser, and the page you requested;
• As an employee (or a family member of an employee) of an employer who subscribes to a RealLife HR service, we may have access to your personal and/or health information that is or has been created or received by us from you, your employer, your employer's Plans, or any of your health care providers that relates to your past, present or future physical or mental health or condition;
• By subscribing to a RealLife HR service, you may give, or authorize others to give, medical, health or other personal identifiable health information to us about you or others in your family;
• By registering for a RealLife HR service and at other times (including, but not limited to, entering into a sweepstakes, contests or promotions sponsored by us or reporting a problem with a RealLife HR service to us), you will be asked to complete forms, applications and other documents that require personal identifiable information, such as your name, email address, address and enrollment information; and
• By visiting our site, you may post messages, use software tools and participate in discussion boards, which may require the submission of information by you.

Section II.
Uses and Disclosures of Your PHI

We may use and disclose your PHI in any of the ways described below.  For each category of uses or disclosures we will explain what we mean and try to provide some examples, but not every use or disclosure in a category will be listed.

For Treatment.   We may use your PHI for treatment purposes, such as to conduct case management or coordination.  For example, we may disclose your PHI to doctors, nurses, pharmacies, or other medical personnel who are involved in treating you, and they may request your PHI from us to supplement their own treatment records.

For Payment.  We will use and disclose your PHI for payment purposes, such as:

• To inform health care providers and suppliers about your eligibility and that of any other person covered under the Plans by reason of your employment with your employer.
• To enroll or disenroll you from Plans with which we contract to provide service.
• To inform health care providers and suppliers about required copayment and deductible amounts under the Plans.
• To coordinate benefits when some other plan may be liable for some or all of the costs of your care.
• Or to communicate with you, your health care providers, and others about the status of claims for your care, as well as to track and receive contributions and premiums under the Plans.

For Health Care Operations.   We will use and disclose your PHI for our operations.  For example, we may use your PHI for activities such as:

• To evaluate the utilization and effectiveness of benefits under the Plans.
• To assist in making underwriting or similar decisions.
• To obtain reinsurance (including stop-loss and excess of loss insurance).
• In the business management and general administration of the Plans. 
• Or for customer service, internal grievance resolution, or appeals of denials of payment or coverage under the Plans. 

To the Plan Sponsor.   We may disclose your individual health information to your employer, or other sponsor of a Plan, so that your employer or other plan sponsor can make decisions about the current or future structure of the Plan and can administer benefits under the Plan.

To, From, and Between Business Associates.  We contract with Plans to provide services under Business Associate Agreements.  We may contract with other Plans to provide some services.  In performing the jobs we have asked them to do, we may disclose your PHI to our business associates, we may receive your PHI from our business associates, and our business associates may share your PHI between themselves.  For example, we may disclose your PHI to a subcontractor who manages the servers supporting the services available on our Web site.  To protect your PHI, however, we require business associates to sign contracts agreeing to appropriately safeguard your information.

To Family and Friends.  We may disclose your PHI to a family member or friend, provided the information is directly relevant to that person's involvement with your health care and payment for that care.  You have a right to request us to limit such disclosures as described herein.

For Treatment Alternatives, Other Health-Related Benefits and Services, and Treatment Reminders.   We may use and disclose your PHI to tell you about or recommend possible treatment alternatives, other health-related benefits or services, or about other plans or certain value added services, that may be offered from time to time.  We may also send treatment reminders.

As Required By Law.   We will disclose your individual PHI when federal, state, or local law requires us to do so.

In Special Situations.   We may also release your PHI as allowed under HIPAA, including under the following circumstances:

• To facilitate organ and tissue donation and transplantation.
• For specialized governmental functions, including the military and veterans, national security, criminal corrections and public benefit purposes.
• For workers' compensation or similar programs, as permitted by law.
• For public health activities.
• To prevent and avoid a serious threat to the health or safety of the public or another person.
• To notify the appropriate government authority, if we believe a patient has been the victim of abuse, neglect, or domestic violence.
• For health oversight activities including, for example, audits, investigations, actions, inspections, and licensure.
• For lawsuits and disputes, we will disclose your PHI in response to a valid court or administrative order or in the course of defending ourselves.
• For law enforcement purposes when asked to do so by a law enforcement official.
• To coroners, medical examiners, and funeral directors as necessary to assist them in their duties.
• To correctional institutions or law enforcement officials with respect to inmates.
• Under certain circumstances, for research.
• Or in response to investigations by Department of Health and Human Services.

By Written Authorization.   Except as described above, we will disclose your PHI only with your prior written permission (called an "authorization" under HIPAA).  You may revoke an authorization, in writing, at any time, unless we have taken action relying on the authorization or if you signed the authorization as a condition of obtaining insurance coverage.

Section III.
Your Privacy Rights With Respect to PHI

You have the following rights regarding the PHI we maintain about you. Except as otherwise provided below, to exercise these rights, you must submit your request in writing to the HIPAA Privacy Officer, in care of Member Services, 10150 York Road, Hunt Valley, Maryland 21030.

Right to Inspect and Copy.   With certain exceptions, you have the right to inspect and copy your PHI maintained in the RealLife HR's "designated record set."  The RealLife HR's designated record set consists of enrollment and case management records, as well as other records used by us while providing services to you.  The designated record set does not include psychotherapy notes and information compiled in anticipation of a criminal, civil, or administrative action or proceeding.

We will generally act on your written request within 30 days of receipt, unless the information is not maintained or accessible to RealLife HR on site, when we generally will act within 60 days.  Where appropriate, we may provide you with a summary of your PHI rather than access to, and copies of, it.   If you request a copy of the information, we may charge a reasonable fee for the costs of copying and, in some circumstances, summarizing the information, and mailing it to you.  If RealLife HR or its business associates do not maintain the PHI, but know where it is maintained, you will be informed where to direct your requests.

We may deny your request to inspect and copy your PHI.  In certain very limited circumstances, our denial will be unreviewable.  Ordinarily, however, you may request within a reasonable period of time that the denial be reviewed.  Except for unusual circumstances, 90 days will be deemed a reasonable period of time in which to request a review.  We will have a person other than the person who initially denied your request review that denial.   We will comply with the outcome of the review.

Right to Request Amendment.   If you feel that the PHI we have about you in the RealLife HR's designated record set is incorrect or incomplete, you may ask us in writing to amend the information.  You must provide a reason that supports your request.

We will generally act on your request within 60 days.  We may deny your request for an amendment if it is not in writing or does not include a reason to support the request.  In addition, we may deny your request if you ask us to amend information that:

• Was not created by us, unless the person or entity that created the information is no longer available to make the amendment.
• Is not part of the RealLife HR's designated record set.
• Is not part of the information which you would be permitted to inspect and copy.
• Or is accurate and complete.
• If we deny your request, we will keep your request on file.  We will distribute it (or a summary) with all future disclosures of the information to which it relates, but only if you ask us to do so.  Further, you may submit a written statement disagreeing with the denial and we will keep it on file and distribute it (or a summary) with all future disclosures of the information to which it relates.

Right to an Accounting of Disclosures.   You may request in writing an "accounting of disclosures."  This is a list of our disclosures of your PHI, with exceptions.  These exceptions include:

• To you or to persons involved in your health care or payment for that care. 
• Pursuant to your written authorization. 
• For the purpose of carrying out treatment, payment or health care operations.
• That are incidental to another permissible use or disclosure.
• For disaster relief, national security or intelligence purposes.
• To correctional institutions or law enforcement officers who have you in custody at the time of the disclosure.
• As part of a limited data set.
• To a health oversight agency or law enforcement official if they so request.
• Or that occurred before April 14, 2003.

The accounting will include the date of each disclosure, the name of the entity or person to whom the disclosure was made and that person's address (if known), and a brief description of the information disclosed together with the purpose of the disclosure.

Your request for an accounting must state a time period that may not be longer than six years and may not include dates before April 14, 2003.  We will generally act on your request within 60 days.  The first list you request within a 12-month period will be free.  For additional lists, we may charge you for the costs of providing the accounting.  We will notify you of the cost involved, and you may choose to withdraw or modify your request at that time before any costs are incurred.

Right to Request Restrictions.  You have the right to request a restriction or limitation on the PHI we use or disclose about you for treatment, payment, or health care operations.  You also have the right to request a limit on the PHI we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend.

We are not required to agree to your request.   If we do agree, a restriction may later be terminated by your written request, by agreement between you and us (including an oral agreement), or unilaterally by RealLife HR for PHI created or received after you are notified that the restriction has been removed.  RealLife HR may also disclose PHI about you if you need emergency treatment, even if RealLife HR has agreed to a restriction. 

In your written request, you must tell us:

• What information you want to limit.
• Whether you want to limit our use, disclosure, or both.
• And to whom you want the limits to apply.

Right to Confidential Communications.   You have the right to file a written request to receive communications from us regarding PHI on a confidential basis by using an alternative means for receipt of information or by receiving the information at an alternative location, but only if you believe and state that the disclosure of all or part of your information could endanger you.  All reasonable requests will be granted.

Section IV.
Disclosure and Sharing of non-PHI

RealLife HR will not distribute, sell, rent or otherwise disclose your non-PHI to any third party except as follows:

• to business partners, suppliers and other third parties that help us to provide certain services to you and to process payments;
• in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with RealLife HR's rights or property, or anyone else that could be harmed by such activities;
• in special circumstances, such as the sale or potential sale of RealLife HR or part of its business or the bankruptcy of RealLife HR;
• when we believe in good faith that it is required or permitted by law; and
• when you have consented to such disclosure.

Section V.
Opting Out and Other Rights With Respect to non-PHI

To keep you in control of your non-PHI and the communications directed to you, we allow you to edit your marketing preferences and/or to opt out of receiving communications from RealLife HR.  You may opt-out of receiving certain communications from RealLife HR by selecting the opt-out feature when it is made available to you by us, including, but not limited to, in e-mail correspondence sent to you by us.  RealLife HR reserves the right to send you certain communications relating to our Web site that are considered part of your account, such as technical alerts, without offering you the opportunity to opt out of receiving them.

Section VI.
Right to a Paper Copy of this Notice

You have the right to a paper copy of this Notice.  You can request in writing a paper copy from the HIPAA Privacy Officer.

Section VII.
Right to File Complaints

You may also file a complaint with us, or in the case of PHI, with the Secretary of the Department of Health and Human Services if you believe your privacy rights have been violated.  You may submit your complaint to us by either writing to the HIPAA Privacy Officer or calling the HIPAA Privacy Officer.  You will not be retaliated against for exercising any right or process described in this Notice, including the filing of a complaint or testifying, assisting, or participating in an investigation, compliance review, or hearing.

Section VIII.
Policies for Children Under 13

No information should be submitted to us by children under 13 years of age without the consent of their parent or guardian.  RealLife HR does not disclose information about children less than 13 years of age except as necessary to complete authorized transactions.

Section IX.
Security

RealLife HR takes the responsibility of protecting your personal identifiable information very seriously.  In addition to physical and technological safeguards, RealLife HR has adopted administrative policies and procedures that require our employees, partners and other persons and entities to treat your personal identifiable information as private.  We limit access to your personal information to those who have a need to know to perform their jobs.

Section X.
Use of Cookies

Cookies are data text files that a Web site transfers to a visitor's computer for record-keeping purposes.  Cookies allow Web site operators like RealLife HR to facilitate and customize your visit by saving your preferences while tracking information about your visit to a Web site.   We use the data collected by cookies to retrieve certain information previously provided by you and to help us provide our visitors with a better experience at our Web site.  Many improvements and updates to our Web site are based on the data collected by cookies.  Information that we track with cookies includes, without limitation, the total number of visitors and pages viewed, the number of sweepstakes entries, and which areas of our Web site you visited.  Some of our advertisers, partners and sponsors may use cookies to track your movement between web pages.   Although most browsers are initially set up to accept cookies, you can reset your browser preferences to indicate when a cookie is being sent or to refuse all cookies.  However, note that if you refuse cookies, you may have difficulty accessing cookie-enabled services available at our Web site.  The Help section of your browser will instruct you on how to prevent your browser from accepting cookies.

Section XI.
Changes to Our Privacy Policy

We are required by HIPAA to maintain the privacy of your PHI.  However, RealLife HR has always been committed to protecting the privacy of your personal information, whether relating to health or otherwise.  RealLife HR's policies and procedures relating to privacy and information security have been designed to support this commitment by providing effective safeguards and ensuring adherence.

We are required to, and will, abide by the provisions of this Notice as currently in effect, but reserve the right to revise and change our policies and procedures, as well as this Notice, effective for PHI and non-PHI we already have as well as any information we receive in the future.  We will post a copy of the current Notice on the Web site.  This Notice contains, on the first page, in the top right-hand corner, its effective date.

Section XII.
Questions

If you have any questions regarding this Notice, please feel free to call the HIPAA Privacy Officer at 410-403-5500 or write the HIPAA Privacy Officer, in care of Human Resources, Member Services, 10150 York Road, Hunt Valley, Maryland 21030.