CIGNA International Expatriate Benefits*

This Notice is Effective as of April 14, 2003

As required by the Privacy Regulations Promulgated Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

This Notice Describes How Health Information About You May Be Used And Disclosed And How You Can Get Access To This Information

Please Review It Carefully

Our Commitment to Your Privacy
CIGNA* is dedicated to maintaining the privacy of your individually identifiable health information. In conducting our business, we will create and maintain certain records regarding you and the services we provide to you. We are required by law to maintain the confidentiality of health information that identifies you. We also are required by law to provide you with this notice of our legal duties and privacy practices concerning your identifiable health information. By law, we must follow the terms of the notice of privacy practices that we have in effect at the time.

To summarize, this notice provides you with the following important information:

• how we may use and disclose your individually identifiable health information;
• your privacy rights regarding your individually identifiable health information; and

The terms of this notice apply to all records containing your individually identifiable health information that are created and/or retained by our organization. We reserve the right to revise or amend our notice of privacy practices. Any revision or amendment to this notice will be effective for all your records that our organization has created and/or maintained in the past, and for any of your records that we may create and/or maintain in the future. You may request a copy of our most current notice at any time by sending a written request to Privacy Office, 590 Naamans Road, Claymont, DE 19703 and/or return to this Web page.

Law Applicable to the United States HIPAA is a United States Federal law that generally applies to health plans, healthcare clearing houses, and health care providers ("Covered Entities") and governs how these Covered Entities use and disclose certain information.

If you have any questions about this notice, please contact:

Privacy Office
CIGNA International Expatriate Benefits
590 Naamans Road
Claymont, DE 19703
Telephone Number: 302.797.3100 or 1.800.441.2668

What is Individually identifiable Health Information (Confidential Information)?
CIGNA* receives health information that is needed to provide health benefits, administer your health plan and conduct general insurance business. You provide us with this information when you apply for coverage or submit a claim. Additional information is received from your health care providers, your employer, and vendors acting on behalf of your employer. CIGNA International Expatriate Benefits is required by law to protect the privacy of your individually identifiable health information (confidential information) and to provide you with this Notice of Privacy Practices.

We May Use and Disclose Your Health Information in the Following Ways?
The following categories describe the different ways in which we may use and disclose your individually identifiable health information:

• Treatment

CIGNA* may use and/or disclose your individually identifiable health information to doctors, dentists, pharmacies, hospitals and other health care providers for treatment purposes. For example, your provider may ask you to undergo laboratory tests such as blood or urine tests and use the results to help reach a diagnosis. Many of the people who work for your provider may use or disclose your individually identifiable health information in order to treat you and/or to assist others in your treatment. Additionally, we may disclose your individually identifiable health information to others who may assist in your care, such as your therapist, spouse, children, or parents.

• Payment

CIGNA* may use and/or disclose your individually identifiable health information in order to pay for the services and items you may receive. For example, we may contact your health provider to certify that you received treatment and for what range of benefits, and we may request details regarding your treatment to determine if your benefits will cover, or pay for, your treatment. We may also use and disclose your individually identifiable health information to obtain payment from third parties that may be responsible for such costs, such as family members.

• Health Care Operations

CIGNA* may use and/or disclose your individually identifiable health information to operate our business. For example, our claims administrator may use your health information to evaluate the quality of care you received from your provider, or to conduct cost-management and business planning activities for our organization.

• Plan Sponsors

CIGNA* may use and/or disclose individually identifiable health information to a plan sponsor for plan administration functions performed by the plan sponsor on behalf of the Health Plan. The Health Plan may also provide summary health information to the plan sponsor so that the plan sponsor may solicit premium bids from other health plans or modify, amend or terminate the plan.

• Vendors

CIGNA* may disclose your individually identifiable health information to companies with whom we contract to perform services on our behalf.

• Disclosures to Other Covered Entities

CIGNA* may disclose individually identifiable health information to other covered entities, or business associates of those entities for treatment, payment and certain health care operations purposes. For example, we may disclose individually identifiable health information to other health plans maintained by your employer if it has been arranged for us to do so in order to have certain expenses reimbursed.

• Marketing Information

If CIGNA* meets with you in person, we may use and disclose your individually identifiable health information to encourage you to purchase or use a product or service that is not part of the health benefits we provide. In addition, we may use and disclose your individually identifiable health information to provide you with a promotional gift of nominal value.

Use and Disclosure of Your Identifiable Health Information in Special Circumstances

Public Health Activities CIGNA* may use and/or disclose your individually identifiable health information to public health authorities that are authorized by law to collect information for the purpose of:

• maintaining vital records, such as births and deaths;
• reporting child abuse or neglect;
• preventing or controlling disease, injury or disability;
• notifying a person regarding potential exposure to a communicable disease;
• notifying a person regarding a potential risk for spreading or contracting a disease or condition;
• reporting reactions to drugs or problems with products or devices;
• notifying individuals if a product or device they may be using has been recalled;
• notifying appropriate government agency(ies) and authority(ies) regarding the potential abuse or neglect of an adult patient (including domestic violence); however, we will only disclose this information if the insured agrees or we are required or authorized by law to disclose this information; and
• notifying your employer under limited circumstances related primarily to workplace injury or illness or medical surveillance.

Health Oversight Activities CIGNA* may use and/or disclose your individually identifiable health information to a health oversight agency for activities authorized by law. Oversight activities can include, for example, investigations, inspections, audits, surveys, licensure and disciplinary actions; civil, administrative, and criminal procedures or actions; or other activities necessary for the government to monitor government programs, compliance with civil rights laws and the health care system in general.

Research CIGNA* may use and/or disclose your individually identifiable health information for research purposes, subject to strict legal restrictions.

Law Enforcement CIGNA* may use and/or disclose individually identifiable health information in certain law enforcement situations.

Lawsuits, Judicial and Administrative Proceedings CIGNA* may use and/or disclose your individually identifiable health information in response to a court or administrative order if you are involved in a lawsuit or similar proceeding.

Health or Safety CIGNA* may, consistent with applicable law and ethical standards of conduct, use and/or disclose your individually identifiable health information when necessary to reduce or prevent a serious threat to your health and safety or the health and safety of another individual or the public. Under these circumstances, we will only use/or make disclosures to a person or organization able to help prevent the threat.

Military or Specialized Government Functions CIGNA* may use and/or disclose your individually identifiable health information to appropriate military command authorities or the U.S. Department of State if you are a member and/or veteran of U.S. or foreign military forces.

Workers' Compensation CIGNA* may use and/or disclose your individually identifiable health information for Workers' Compensation and similar programs.

Right to Provide an Authorization for Other Uses and Disclosures

CIGNA* will obtain your written authorization for uses and/or disclosures that are not identified by this notice or permitted by applicable law. Any authorization you provide to us regarding the use and/or disclosure of your individually identifiable health information may be revoked at any time by providing us written notice at the address set forth in this notice. After you revoke your authorization, we will no longer use and/or disclose your individually identifiable health information for the reasons described in the authorization, except for the following circumstances:

• • We have taken action in reliance on your authorization before we received your written revocation;
  • You were required to give us your authorization as a condition of obtaining coverage; or
  • If state law gives us the right to contest a claim under your policy.

Note: We are required to retain records of your care.

Your Rights Regarding Your Individually Identifiable Health Information

You have the following rights regarding the individually identifiable health information that we maintain about you:

• You have the right to request that our office communicate with you about your health and related issues in a particular manner or at a certain location. For instance, you may ask that we contact you at home, rather than work. In order to request a type of confidential communication, please submit your request in writing to the address set forth in this notice. We will accommodate reasonable requests whenever feasible.
• You have the right to request a restriction in our use and/or disclosure of your individually identifiable health information for treatment, payment, or health care operations. While we will consider all requests for restrictions, we are not required to agree to your request. Please submit your written request to the address set forth in this notice and include the following:

• • the information you wish restricted;
  • whether you are requesting to limit our organization's use, disclosure or both;
  • to whom you want the limits to apply.

• You have the right to inspect and obtain a copy of the individually identifiable health information that may be used to make decisions about you, including medical records and billing records, but not including psychotherapy notes. You must submit your request in writing to the address set forth in this notice in order to inspect and/or obtain a copy or your identifiable health information. We may charge you a fee for copying and mailing costs.
• You may ask us to amend your individually identifiable health information if you believe it is incorrect or incomplete for as long as the information is kept by our organization. If we determine that the record is inaccurate or incomplete and the law permits us to amend it, we will correct the information that is affected. If your physician or other health care provider created the information that you desire to be changed, you should contact such physician/provider to request that the information be amended. You must submit your request in writing to the address set forth in this notice in order for us to amend your health information.
• All of our insureds have the right to request an "accounting of disclosures," which is a list of certain disclosures our organization has made of your individually identifiable health information, excluding, however, those disclosures made for treatment, payment or health care operations. All requests for "accounting of disclosures" must state a time period, which may not be longer than six years and may not include dates before April 14, 2003. If you request an accounting more than once during any 12-month period, we will charge you a reasonable fee for the subsequent accounting statements.
• You are entitled to receive a paper copy of our Notice of Privacy Practices. You may ask us to give you a copy of this notice at any time. To obtain a paper copy of this notice please contact the Privacy Office at the address set forth in this notice.

Right to File a Complaint
If you believe your privacy rights have been violated, you may file a complaint with our organization or with the Secretary of the United States Department of Health and Human Services. To file a complaint with our organization, please submit your concern(s) in writing to our Privacy Office at the address set forth in this notice. We will not penalize you if you choose to file a complaint directly with us or with the Secretary of the United States Department of Health and Human Services.

*CIGNA refers to CIGNA Corporation and/or one or more of its subsidiaries. CIGNA Corporation is a holding company and is not an insurance or an operating company. CIGNA International Expatriate Benefits ("CIEB") refers to various operating subsidiaries of CIGNA Corporation. Products and services are provided by these subsidiaries and not by CIGNA Corporation. Most employees are employed by such subsidiaries and not by CIGNA Corporation. CIGNA® is a registered servicemark of CIGNA Intellectual Property, Inc., licensed for use by CIGNA Corporation and its subsidiaries.