OnlineNavigator's role is to provide health plan enrollment advice through a consultative process in relation to an individual's overall personal financial planning considerations. This service normally requires the collection, retention and distribution of private information as part of our regular business procedures. The term "private information" used here in a generic sense is meant to incorporate the terms "private personal information", "protected health information" and "personal financial information" as defined and controlled under various privacy laws. This privacy statement expands and explains the treatment of each of these items as it affects your privacy at OnlineNavigator.
Private personal information is defined by the federal government as the combination of an individual's name with at least one of the following: 1) social security number, 2) credit card information or 3) financial account information. State laws may use a similar or slightly different definition. We do not normally have access to credit card information, financial account information, or the user's social security number. Private personal information, if available to us, is used only to provide the specified service and then treated in the same manner as all other electronic data and communications as described below.
Protected health information - Health information privacy is primarily controlled by a federal law know as HIPAA that defines and controls the handling of "protected health information". OnlineNavigator is not a covered entity as defined by HIPAA as determined by guidance published by the Centers for Medicare and Medicaid Services. Private health information that is not controlled by HIPAA is protected in the same manner as other private information. OnlineNavigator does not handle, and is not equipped to handle, personal health information as regulated under HIPAA except for the specific purpose of providing advice as described.
Personal financial information - Financial information is controlled by various state and federal authorities as well as industry self-regulatory groups. Our primary governing body on the handling of private financial information is the American Institute of Certified Public Accountants. Additional information is available in this article titled "Code of professional conduct for a Certified Public Accountant acting as navigator".
Business financial information - Businesses typically need to reveal financial information to a navigator and an insurance company in order to determine eligibility for coverage of its employees and determination of tax subsidies for the employer. Our primary governing body on the handling of private financial information is the American Institute of Certified Public Accountants. Additional information is available in this article titled "Code of professional conduct for a Certified Public Accountant acting as navigator".
Data security and management - OnlineNavigator uses secure data management services for the handling of all private information. While the risk of data security cannot ever be entirely eliminated, we believe that these secure cloud-based data services provide the highest level of protection commercially and practically available to protect your private information.
Our internal control of data security meets or exceeds the industry standards of the financial advisory industry, specifically those addressed by the AICPA TTI II statement in 2011. We do not meet the HIPAA data security standards required of health care providers, accountable care organizations or health insurance companies.
Privacy concerns - If you have any questions or concerns about privacy issues at OnlineNavigator.org please contact our privacy officer Tony Novak.