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IBC Website Privacy Policy

Welcome to an Independence Blue Cross (“IBC”) Website. Our publicly-accessible Websites are designed to make it easier for visitors to learn about the services, programs and products provided by Independence Blue Cross and its subsidiaries. If you are currently a member who has IBC coverage, or a provider, broker, or group that does business with IBC, you also may choose to register for one of our web portals if applicable. A web “portal” is a Website that allows two-way interaction and can collect information from the visitor. After registration, these portals allow you to access information about certain benefits or programs, claims information, or health information. In addition, certain individuals eligible for special health programs may be able to register to access the consumer web portal. As with all online resources, we appreciate that visitors to our Websites are concerned about the privacy of personal information. This Privacy Policy discloses IBC’s policy for collecting, using and disseminating information through its Websites and Web portals.

Please note that this Privacy Policy is distinct from IBC’s Notice of Privacy Practices (“the IBC Notice”), which describes how IBC uses individually identifiable health information collected by IBC – both online and offline – to provide services to you and to administer the various programs that IBC administers. IBC publishes the IBC Notice in accordance with the federal privacy law known as “the HIPAA Privacy Rule.” Together, this Privacy Policy and the IBC Notice describe how IBC uses your individually identifiable health information and personal information collected through this Website. Information you provide to IBC in an offline setting is covered by the IBC Notice, but is not covered by this Privacy Policy.

1. Collection of Personal Information from Site Visitors.

When you visit www.ibx.com, or one of our other Websites, IBC may collect and/or track: (1) your home server domain names, your email address, your type of computer, the files downloaded, the search engine used, operating system, and type of web browser; (2) the email addresses of visitors who communicate with IBC via email; (3) information knowingly provided by the visitor in online forms, surveys, email, contest entries, and other online submissions (including demographic and personal profile data), and (4) aggregate information on pages accessed by a visitor.

To better serve you, we use "cookies" to customize your browsing experience. Cookies are simple text files stored by your browser and they provide a method of distinguishing among visitors to our sites. We use "cookies" to store a randomly generated tag on your computer such that when you revisit our sites, we may recognize the visitor by the Internet cookie and customize the visitor’s experience accordingly. The cookies created on your computer by using our sites do not contain personally identifiable information. You may refuse a cookie, or delete the cookies file from your computer at any time by using any one of a number of widely available methods. However, you should be aware that if you disable the "cookies" feature of your browser, you may not be able to use the portals within our site.

When a visitor performs a search on our Website, we may record information identifying the Visitor or linking the visitor to the search performed. IBC also may record limited information for every search request and use that information only to solve technical problems with the service and to calculate overall usage statistics.

2. Use of Online Personal Data Collected Through the Website.

When you access the Website, online personal information is collected about you. "Online personal information" is any information or data you provide through this Website that is individually identifiable, such as a name, address, postal address, email address, birth date, phone number, and other personal information, including health information that you voluntarily provide to IBC. It also may include other information that we collect about you that is associated with your name or address, such as your email address. You may provide that information to us on our registration page, or at some other point during your online interaction.

IBC may use the online personal information for a number of different reasons, including editorial and feedback purposes, health care marketing and promotions, performing a statistical analysis of visitor usage, product development, content improvement, or to customize the content and layout of our site. Aggregate data that does not identify individual users may be used for internal purposes or provided to third parties.

Personally identifiable information that visitors voluntarily provide to IBC may be added to our databases and used for future communications, which may include Website updates, new products and services, the confirmation of transactions through the portals, upcoming events, or health reminders, and for other purposes in accordance with applicable state and federal law.

Online personal information may or may not be individually identifiable health information that is also protected by the federal HIPAA privacy law (“the HIPAA Privacy Rule”). Where online personal information also constitutes individually identifiable health information and is considered “protected health information” or “PHI”) under the HIPAA Privacy Rule the provisions of this Privacy Rule also will govern IBC’s permitted uses and disclosures of the online personal information.

3. Disclosure of Online Personal Data to Third Parties.

Unless otherwise authorized by a visitor, IBC will not sell, rent, license, or disclose personally identifiable information to unaffiliated third parties. Under the HIPAA Privacy Rule, however, IBC is permitted to disclose individually identifiable health information to business associates who perform various functions or provide services on their behalf. To perform these functions or to provide services, business associates will receive, create, maintain, use, or disclose protected health information, but only after we require the business associates to agree in writing to contract terms designed to safeguard your information. IBC has contracted with certain third party vendors such as WebMD to serve as its business associate to provide services in connection with IBC’s Web portals.

IBC will not release personally identifiable information to any party unless required to do so by government authorities or legal process in accordance with applicable law. Laws that permit disclosure of your personally identifiable information as part of healthcare operations might include activities such as Wellness Programs.

4. Wellness Programs and Health Support Programs.

Wellness and health support programs (such as but not limited to Healthy LifestylesSM, ConnectionsSM Programs for chronic conditions, Healthy LifestylesSM Rewards Program) are intended to help members to improve their overall health. They are not intended to replace professional medical advice. Information on member participation in these programs may be used by IBC for aggregate reporting and outreach purposes.

When appropriate, IBC may share protected health information or PHI with third party vendors with which IBC has a contract to administer benefits or provide health support services as IBC’s business associates. Such vendors are required to sign a contract with IBC to maintain the privacy of protected health information as required by law. IBC also may share information with treating providers to improve the health care of members. Providers also must follow all legal confidentiality requirements for PHI.

In addition, when appropriate, we may confirm your enrollment in these programs or in certain preventive health activities, but not your individual responses or final results, with your employer or health and welfare fund (“fund”), for the purpose of an incentive program or corporate wellness planning. For example, we may inform your employer or fund that you completed a “Health Risk Assessment or Personal Health Profile” but will not disclose your answers. We may inform your employer or fund that you attended 10 sessions of a weight management program but not disclose whether you lost any weight. Your individual responses also will not be shared with your employer or fund or their broker/consultant.

5. Links from Independence Blue Cross Websites to Other Websites.

IBC Websites occasionally include links to other organizations’ websites for your convenience in locating health-related information, services, and products. Please be advised that when you link to these other sites, you are leaving IBC’s Website and that these other sites are maintained by organizations over which IBC may have no control.

Accordingly, a link on any of these sites does not constitute endorsement of the content, viewpoint, policies, products, or services provided or advertised on that site. These other third party sites may have their own terms and conditions and privacy policies or no policy at all. Once you link to a website not maintained by IBC, you are subject to any terms and conditions of that site, including, but not limited to any privacy policy. The IBC Privacy Policy and the Terms and Conditions of Access do not apply to the sites of such other third parties. IBC does not guarantee that you will receive an alert that you are leaving an IBC Website and linking to other third party websites. It is your responsibility to determine when you have left an IBC Website.

Certain products, services or treatments referred to on other sites that have a link on our site, may not be covered under certain plans offered by IBC. Members should refer to their benefits contract for complete details of the terms, limitations, and exclusions of coverage. In addition, certain providers may not be network providers. Please refer to our provider directory or call IBC to make certain the professional listed is a network provider.

Certain health information and tools accessible to registered members on the member web portal may be provided in combination with third party vendors from which IBC licenses or purchases services. IBC may customize these tools to serve IBC members with IBC plan coverage. An example of this is the portion of our member website supported by the company WebMD, which is a business associate of IBC (and, therefore, is bound by the use and disclosure restrictions of the HIPAA Privacy Rule for information that constitutes PHI). A partial list of these services provided by WebMD includes the Provider Finder, Hospital Comparison Tool, Personal Health Record, and Personal Health Profile. The WebMD sections of the Website have an additional Privacy Policy that governs the collection, use and disclosure of any PHI provided to WebMD through its website. A visitor can tell they are on a WebMD-supported tool because the bottom of the webpage will be labeled “Powered by WebMD”.

6. Security Measures.

IBC has implemented numerous security features to prevent the unauthorized release of or access to personal information. For example, all IBC employees are required to certify their understanding that personal information is considered confidential, that it is important to safeguard personal information, and that IBC will take appropriate action against any employee who fails to acknowledge these facts or adhere to the requisite security standards of conduct.

The IBC web portals use 128-bit encryption to help keep information secure. You will not be able to view certain pages of our site unless your computer has 128-bit encryption. You should also be aware that despite these and other security measures implemented by IBC, no security process is completely foolproof. We will continually assess our security procedures and modify them to protect your information and we ask that our visitors take the appropriate measures to protect their information.

If you register for one of our Web Portals, you will have the opportunity to receive or create a password to access view or submit personal information. Visitors who register to use a Web Portal should not divulge their password to anyone, and IBC will never ask for your password in an unsolicited phone call or email. When you are finished with applications that are password-protected, you should exit the page.

You should be aware that the confidentiality of any communication or material transmitted to/from IBC via this site or email cannot be guaranteed. IBC is not responsible for the security of information transmitted via the Internet. Visitors who prefer to communicate with IBC in another manner other than through our site can write to us via regular mail at: Independence Blue Cross, Electronic Communications – 38th Floor, 1901 Market Street, Philadelphia, PA 19103-1480. If you prefer email, you can write to us at ibc.eCorrespondence@ibx.com.

7. Opt-Out Right.

Visitors may opt out of having certain personally identifiable information, i.e. PHI, used by IBC or its affiliates for health-related marketing or other health-related promotional communications by contacting IBC via regular mail or email at the addresses above. This opt-out right does not apply to IBC’s collection of the type of web browser of visitor to IBC’s site or the sharing of PHI permitted under the HIPAA Privacy Rule for treatment or health care operations as part of wellness and health support programs as described above.

In sections of the member website that are “powered by WebMD”, visitors may customize their preferences regarding receipt of e-mail health reminders and other electronic communications. This is done by accessing the “settings” tab.

8. Access to and Ability to Correct Online Personal Data.

Upon request via regular mail or email, IBC provides visitors a summary of any personally identifiable information retained by IBC regarding the visitor. You will also be able to see personal information retained by IBC through the Member Web Portal. Members may seek to modify, correct, change, or update information that IBC has collected by contacting us via regular mail or email at the addresses above. Some visitors may also be able to update their information via the member portal. Although you may provide individually identifiable health information on this Website, the information is not a medical record, and is not, under the HIPAA Privacy Rule, considered information we maintain in a designated record set. Such information, however, will be treated as PHI, as discussed in this Privacy Policy and in IBC’s Notice.

9. Collection of Online Personal Data From Children.

Although parents are free to seek information available on this Website concerning the health of their children, no person under 18 years old is permitted to use this Website. IBC does not direct this Website to children under the age of 18 years or knowingly collect personal information from children under 18. Adults should not assist minors in accessing the Site. When visitors enter personal information on our Website, the visitor is representing to us that he/she is an adult over 18 years old.

IBC does not direct this Website to children under the age of 18 years, or knowingly collect information from children under 18. To the extent that IBC is able to determine the age of visitors by their submissions to or communications with IBC’s site, IBC will not knowingly (1) collect or post information from individuals under age 18 without their parent’s or guardian’s consent, or (2) provide any personally identifying information collected from children, regardless of its source, to any third party for any purpose whatever unless otherwise permitted by law.

More specifically, if registration is required for any services on the IBC Website, and a visitor submits information to IBC’s Website through such a registration process that indicates that such visitor is a child, the child’s parent or guardian will be alerted to the child’s registration and will be provided instructions on how the parent or guardian can delete the child’s registration, if so desired. No information collected through IBC’s Website from visitors who identify themselves as children will knowingly be used for any direct marketing or promotional purposes. If there are no age restrictions on a contest that requires registration, and if a child wins, notification and prizes will be sent to the parents or guardians identified in the initial registration process.

10. Independence Blue Cross’s Right to Contact Visitor.

IBC reserves the right to contact Website visitors regarding account status and changes to the member handbook, the Privacy Policy, or any other policies or agreements relevant to those who visit the Website.

11. Independence Blue Cross’s Right to Change Privacy Policy.

IBC reserves the right to change this Privacy Policy at any time. Consequently, you should refer back to this Privacy Policy regularly as it might be amended from time to time.