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Notice of Privacy Practices - Full


Your Protected Health Information (PHI)

PHI stands for the words Protected Health Information. PHI is health information that includes your name, member ID number or other items that can be used to identify you.

Important Information About Privacy

Protecting the privacy of your personal and health information is important to the ROSEBUD program. We are required by law to maintain the privacy of your information and to provide you with notice of our legal duties and privacy practices. That is what this notice is for. It explains how we use information about you and when we can share that information with others. It also tells you about your rights with respect to your personal health information and how you can use your rights. We are required to stand by the terms of this notice. If your information is subject to a breach (if it is used by or shared with someone who is not authorized to use or have your information), we are required to notify you in writing.

When we use the term “PHI” or “information” in this notice, we are referring to the personal and health information about you that we collect when you fill out forms or when you obtain our services. We keep this information and use it to provide services to you and to operate ROSEBUD.

When we use the term “ROSEBUD”, “we” or “us” in this notice, we are referring to the ROSEBUD Program, which is operated by RGA Reinsurance Company.

How We Protect Your PHI

We protect your PHI whether it is written, spoken or electronic form by requiring employees and others who handle your information to follow specific confidentiality and technology usage policies. When they begin working for ROSEBUD, all employees and contractors must sign that they have reviewed ROSEBUD policies and that they will protect PHI even after they leave ROSEBUD. An employee or contractor’s use of protected information is limited to the minimum amount of information necessary to perform a legitimate job function. Employees and contractors also are required to comply with this privacy notice and may not use or disclose your information except as described in this notice.

We expect all our Providers will also safeguard your PHI and follow our policies and procedures for the use and disclosure of your PHI.

Using and Disclosing PHI

The following sections describe how ROSEBUD uses your information. We share your information only with those who have a “need to know” in order to perform the tasks listed below:


We may share your PHI with doctors, hospitals or other providers to help them provide medical care to you. For example, if you are in the hospital, we may give them access to any medical records sent to us by your doctor. We may use or share your PHI with others to help manage your health care. For example, we might talk to your doctor to suggest a disease management or wellness program that could help improve your health.


We share your PHI with affiliated companies as permitted by law, non-affiliated third parties with whom we contract to help us operate ROSEBUD and with others who are involved in providing or paying for health care services for you. We may share your information with others who help us conduct our business operations. If we do so, we will require these persons or entities to protect the privacy and security of your information and to return or destroy such information when it is no longer needed for our business operations.

Other Uses and Disclosures that are Permitted or Required

ROSEBUD may also use or release your health information:

  • For certain types of public health or disaster relief efforts.
  • To give you information about alternative medical treatments and programs or about health-related products and services that you may be interested in. For example, we might send you information about smoking cessation or weight loss programs.
  • To give you reminders relating to your health such as a reminder to refill your prescription(s) or to schedule recommended health screenings.
  • To report information to state and federal agencies that regulate us, such as the U.S. Department of Health and Human Services and the U.S. Department of Financial and Insurance Services.
  • When needed by the employer/plan sponsor to administer your health benefit plan.
  • For certain FDA investigations such as investigations of harmful events or product defects or for product recalls.
  • For public health activities if we believe there is a serious health or safety threat.
  • For health oversight activities authorized by law.
  • For court proceedings and law enforcement purposes.
  • To a government authority regarding abuse, neglect or domestic violence.
  • To comply with workers’ compensation laws.
  • When permitted to be released to government agencies for the protection of the U.S. President.

If one of the above reasons does not apply, we must get your written permission to use or disclose your PHI. We must get your written permission to share your information for marketing purposes or to sell your information. If you give us written permission and change your mind you may cancel your written permission at any time. Cancellation of your permission will not apply to any information we have already disclosed. We may ask you to complete a form when making a request. Once you give us authorization to release your PHI, we cannot guarantee that the person to whom the information is provided will not disclose the information.

Other Uses or Health Information

We may release your PHI to a friend, family member or other individuals who are authorized by law to act on your behalf. For example, parents may obtain information about their children covered by ROSEBUD, even if the parent is not covered by ROSEBUD.

We may use or share your information with an employee benefit plan through which you receive health benefits. Except for enrollment information or summary health information and as otherwise required by law, we will not share your information with an employer or plan sponsor unless the employer or plan sponsor has provided us with written assurances that the information will be kept confidential and will not be used for an improper purpose. Generally, information will only be shared when needed by the employer/plan sponsor to administer your health benefit plan.

We may use your information so that we can contact you, either by phone or by mail, in order to conduct surveys, such as the annual member satisfaction survey.

In certain extraordinary circumstances, such as a medical emergency, we may release your information as necessary to a friend or family member who is involved in your care, if we determine that the release of information is in your best interest. For example, if you have a medical emergency in a foreign country and are unable to contact us directly, we may speak with a friend or family member who is acting on your behalf.

Changes to this Privacy Statement

We may from time-to-time change the contents of this notice and reserve the right to do so. If we do so the new notice will be effective for all the PHI maintained by us. Once revised, we will post the new notice on our website.

Who to Contact

If you have any questions about this notice or about how we use or share your PHI, you may contact the ROSEBUD Program at:

Attn: Privacy Officer
100 Washington Ave. S., Suite 1400
Minneapolis, MN 55401

You may also contact us at 1-800-535-7673.


If you believe your privacy rights have been violated, you may file a complaint with us by contacting the Privacy Officer as noted above. You may also notify the Secretary of the U.S. Department of Health and Human Services of your complaint. We will not take any action against you for filing a complaint.

Using the Internet-the Choice if Yours

Using the Internet to communicate with ROSEBUD is completely voluntary. You should read this statement to understand the benefits and risks of communicating over the Internet. If you do not choose to communicate with us over the Internet by sending us an email, you browse our website anonymously.

Internet Privacy Statement

We do not collect any information that can be used to personally identify you unless you send an email to us.

Information We Collect When You Communicate With Us over the Internet

When ROSEBUD implements our member portal, we are committed to protecting the privacy of the personal information you provide to us over the Internet. All information is protected by our privacy policies, which we periodically review and update.

If you choose to communicate with us over the Internet, we may request personally identifiable information from you necessary for us to process your request for information, respond to our questions or deliver a product or service. Personally identifiable information is any information that can be used to identify you, such as your name, address or web address. When you send information to us using email, the information may be shared with our employees and contractors who need to know the information to respond to your request and as permitted by law. We keep some of this information for a period of time determined necessary by us.

Using Email

There are a number of risks you should consider before using email to communicate with us: email can be circulated, forwarded and stored in numerous paper and electronic files; email can be intercepted, altered, forwarded or used without authorization or detection; email senders can easily misaddress an email; backup copies of email may exist even after the sender deletes the email; employers and online services have the right to inspect email transmitted through their systems; email is easier to falsify than handwritten or signed documents; and email can be used to introduce viruses into computer systems. Confidentiality of Internet communications cannot be guaranteed by ROSEBUD. Use of the Internet is solely at your own risk.

Links to Other Websites

We have links from our website to a number of different health care related websites. When you click on one of these links, you leave and link to another website not controlled by ROSEBUD. We do not control the privacy policies or security measures of any of these health care related sites. You should read the privacy statements on the other sites you visit to understand their privacy practices.


ROSEBUD has taken steps to make all information received from our online visitors as secure as possible against unauthorized access and use. All information is protected by our security measures, which we periodically review and update.

We use security technology to protect you during your Internet communications with us. This security includes server authentication, privacy using encryption and data integrity. Your personal information is protected from unauthorized access by a secure firewall and security infrastructure. We employ extensive physical, electronic and procedural safeguards to maintain the security of your information. ROSEBUD also conducts periodic reviews of its web security to ensure that our electronic security safeguards remain up-to-date and effective.

Here’s What You Can Do to Protect Your Internet Communications

There are things you can do to improve the privacy and security of your Internet communications.

Here are a few of them:

  • Do not submit sensitive or confidential information over email links on this website. Instead, contact us by telephone or mail.
  • Do not send sensitive or confidential information to us over the Internet from work. Your employer has the right to inspect your email, co-workers may see the information on a computer screen and you can inadvertently forward the email to co-workers or others.
  • After you submit information online, end your browser session before leaving your computer. This helps preserve the confidentiality of your data by ensuring that you are not leaving personally identifiable information on the computer for those who use the computer after you. This is especially information if you are using a computer in a public area.
  • If you communicate with us over the Internet, tell us when your @Html.ActionLink("email address changes", "Contact" null, new { @class="td-u"}).

Changes to This Statement

We periodically review and update our privacy policies and security measures. When we do so we may need to change or update this statement and reserve the right to do so. All updates and changes automatically apply to you without notice.

If you do not believe that the policies in this Internet Privacy Statement give you the Internet privacy and security protection you need, you have the ability and right to stop interacting with ROSEBUD over the Internet by exiting this website now.

Privacy Statement about our Website

This privacy statement demonstrates the ROSEBUD commitment to your right to privacy and explains the privacy policy governing If our privacy policy changes, we will post the change on the website.

Information collection, disclosure, and use:

When you access the website, you are not required to register or provide any personal information. As a result, we do not sell, lease or provide personally identifiable information to third parties because we do not collect that information.

Minors: We do not direct any of our content specifically at minors.

We have links from our website to a number of different health care related sites. We provide these links to help you find information. We are not responsible for the performance or content of sites linked from since they are beyond our control. We ask that you read the privacy statement on these sites you visit to understand their privacy practices.