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HIPAA - PROTECTION OF PERSONAL INFORMATION

The Health Insurance Portability and Accountability Act (HIPAA) mandates that all “Protected
Health Information” (PHI) be kept secure and confidential. We follow the applicable guidelines

set forth in the Health Insurance Portability and Accountability Act of 1996 (HIPAA). In
addition, we expect our employees on assignment in positions with access to protected health
information to uphold these guidelines as well.

HOW WE PROTECT PERSONAL INFORMATION

We treat personal information securely and confidentially. We limit access to personal
information to only those persons who need to know that information to provide support
services to our employees. These individuals are trained on the importance of safeguarding this

information and must comply with procedures and applicable laws. We meet strict physical,
electronic and procedural security standards to protect personal information and maintain
internal procedures to promote the integrity and accuracy of the information. In addition, we
follow all of the guidelines established by our benefit carriers to insure the protections of data.

DISCLOSURE OF PERSONAL INFORMATION

We may share any of the personal information we collect (as described above) with only those
necessary and as permitted by law. The information is not discussed or disseminated either
outside of the client site or with anyone on the client site that has no involvement with the

individual. Examples of those that we may have to share information with include: health and
dental care carriers, health and dental care providers, your authorized representatives, third
party administrators such as our workers’ compensation carrier, and our disclosures order
related to a court subpoena.

HOW TO CONTACT US

If you have questions or need additional information regarding this policy or any privacy related

procedure, please contact the Human Resource Service Team. If you have a complaint
regarding privacy, please immediately contact the Privacy Officer of Checks and Balances, Inc.

ETHICS AND CONFIDENTIALITY AND PROTECTION OF PROPRIETARY
INFORMATION

We expect all employees to act honestly and deal fairly in all business relationships. We
endeavor to maintain legal and ethical compliance with all laws and expect employees to
conduct themselves in a manner consistent with this policy.

Checks and Balances, Inc. 23 1/2017

Disclaimer: This Handbook contains internal confidential propriety information. The policies can change at any time, for any
reason, without warning.