Compliance: What do I do if there is a PII breach?

Consumers provide their Personally Identifiable Information (PII) to the Exchange for the purpose of determining eligibility in a qualified health plan and/or determining eligibility for other insurance affordability programs, such as Cost Sharing Reductions, Advance Premium Tax Credits, Medicaid and MCHP.

Personally Identifiable Information is defined as “Any information which can be used to distinguish or trace an individual’s identity, such as their name, social security number, biometric records, etc., alone, or when combined with other personal or identifying information which is linked or linkable to a specific individual, such as date and place of birth, mother’s maiden name, etc.”

Consumers’ private information may not be published, sold, shared through social media, discussed in public places or otherwise disseminated. Such behavior is unethical and may be illegal. It could lead to loss of employment and potentially significant legal consequences.

If you suspect an individual’s PII may have been leaked, you must report it within one hour of obtaining this knowledge to MHBE’s Compliance Officer, Cat Pangilinan.

Reportable incidents can include but are not limited to:

  • A consumer calls to report another consumer’s identification documents were uploaded into their application.
  • A consumer assistance worker sends an un-encrypted email to another worker containing PII.
  • Documents containing PII are left on a table during an enrollment event instead of being secured after the consumer was assisted.

To report an incident, please download the MHBE Incident Report Form and email it using a secure email service to caterina.pangilinan@maryland.gov with cc to eliot.burkom@maryland.gov.

Protecting consumers information is not just the responsibility of the Compliance team at MHBE, but a Cultural Value that should be shared by all. Let’s work together and focus on “Doing the right thing, all of the time!”

Questions:  Contact the MHBE Compliance Hotline at 410-547-6862.

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