HomeMy WebLinkAboutBPW 02-01-17-03/McCready and Keene, Inc/6,000/Report of Retiree BenefitsRESOLUTION NO. BPW 02-01-17-03
RESOLUTION OF THE CITY OF CARMEL BOARD OF PUBLIC WORKS AND SAFETY
ACKNOWLEDGING RECEIPT OF CONTRACT
WHEREAS, pursuant to Indiana Code 36-1-4-7, the City of Carmel, Indiana ("City"), is authorized to
enter into contracts; and
WHEREAS, pursuant to Indiana Code 36-4-5-3, the City's mayor may enter into contracts on behalf of the
City; and
WHEREAS, pursuant to his authority under Indiana law, the City's mayor, the Honorable James C.
Brainard, has caused to be signed the City contract attached hereto as Exhibit A (the "Contract"); and
WHEREAS, Mayor Brainard now wishes to present the contract to the City's Board of Public Works and
Safety for it to be publicly acknowledged, filed in the Clerk -Treasurer's Office, and made available to the public for
review.
NOW, THEREFORE, BE IT RESOLVED by the City of Carmel Board of Public Works and Safety as
follows:
1. The foregoing Recitals are incorporated herein by this reference.
2. The receipt of the Contract is hereby acknowledged.
3. The Contract shall be promptly filed in the office of the Clerk -Treasurer and thereafter made available to
the public for review.
SO RESOLVED this day of , 2017.
CITY OF CARMEL, INDIANA
By and through its Board of Public Works and Safety
BY: _ _,7
Brainard, Presiding C
—/ e1 p
Mary A/n Burk Meber
Date: _ 7"
Lori S. Wf atson, Nnbe
Date: I
ATTEST:
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Christine auley> Cler reasu
Date: �/ �!�
S:\E Bass\My Documents\BPW-Resolutions\2017\Acknowledge McCready and Keene Inc. Agreement.docxl/24/2017 11:51 AM
SERVICE AGREEMENT OD
and
BUSINESS ASSOCIATE AGREEMENT
This Agreement is made and entered into effective the 1st day of January, 2017, between the
City of Carmel, Carmel, Indiana (hereinafter referred to as "Employer") and McCready and
Keene, Inc. (a OneAmerica Financial Partners, Inc. company), Indianapolis, Indiana
(hereinafter referred to as "McCready"), for report services with regard to Calculation Services (as
defined in Section 2.1(c) herein). This Agreement will also include disclosures under the Health
Insurance Portability and Accountability Act of 1996 and serve as a Business Associate Agreement
under that Act.
The parties hereto agree as follows:
1. Services by McCready
McCready expressly agrees that it shall review the benefit plans as they pertain to Calculation
Services and provide actuarial services in accordance with the Actuarial Standards of Practice, the
Actuarial Code of Professional Conduct, and the applicable accounting rules with regard to
Calculation Services. McCready will complete the necessary calculations and will then create an
actuarial valuation (hereinafter referred to as "Report") with regard to Employer's pension benefits
associated with both the City of Carmel Municipal Police Officers' Fund (not administered by
PERF) and the City of Carmel Municipal Firefighters' Fund (not administered by PERF).
The Report will review information regarding active and terminated participants who are
potentially eligible for these benefits and retirees currently receiving pension benefits from
Employer. The Report will include the required disclosure information and the annual expense
for each fiscal year as outlined in the Report. McCready's services will include the appropriate
review, calculations, a written Report, and one on-site visit to discuss the results of the Report.
2. HIPAA Compliance
The Health Insurance Portability and Accountability Act of 1996, Pub. L. No. 104-191
("HIPAA"), and its implementing regulations, the Standards for Privacy of Individually
Identifiable Health Information (the "Privacy Rule") and the Security Standards for Protection of
Electronic Health Information (the "Security Rule"), require McCready to protect the privacy
rights of persons covered under Plans for which Calculation Services are completed by McCready
for Employer (also referred to as "Covered Entity"). Under HIPAA, McCready is considered a
Business Associate of Covered Entity because it has undertaken to complete Calculation Services,
and HIPAA requires McCready and Covered Entity to enter into a Business Associate Agreement
in order to permit the appropriate exchange of Protected Health Information and Electronic Health
Information (collectively "PHI") between Covered Entity and McCready. McCready has also
adopted a Privacy Policy (a copy of which is attached) that reflects its privacy practices and
procedures.
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2.1 Definition's
The following definitions are included in this Agreement to comply with requirements of
the Privacy Rule and the Security Rule under HIPAA:
a. "Agreement" means this Agreement between McCready and Employer, on behalf of
the Covered Entity.
b. 'Business Associate" means McCready.
c. "Calculation Service" or "Calculation Services" means actuarial valuation services for
pension benefits (sometimes referred to as "FASB ASC 715-20, FAS 87/88, or GASB
67/68) with regard to employer liability and disclosure for these benefits.
d. "Covered Entity" means any health care plan of Employer for which Calculation
Services apply.
e. "Designated Record Set" means any item, collection or grouping of information that
includes PHI and is maintained, collected, used or disseminated by or for a Covered
Entity.
f. "Electronic Health Information" or "BPHI" means Protected Health Information that is
transmitted or maintained by or in electronic media, as defined by 45 CFR Section
160.103.
g. "HITECH" shall mean the Health Information Technology for Economic and Clinical
Health Act of 2009, as amended.
h. "Individual' means a person who is the subject of PHI and shall include a person who
qualifies as a personal representative in accordance with the Privacy Rule.
i. "Privacy Rule" means the Standards for Privacy of Individually Identifiable Health
Information at 45 CFR part 160 and part 164, subparts A and E, as amended or modified
by HITECH or other applicable laws or regulations.
j. "Protected Health Information" or "PHI" means all individually identifiable health
information transmitted or maintained by a Covered Entity. For purposes of this
Agreement, PHI is limited to information created or received by the Business Associate
from or on behalf of a Covered Entity for the purpose of completing Calculation
Services.
k. "Required By Law" means a mandate contained in law that compels a Covered Entity
to make a use or disclosure of PHI and that is enforceable in a court of law.
1. "Secre " means the Secretary of the U.S. Department of Health and Human Services
or his or her designee.
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in. "Securi , Rule" shall mean the Security Standards for Protecting Electronic Health
Information at 45 CFR parts 160 and 164, as amended or modified by HITECH or other
applicable laws or regulations.
Any definitions of terms used, but not otherwise defined in this Agreement, shall have the same
meaning as those terms in the Privacy Rule of HIPAA.
2.2 Obligations and Activities
a. McCready agrees to not use or disclose PHI or EPHI other than as permitted or required
by this Agreement or as Required By Law.
b. McCready agrees to use appropriate safeguards to prevent use or disclosure of the PHI
other than as provided for by this Agreement.
c. McCready agrees to mitigate, to the extent practicable, any harmful effect that is known
to McCready of a use or disclosure of PHI by McCready in violation of the
requirements of this Agreement, the Privacy Rule, or the Security Rule.
d. McCready agrees to report to Covered Entity any use or disclosure of PHI or EPHI not
provided for by this Agreement of which it becomes aware.
e. McCready agrees to ensure that any agent, including a subcontractor, to whom it
provides PHI received from or created or received by McCready on behalf of Employer
agrees to the same restrictions and conditions that apply through this Agreement to
McCready with respect to such information.
f. McCready agrees to provide access, at the request of Employer, to PHI in a Designated
Record Set to an Individual in order to meet the requirements under 45 CFR § 164.524
and in accordance with the Privacy Policy. McCready may charge a reasonable fee for
any information provided to the same extent as could be charged pursuant to 45 CFR
§ I64.524(c)(4).
g. McCready agrees to make any amendment(s) to PHI in a Designated Record Set if
requested pursuant to 45 CFR § 164.526 at the request of Employer, a Covered Entity,
or an Individual.
h. McCready agrees to make internal practices, books, and records, including policies,
procedures and PHI, relating to the use and disclosure of PHI received from, or created
or received by McCready on behalf of Employer available to the Secretary or his
designee for purposes of the Secretary determining compliance with the Privacy Rule
or the Security Rule.
i. McCready agrees to document such disclosures of PHI and information related to such
disclosures as would be required to respond to a request by an Individual for an
accounting of disclosures of PHI in accordance with 45 CFR §164.528.
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McCready agrees to provide to Employer, a Covered Entity, or to an Individual
information collected in accordance with the Agreement to permit McCready or
Employer to respond to a request by an Individual for an accounting of disclosures of
PHI in accordance with 45 CFR § 164.528.
2.3 Permitted Uses and Disclosures Except as otherwise limited in this Agreement:
a. McCready may use or disclose PHI to perform functions, activities, or services for or
on behalf of Employer, provided that such use or disclosure would not violate the
Privacy Rule if done by either party or would not exceed the minimum necessary
policies and procedures of HIPAA.
b. McCready may use PHI for its proper management and administration or to carry out
its legal responsibilities and disclose it for those purposes but only if the disclosures
are Required By Law or if McCready obtains reasonable assurances from the person to
whom the information is disclosed that it will remain confidential and used or further
disclosed only as Required By Law or for the purpose for which it was disclosed to the
person, and the person notifies McCready of any instances of which it is aware in which
the confidentiality of the information has been breached.
c. McCready may use PHI to provide Data Aggregation services as permitted by 45 CFR
§ 164.504(e)(2)(i)(B).
d. McCready may de -identify PHI that it receives from or on behalf of Employer or PHI
that it creates for Employer and use and disclose the de -identified data in any manner
permitted by law.
e. McCready may use or disclose PHI in any other manner permitted by law.
2.4 Obligations
a. McCready shall not use or disclose PHI except as permitted or required by this
Agreement or as Required by Law.
b. McCready will provide Employer with a copy of its Privacy Policy, including any
amendment thereto. McCready shall notify Employer of any limitation(s) in its privacy
practices in accordance with 45 CFR §164.520, to the extent that such limitation may
affect Employer use or disclosure of PHI.
c. Each party shall notify the other party of any -changes in, or revocation of, permission
by an Individual to use or disclose PHI, to the extent that such changes may affect the
use or disclosure of PHI by either party.
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d.. Each party shall notify the other of any restriction to the use or disclosure of PHI that
has been agreed to in accordance with 45 CFR §164.522, to the extent that such
restriction may affect the use or disclosure of PHI. If Employer agrees to any restriction
that materially increases McCready's cost of performing its Calculation Services (other
than a restriction required by 45 CFR § 164.522(b)(ii)), Employer shall pay an
additional fee, as needed, to defray the additional cost.
McCready represents and warrants that it and all of its officers, employees, agents,
contractors and subcontractors shall comply with all laws of the United States, the State
of Indiana and City prohibiting discrimination against any employee, applicant for
employment or other person in the provision of any Goods and Services provided by
this Agreement with respect to their hire, tenure, terms, conditions and privileges of
employment and any other matter related to their employment or subcontracting,
because of race, religion, color, sex, handicap, national origin, ancestry, age, disabled
veteran status and/or Vietnam era veteran status.
f. Pursuant to I.C. § 5-22-16.5, McCready shall certify that, in signing this document, it
does not engage in investment activities within the Country of Iran
2.5 Permissible Requests
a. Except as otherwise limited in this Agreement, McCready may use PHI to complete
Calculation Services required for Employer based on information provided by
Employer and/or the Covered Entity.
b. McCready shall not request to use or disclose PHI in any manner that would not be
permissible under the Privacy Rule or the Privacy Policy. However, this will not be
deemed to prevent McCready from using or disclosing PHI for Data Aggregation or
management to the extent required by this Agreement or administrative activities.
c. McCready shall not request Employer or a Covered Entity to disclose to it PHI in excess
of the minimum necessary to satisfy the need that underlies any such request.
3. Not an Agreement to Audit Data
This Agreement does not contemplate nor shall it provide a service designed to audit data, discover
errors, omissions, misrepresentations, fraud, illegal acts, or other misuses of assets. However,
McCready will inform Employer of such matters if they are observed.
4. Obligations of Emnlover
Employer expressly agrees that it shall perform the obligations set out in this Agreement, and shall
use its best efforts in completing its obligations timely, accurately, and professionally. Such
obligations may be amended from time to time upon the agreement of both parties.
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a. Employer agrees to furnish the data required by McCready to perform the contracted services
for the Report, and such data shall be delivered to the offices of McCready in the form
specified. The fees stated in this Agreement assume that data is transmitted to McCready
electronically in the format requested by McCready. Failure to provide data in such form will
result in higher fees based upon any additional time incurred for processing. All reports
generated by McCready will be based on the data provided by Employer.
b. Employer also authorizes McCready to contact the Plan's accountant, attorney, broker,
insurance agent, or other financial advisor, including any financial institution, as needed, for
information necessary to perform services. Employer will notify any individual or
organization holding information to provide such information to McCready if it is needed to
complete the Report. McCready shall assume all data provided to it is accurate as received
and bears no responsibility to verify the accuracy of such data or to audit such information.
5. Assignment
McCready may not assign this Agreement or its rights and responsibilities outside its mutual
insurance holding company (OneAmerica Financial Partners, Inc.) without prior written consent
from Employer, which shall not be unreasonably delayed or withheld. McCready reserves the
right to subcontract work covered by this agreement to affiliates within its mutual insurance
holding company or to subcontract work to a third -party health actuary. McCready will not request
prior written consent in connection with a name change, corporate reorganization, merger, or the
sale of substantially all of its business or assets. Any purported assignment or transfer in violation
of this provision shall be void and without effect.
6. Term and Termination
The term of this Agreement shall continue from year to year, or until it is terminated by either
party. Except as otherwise provided herein, either party shall have the right to terminate this
Agreement with or without cause, at any time, by giving ninety (90) days written notice of the
termination to the other party. In the event of termination, Employer will pay for all work
completed by McCready through the end of the notification period.
After this Agreement is terminated for any reason, including the completion of any Reports which
Employer has requested McCready complete, the following will apply with regard to the Privacy
Rule:
a. All of the PHI provided to McCready by Employer or a Covered Entity, or created or received
under this Agreement, will be destroyed or returned. If for some reason it is not feasible to
return or destroy PHI, McCready shall extend the protections of this Agreement to such PHI
and limit further uses and disclosures of such PHI to those purposes that make the return or
destruction infeasible as long as McCready holds and maintains such PHI. This provision shall
also apply to PHI that is in the possession of subcontractors or agents of McCready.
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b. Upon one party's knowledge of a material breach by the other party, the parry with the
knowledge shall give written notice detailing the nature of the breach to the other party. The
offending party shall be given an opportunity to cure the breach or end the violation. If the
offending party fails to substantially cure the breach within 30 days after receiving notice from
the other party, this Agreement may terminate. However, if termination is not feasible, the
aggrieved party will report the violation to the Secretary.
7. Compensation
Employer hereby agrees to pay McCready $3,950 (_ $1,975 for the Police Officers' Fund and
$1,975 for the Firefighters' Fund) for the work needed to prepare the requested Pension Benefit
Calculations Reports pursuant to GASB 67 and 68. If after receipt of a Report, alternative
calculations using different assumptions and/or plan provisions are requested, those calculations
will be prepared for a fee based on an hourly rate of one hundred fifty dollars ($150) to three
hundred fifty dollars ($350), depending upon the personnel needed to complete the calculations.
McCready reserves the right to choose who among its staff is needed to prepare such calculations.
Payment is expected within thirty (30) days of receipt of an invoice. Interest will be charged at a
rate of one percent (1%) per month on any balance due that exceeds thirty (30) days. McCready
retains the right to withhold additional services in the event that bills are not paid timely and
completely.
8. Privacy and Records
McCready shall maintain procedural, physical, electronic, and contractual safeguards to secure the
confidentiality of all information pertaining to Employer. McCready shall restrict access to such
information to those that have a legitimate business need to know but only after prior written
approval by Employer. McCready shall not discuss, disclose, or reveal information except as
required by federal or state law, subpoena, court order, or regulatory agency examiners, provided
that prior written notice of such disclosure is furnished to Employer as soon as practicable to afford
Employer an opportunity to seek a protective order or other appropriate remedy to protect
confidential information.
Employer is the owner of the reports prepared in conjunction with this Agreement along with any
information provided by Employer for the preparation of the Report. In the event Employer
provides to McCready data of a confidential nature that McCready does not need to complete its
duties, McCready shall return such information immediately.
9. Destruction of Records
McCready shall maintain file copies of the Report delivered to Employer along with the supporting
information used to develop those reports for a minimum of six (6) years. McCready may destroy
original documents as McCready deems appropriate, at any time McCready retains imaged or
similarly reproduced records which are clear reproductions of original documents.
10. Miscellaneous
a. Any reference in this Agreement to a section in the Privacy Rule means that rule or
section as in effect or as amended.
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b. The parties agree to take such action as is necessary to amend this Agreement from
time to time as necessary for the Plan to comply with the requirements of the Privacy
Rule and Security Rule.
c. The respective rights and obligations of each party under Section 6 of this Agreement
shall survive the termination of this Agreement.
d. If there is any ambiguity in this Agreement, it shall be resolved to comply with the
Privacy Rule and/or the Security Rule, as applicable.
11. Severability
The parties intend each and every provision of this Agreement to be severable. In the event that
any provision of this Agreement is determined to be invalid or unenforceable, such invalidity or
unenforceability shall not in any way affect the validity or enforceability of the remaining
provisions.
12. Notices
All notices under this Agreement shall be in writing and shall be deemed given when personally
delivered, when sent by facsimile transmission with proof of receipt by the recipient, or three days
after being mailed postage prepaid by certified.U.S. mail to the address of the party as set forth
below or such other address which a party provides to the other by written notice. Each party to
this Agreement shall notify the other parties of any change in its address. Such notification shall
be provided as follows:
If to Employ
Barbara A. Lamb
Director of Human Resources
City of Carmel
One Civic Square
Carmel, IN 46032
Phone: (317) 571-2471
Fax: (317) 571-2409
E-mail: blamb o,carmel.in. ov
If to McCready:
John C. Benge
Senior Consulting Principal
McCready and Keene, Inc.
P.O. Box 6094
Indianapolis, IN 46206
Phone: (317) 285-6502
Fax: (317) 285-6466
E -Mail: john.benaegoneamerica.com
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13. Governine Law and Attornev's Fees
The validity of this Agreement, the construction and enforcement of its terms, and the interpretation
of the rights and duties of the parties shall be governed by the laws of the State of Indiana.
In the event of any arbitration or other legal proceedings between the parties, each party will be
responsible for their own attorney's fees and all costs. The parties agree that all arbitration or other
legal proceedings under this Agreement shall be brought in the courts of the State of Indiana.
14. Indemnification
The parties shall indemnify to the extent identified by Indiana law and hold harmless each other
from all demands, claims, actions,_ assessments, losses, damages, and reasonable attorney's fees
and costs as a result of any liability arising from any action or failure to act resulting from
compliance with instructions received from the other party, except to the extent it is. determined
such action or failure to act is directly attributable to gross negligence, willful misconduct, or
violation of applicable law- by the offending party. Notwithstanding the preceding, McCready's
liability shall be limited to the maximum compensation indicated in Section 7 of the Agreement.
15. Force Maieure
McCready is not responsible or liable for any failure or delay in the performance of its obligation
under this Agreement arising from or caused directly or indirectly by circumstances beyond its
control, including acts of God, earthquakes, fires, floods, wars, civil or military disturbances,
sabotage, epidemics, riots, loss or malfunction of utilities or communication services, acts of civil
or military authority, or governmental action.
16. E -Verify Program
McCready is required to enroll in and certify the work eligibility status through the E -Verify
program of all newly hired employees who are given responsibility to perform services for the
Employer as provided in item 1. Should the E -Verify program cease to exist, this requirement will
no longer exist.
By execution of this Agreement, McCready certifies that, based solely on the use of the E -Verify
program, McCready believes that, to the best of its knowledge, no unauthorized alien is an
employee of McCready who would be given responsibilities to perform services for the Employer.
17. Entire Amement
This Agreement and its Exhibits constitute the entire understanding of the parties, superseding all
prior agreements, understandings, negotiations, and discussions between them whether written or
oral, and there are no other understandings, representations, warranties, or commitments with
respect thereto.
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18. Acceptance
This agreement may either be signed by Employer and a copy returned to McCready, or, in lieu of
written acceptance of this Agreement, the Employer's acceptance of services and/or payment of
fees under this Agreement will constitute acceptance of this Agreement.
IN WITNESS WHEREOF, the parties have executed this Agreement as follows.
The City of Carmel
BIy.L1�1�,'�'Lri
Signature
Printed
Title
Date
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McCready and eene, I C.
By:
Signature
Andrew V. Wilkinson
Printed
Sr. Vice President & Managing Principal
Title
December 23, 2016
Date
PENSION BENEFIT
INFORMATION REQUIREMENTS
FOR BENEFITS PAYABLE TO
CITY OF CARMEL MUNICIPAL POLICE OFFICERS' AND FIREFIGHTERS' FUND
(NOT ADMINISTERED BY PERF)
The following is a list of the information that is required for the preparation of a Pension Benefit disclosure
report. This is a comprehensive list and some of this information you may have already provided. Some
of the requested information may not be applicable or available. Please provide as much of this information
as is practical, but please do not provide the Social Security Numbers of participants.
1. Plan Documentation describing the substantive plan, such as:
a. Legal documents (plan document, amendments, board resolutions, etc.)
b. Booklets
C. Summary Plan Descriptions
d. Letters, memorandums, agreements, or other communication materials
2. Any differences between the written plan and the manner in which the plan is administered.
3. A history of benefit changes during the past ten years along with any benefit changes currently
being considered.
4. Census information for all active, terminated vested, and retired employees, and their beneficiaries
including:
a. Status (active, retired, surviving spouse, etc.)
b. Employee number or unique identifier (Please do not use Social Security #'s)
c. Sex
d. Date of Birth
e. Date of Hire
f. 5 -year history of total plan compensation earned and received (for current actives only)
g. 5 -year history of total hours worked (for current actives only)
h. Date of Termination (for current terminated vested participants only)
i. Monthly accrued benefit (for current terminated vested participants only)
j. Date of Benefit Commencement (for current retirees and beneficiaries in payment status)
k. Monthly annuity benefit amount (for current retirees and beneficiaries in payment status)
1. Annuity payment form (for current retirees and beneficiaries in payment status)
in. Date of birth and sex of spouse (for current retirees in payment status with covered spouse)
A copy of the most recent actuarial valuation report prepared for this plan.
Is there an established Trust with assets? Are assets segregated to fund retiree benefits only? If
assets are segregated for retirees, please provide the Market Value of the Trust as of the
measurement date.
7. Do you disclose as a public or nonpublic employer?
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McCready and Keene, Inc. Privacy Policy
In the course of providing actuarial, record keeping, and other administrative services for our
clients and their retirement and other employee benefit plans, we receive participant information and
related financial data from employees and financial institutions in connection with such plans. This
Privacy Policy establishes the following guidelines for how our McCready and Keene, Inc. and its
employees are to deal with any such information:
1. The use of information is specifically limited to those activities for which we have been
employed. Such information will be used to compile reports and other materials, including the processing
of plan benefits, as appropriate, in connection with our services to the plan(s) and the participants to
which such information relates.
2. Computer files and hard copies containing such information are maintained as deemed
appropriate for providing ongoing services to the plans involved in a manner reasonably designed to
preserve their confidentiality.
3. The Company has a shredding policy and a contract with a vendor providing shredding and
certified disposal services for all materials containing client information. This policy is designed to
prevent inadvertent disclosure of client information contained on discarded materials.
4. If the Company learns that any client or participant information is disclosed to a third party
without the client's permission, the Company will notify the client of such breach and comply with rules
and regulations related to this matter.
5. Our records retention policy generally involves the retention of materials for ongoing clients as
long as they are deemed pertinent to those services. Some older records are transferred from time to time
to an off-site storage facility maintained by a third party in that business. From time to time, we direct the
disposal of certain stored information that is no longer needed in connection with our services. The
storage facility has contracted to dispose of such materials in a manner designed to protect the
confidentiality of any client information contained in the materials. The storage facility's security
procedures also ensure that such stored materials can only be delivered to one of our authorized
employees. When a client terminates our services, we will retain records for six years, and then such
records will be disposed of in due course in a manner designed to protect client and participant
confidentiality.
6. The names of representative clients may be used with their permission from time to time as
references in connection with our efforts to obtain new business, but specific financial information on
clients and their plans and participating employees is not used for any purpose other than providing the
agreed services to individual clients and is not disclosed to anyone outside the Company, except as
required in connection with providing our agreed services or as required by law.
7. Our Employee Manual emphasizes the importance of using client information only in
connection with providing our professional services. Employees are prohibited from disclosing client
information to anyone outside the Company, except as required in connection with our agreed services.
8. We also will comply with any legal process that might require the disclosure of certain client
information. However, it is generally the Company's policy to notify the client before complying with any
request for production of documents pursuant to subpoena or in any other legal proceeding.
9. We maintain internal security procedures with regard to our premises and our computer
systems to restrict access to any information provided to us so that we can provide services for our clients,
including their employees and plan participants. Our policy applies to both active and former clients.
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