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Privacy Policy & Procedures

Corporate Strategies Insurance & Financial Services, Inc. 
Also doing business as CorpStrat, Corporate Strategies Inc., and 
Unlimited Life Insurance Solutions, LLC

Effective: April 2025

1. Purpose

At Corporate Strategies Insurance & Financial Services, Inc. (collectively referred to as “CorpStrat,” “we,” “our,” or “the Company”), protecting the privacy and security of our clients’ information is central to our mission. We are committed to maintaining the confidentiality of all “nonpublic personal information” and “protected health information” (PHI) in compliance with applicable laws, including the Health Insurance Portability and Accountability Act of 1996 (HIPAA), and industry best practices.

This policy applies to all employees, contractors, consultants, and temporary workers (collectively “employees”) with access to sensitive client data, regardless of the medium or form in which it is stored, accessed, or transmitted.

2. Scope & Definitions

This policy covers Protected Health Information (PHI) and other personally identifiable information (PII), which includes—but is not limited to:

  • Name, date of birth, Social Security number
  • Address, phone number, and email
  • Subscriber or policy numbers
  • Medical records, diagnosis codes, and claims details
  • Genetic, biometric, and employment-related data
  • Any other identifiable health information in electronic, paper, verbal, or visual form

This includes data transmitted or stored via:

  • Paper records
  • Email and digital files
  • Electronic systems, mobile devices, and cloud storage
  • Verbal discussions and voicemail

3. Permitted Uses & Disclosures

Employees may access or disclose PHI only as necessary to perform authorized job functions in connection with:

  • Claims processing or payment
  • Healthcare operations and support services
  • Procurement and servicing of insurance and benefits products
  • Activities for which the client has provided explicit written consent

Employees must always adhere to the “Minimum Necessary” standard—accessing only the amount of information required to complete a task.

  • PHI must never be shared:
  • Casually or in informal conversations
  • In public areas like hallways, elevators, restrooms, or reception areas
  • With coworkers who do not have a legitimate business need to know

4. Access Controls & Security Requirements

Physical and Digital Security:

  • PHI must be stored in secure areas or systems, including password-protected and encrypted digital platforms.
  • Workstations accessing PHI must automatically lock after 5 minutes of inactivity.
  • Printed PHI should be secured when unattended and properly disposed of when no longer needed.
  • Fax machines, printers, and copiers must be checked regularly to prevent unattended PHI.
  • Visitors must be escorted through areas where PHI may be accessible.

Remote Work & Devices:

  • Employees working remotely must follow the same standards as on-site operations.
  • PHI must not be stored on unencrypted devices such as smartphones or personal laptops.
  • Use of encryption software is required when emailing PHI externally.
  • Pooled or shared laptops must not retain PHI and must be wiped regularly.

5. Data Retention and Disposal

All PHI must be retained and disposed of in accordance with regulatory standards:

Item Type

Examples

Disposal Method

Item Type

Paper

Examples

Medical records, applications, census forms

Disposal Method

Shredded or placed in secure, locked recycling bins

Item Type

Electronic

Examples

Emails, files, hard drives, CDs, USBs

Disposal Method

Hard drives removed and destroyed; electronic files deleted using secure methods; disks reformatted or destroyed

Employees must not leave PHI in unsecured locations and must regularly clean workspaces containing sensitive data.

6. Reporting Violations or Breaches

Employees are required to report any suspected or confirmed breaches of confidentiality to their manager or the Chief Privacy Officer immediately.

Violations of this policy may result in:

  • Disciplinary action (including termination)
  • Civil or criminal penalties as outlined under HIPAA and applicable state laws

Unscheduled audits may be conducted to ensure ongoing compliance.

7. Policy Updates

This Privacy Policy & Procedures document may be updated periodically to reflect legal, technological, or operational changes. The most current version will always be available on our website and accessible internally.

Contact Us
If you have questions about this policy or wish to report a concern, please contact:

Chief Privacy Officer
Corporate Strategies Insurance & Financial Services, Inc.
818.377.7260, ext. 139 or Inquire@corpstrat.com