SOCIAL SECURITY NUMBER PRIVACY PROTECTION POLICY

SOCIAL SECURITY NUMBER PRIVACY PROTECTION POLICY

I. policy

Carolina Casualty Insurance Company is committed to maintaining the confidentiality of Social Security numbers that it collects during the regular course of business. Accordingly, Carolina Casualty Insurance Company has established this policy to restrict access, disclosure, use and disposal of Social Security numbers that have been collected by the Company. The purpose of this policy is to assure compliance with all with Federal, State and Local Law protecting the confidentiality of Social Security numbers.

II. procedures to protect THE confidentialITY of social security numbers

Authorized Collection And Access To Social Security Numbers

Carolina Casualty Insurance Company collects the Social Security numbers of employees, applicants, independent contractors, interns and other individuals only for legitimate business reasons. Examples of such reasons may include:

· The handling of insurance claims and payments in connection with operating its insurance business (i.e. under Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA) (P.L. 110-173));

· Background checks for applicants for employment;

· Determining eligibility for employment;

· Enrollment in employee benefits programs;

· Reporting that is required by law, such as for tax purposes.

Carolina Casualty Insurance Company restricts access to the Social Security numbers that it collects only to Carolina Casualty Insurance Company employees and certain third parties who are legally authorized to access this information. Authorized employees are those whom the Company has determined have a legitimate business need to access this information. Authorized third parties are those who have a legitimate need to access this information and owe a duty to maintain its confidentiality (e.g. vendors who are provided Social Security numbers to run background checks and insurance providers).

Disclosure And Use Of Social Security Numbers

Carolina Casualty Insurance Company prohibits the disclosure and use of Social Security numbers unless such disclosure and use complies with this policy and with Federal, state and local law. Social Security numbers shall not be displayed on identification cards or badges, bulletin boards, or any similar materials that are publicly displayed. Documents, materials or computer screens that display Social Security numbers shall be shown only to authorized employees and third parties and shall be kept out of public view at all times.

Social Security numbers may only be used by authorized Carolina Casualty Insurance Company employees for legitimate business reasons, including but not limited to those reasons described above.

Storage And Disposal Of Personal Information Including Social Security Numbers

Carolina Casualty Insurance Company takes reasonable steps so that all documents and files (both electronic and in hard copy) that contain personal information such as Social Security numbers are stored in a physically secure manner. “Personal information” is defined under the law as information capable of being associated with a particular individual through one or more identifiers. Examples of personal information include a person’s Social Security number, driver’s license number, passport number, credit or debit card numbers and health insurance identification numbers.

Carolina Casualty Insurance Company requires that personal information be stored in a way that prevents unauthorized access. For example, hard copy documents that contain personal information should be stored in files that can only be accessed by authorized Carolina Casualty Insurance Company employees or third parties, and computers or other electronic devices that contain personal information should be secured against unauthorized access, such as through the use of a password. Carolina Casualty Insurance Company requires that any authorized personnel who maintains personal information must take appropriate steps consistent with this policy to safeguard such information.

Documents or other materials (both electronic and in hard copy) that contain personal information shall be disposed of in a manner such that the personal information is erased or made unreadable at the time of disposal. It may be necessary to consult with Carolina Casualty Insurance Company’s IT department to ensure proper disposal of personal information that is stored electronically.

III. NON-COMPLIANCE WITH THIS POLICY AND THE LAW

Failure to comply with this policy may result in disciplinary action up to and including termination. Furthermore, the law provides civil and criminal penalties for individuals who violate laws protecting the confidentiality of Social Security numbers.

If you have any questions about this policy, including about how to dispose of personal information, please contact Betty C. Sutherland, Vice President and Secretary.

(10/09)

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