Notice covers the Aetna Resources For Living EAP in California
This notice applies to the Aetna Resources For Living Employee Assistance Program (EAP) when it is offered in California. If your EAP is offered outside California, the notice suggests you may want to ask for a copy of your employer's privacy notice instead.
Supporting quotations
This Notice of Privacy Practices applies to Aetna Resources For Living (EAP Program) offered in California.
If your EAP Program is offered outside of California, you may want to ask for a copy of your employer’s privacy notice.
Qualifications & exceptions
The notice does not say how an out-of-state EAP member's information is handled; it only points to the employer's own notice.
Not stated here
The contents of any employer privacy notice for an EAP offered outside California are not supplied.
Legal Rights & Agreement Rules · Procedure
Spanish copy offered by phone
A Spanish-language line says that to receive this notice in Spanish you should call the number provided in the document. The rights section later refers to a toll-free EAP number provided by your benefits department and a fax number.
Supporting quotations
Para recibir esta notificación en español por favor llamar al número provisto en este documento.
Not stated here
The supplied text does not print a single dedicated telephone number for the Spanish copy.
Legal Rights & Agreement Rules · Context
Who 'we' is: the Aetna HMO and insurer subsidiaries
A footnote says that for this notice, 'Aetna Resources for Living' and the words we, us and our refer to all of the HMO and licensed insurer subsidiaries of Aetna Inc.
Supporting quotations
For purposes of this Notice, “Aetna Resources for Living” and the pronouns “we,” “us” and “our” refer to all of the HMO and licensed insurer
subsidiaries of Aetna Inc.
Not stated here
The footnote does not list the entities; it only describes them as HMO and licensed insurer subsidiaries of Aetna Inc.
Cross-references
contrast (model-proposed): Aetna Resources for Living is a brand name of Health and Human Resource Center, Inc. — contrast: The footnote at the start says 'we' means the HMO and licensed insurer subsidiaries of Aetna Inc., while the closing line says Aetna Resources for Living is a brand name for products and services provided by Health and Human Resource Center, Inc. The notice does not explain how these two statements fit together or which entity holds the information.
Legal Rights & Agreement Rules · Context
Effective date of October 1, 2025 and unexplained form code
The notice says it became effective on October 1, 2025. A page footer carries the form code GR-68164 with (2-26), which the notice does not explain.
Supporting quotations
This notice became effective on October 1, 2025.
GR-68164 (2-26) EAP Privacy Notice Page 1 of 4
Not stated here
The notice does not say whether the '(2-26)' in the footer is a revision date, and no later or earlier version is supplied.
Legal Rights & Agreement Rules · Company commitment
Required disclosures to you, your representative and HHS
Aetna says it must use and disclose your personal information to you or someone with legal authority to act for you (your personal representative) in order to administer your rights under the notice, and to the Secretary of the U.S. Department of Health and Human Services as necessary for HIPAA compliance and enforcement.
Supporting quotations
Required Disclosures: We must use and disclose your personal information in the following manner:
To you or someone who has the legal right to act for you (your personal representative) in order to administer your rights as described in this notice; and
To the Secretary of the Department of Health and Human Services, as necessary, for HIPAA compliance and enforcement purposes.
Qualifications & exceptions
This list uses 'must', unlike the 'may' disclosures above.
Legal Rights & Agreement Rules · User right or choice
Written authorization needed for situations not described
In all other situations than those described in the notice, Aetna says it will ask for your written authorization before using or disclosing personal information about you. Examples where it will get your authorization are marketing unrelated to your benefit plan(s), disclosing psychotherapy notes, the sale of your health information, and other reasons required by law.
Supporting quotations
In all other situations other than those described above, we will ask for your written authorization before using or disclosing personal information about you.
for marketing purposes that are unrelated to your benefit plan(s),
before disclosing any psychotherapy notes,
related to the sale of your health information, and
for other reasons as required by law.
Qualifications & exceptions
The list is introduced by 'For example', so it is not complete.
The earlier lists of permitted uses and disclosures are described by 'may' and are not stated to need authorization.
Legal Rights & Agreement Rules · User right or choice
You can revoke an authorization in writing
If you have given Aetna an authorization, you may revoke it in writing at any time, if Aetna has not already acted on it.
Supporting quotations
If you have given us an authorization, you may revoke it in writing at any time, if we have not already acted on it.
Qualifications & exceptions
Revocation does not undo anything Aetna has already done in reliance on the authorization.
Legal Rights & Agreement Rules · Restriction or exception
Special protections can apply to sensitive categories of health information
The notice says some state and federal laws may require special privacy protections, including certain requirements to obtain attestations from requestors, that limit the use and disclosure of certain sensitive health information. The categories listed are alcohol or substance use disorder, biometric information, child or adult abuse or neglect including sexual assault, communicable diseases, genetic information, HIV/AIDS, mental health, minors, reproductive health and sexually transmitted diseases.
Supporting quotations
Some state and federal laws may require special privacy protections, including certain requirements to obtain attestations from requestors, that limit the use and disclosure of certain sensitive health information. Such laws may protect information related to:
Alcohol or substance use disorder
Biometric Information
Child or adult abuse or neglect, including sexual assault
Communicable diseases
Genetic information
HIV/AIDs
Mental health
Minors
Reproductive health
Sexually transmitted diseases
Qualifications & exceptions
The notice says such laws 'may' apply; it does not say which laws or in what situations they apply to this EAP.
Not stated here
The notice does not name the specific laws or the attestation requirements.
Legal Rights & Agreement Rules · Restriction or exception
Aetna follows the stricter law and points to the Privacy Office
Aetna says it will follow the law that is stricter, or more protective of your PHI, where it applies to Aetna. For more about additional use or disclosure restrictions for sensitive PHI, the notice says to contact the Aetna Privacy Office.
Supporting quotations
We will follow the law that is stricter (or more protective of your PHI), where it applies to us.
If you would like additional information about additional use or disclosure restrictions that may apply to your sensitive PHI, please contact the Aetna Privacy Office.
Qualifications & exceptions
This rule applies to the general uses and disclosures described earlier.
Legal Rights & Agreement Rules · Restriction or exception
Substance use disorder information: limited disclosures without permission
In limited situations where Aetna may disclose this information without your permission, such as medical emergencies and government audits, Aetna says it will follow the law that is more protective of your information.
Supporting quotations
In limited situations where we may disclose this information without your permission, such as medical emergencies and government audits, we will follow the law that is more protective of your information.
Qualifications & exceptions
The examples are introduced by 'such as' and are not exhaustive.
Legal Rights & Agreement Rules · Restriction or exception
Substance use disorder information is not used in legal cases against you without consent or court order
Aetna says it will not use or share this information in any legal case against you unless you give written consent, or a court orders it with a subpoena or other legal requirement. The notice adds that you or Aetna must also receive notice and a chance to be heard.
Supporting quotations
We will not use or share this information in any legal case against you unless:
You give us written consent, or
A court orders us with a subpoena or other legal requirement.
You or Aetna must also receive notice and a chance to be heard.
Qualifications & exceptions
The two exceptions are joined by 'or'; the notice and chance to be heard is an additional stated condition.
Not stated here
The passage says 'You or Aetna' must receive notice and a chance to be heard; it does not say whether this applies to both exceptions or only the court-order route.
Cross-references
narrows (model-proposed): Law enforcement, court orders and legal requirements — narrows: Aetna may disclose information in response to a court order or other lawful process, but for substance use disorder information it says it will not use or share it in a legal case against you without your written consent or a court order.
Legal Rights & Agreement Rules · Context
Your rights regarding health information come from federal privacy regulations
The notice says the federal privacy regulations give you several rights regarding your health information, which it then lists.
Supporting quotations
The federal privacy regulations give you several rights regarding your health information.
Qualifications & exceptions
The rights are described as arising under federal privacy regulations; the notice does not mention state-law rights here.
Legal Rights & Agreement Rules · User right or choice
Right to ask for restrictions; Aetna may not agree
You have the right to ask Aetna to restrict how it uses or discloses health information about you in connection with health care operations, payment and treatment, and to restrict disclosures to persons involved in your health care. Aetna says it will consider, but may not agree to, such requests.
Supporting quotations
You have the right to ask us to restrict the way we use or disclose health information about you in connection with health care operations, payment and treatment. We will consider, but may not agree to, such requests. You also have the right to ask us to restrict disclosures to persons involved in your health care.
Qualifications & exceptions
The right is a right to ask; the notice does not promise Aetna will grant a restriction.
Legal Rights & Agreement Rules · User right or choice
Right to get a copy of records in a designated record set
You have the right to ask Aetna to obtain a copy of health information contained in a 'designated record set', meaning medical records and other records maintained and used in making payment, medical management and other decisions. Aetna may ask you to make the request in writing, may charge a reasonable fee for producing and mailing the copies and, in certain cases, may deny the request.
Supporting quotations
You have the right to ask us to obtain a copy of health information that is contained in a “designated record set” – medical records and other records maintained and used in making payment, medical management and other decisions.
We may ask you to make your request in writing, may charge a reasonable fee for producing and mailing the copies and, in certain cases, may deny the request.
Qualifications & exceptions
The right covers the designated record set, not every record Aetna may hold.
Not stated here
The notice does not say in which cases a request may be denied.
Legal Rights & Agreement Rules · User right or choice
Right to ask for an amendment in writing
You have the right to ask Aetna to amend health information in a designated record set. The request must be in writing and include the reason. If Aetna denies the request, you may file a written statement of disagreement.
Supporting quotations
You have the right to ask us to amend health information that is in a “designated record set.” Your request must be in writing and must include the reason for the request. If we deny the request, you may file a written statement of disagreement.
Not stated here
The notice does not say when Aetna may deny an amendment.
Legal Rights & Agreement Rules · User right or choice
Right to an accounting of certain disclosures
You have the right to ask Aetna for a list of certain disclosures it has made about you, such as disclosures to government agencies that license it. The request must be in writing. If you request an accounting more than once in a 12-month period, Aetna may charge a reasonable fee.
Supporting quotations
You have the right to ask us to provide a list of certain disclosures we have made about you, such as disclosures of health information to government agencies that license us. Your request must be in writing. If you request such an accounting more than once in a 12-month period, we may charge a reasonable fee.
Qualifications & exceptions
Only 'certain' disclosures are listed; the example given is disclosures to government agencies that license Aetna.
Not stated here
The notice does not say which disclosures are included or excluded from the accounting.
Legal Rights & Agreement Rules · User right or choice
Right to file a complaint with Aetna
You have the right to file a complaint if you think your privacy rights have been violated. The notice says to email the Aetna Privacy Office at PrivacyAetna@aetna.com or send your inquiry to Resources for Living, 9350 Waxie Way Suite 210, San Diego, CA 92123, or to fax 1-800-678-9229.
Supporting quotations
You also have the right to file a complaint if you think your privacy rights have been violated. To do so, please send an email to Aetna Privacy Office at PrivacyAetna@aetna.com or send your inquiry to the following address:
Resources for Living 9350 Waxie Way Suite 210
San Diego, CA 92123
Fax: 1-800-678-9229
Qualifications & exceptions
The fax number appears under the complaint address block; the notice does not state expressly that the fax is for complaints, so this reading is from placement.
Not stated here
The notice does not say how Aetna handles or responds to complaints.
Legal Rights & Agreement Rules · User right or choice
Right to complain to HHS and not be penalized
You may also write to the Secretary of the U.S. Department of Health and Human Services. The notice says you will not be penalized for filing a complaint.
Supporting quotations
You may also write to the Secretary of the U.S. Department of Health and Human Services. You will not be penalized for filing a complaint.
Not stated here
No HHS address or complaint deadline is given in the supplied text.
Legal Rights & Agreement Rules · Company commitment
Aetna is required to keep information private and follow this notice
The notice says the federal privacy regulations require Aetna to keep personal information about you private, to give you notice of its legal duties and privacy practices, and to follow the terms of the notice currently in effect.
Supporting quotations
The federal privacy regulations require us to keep personal information about you private, to give you notice of our legal duties and privacy practices, and to follow the terms of the notice currently in effect.
Qualifications & exceptions
The duty is to follow the notice 'currently in effect', which Aetna may change.
Legal Rights & Agreement Rules · Permission or license
Aetna may change the notice and its policies at any time, including for existing information
Aetna says it may change the terms of this notice and its privacy policies at any time. If it does, the new terms and policies will be effective for all of the information it already has about you, as well as any information it may receive or hold in the future.
Supporting quotations
We may change the terms of this notice and our privacy policies at any time. If we do, the new terms and policies will be effective for all of the information that we already have about you, as well as any information that we may receive or hold in the future.
Qualifications & exceptions
The notice does not promise advance notice of changes.
Not stated here
The notice does not say how members would learn of a change.
Legal Rights & Agreement Rules · Context
Aetna Resources for Living is a brand name of Health and Human Resource Center, Inc.
The notice says Aetna Resources for Living is the brand name used for products and services provided by Health and Human Resource Center, Inc.
Supporting quotations
Aetna Resources for Living is the brand name used for products and services provided by Health and Human Resource Center, Inc.
Not stated here
The footnote at the start says 'we' means the HMO and licensed insurer subsidiaries of Aetna Inc.; the notice does not explain how that relates to the entity named here.