Employee assistance plans notice of privacy practices

Aetna / CVS Health · agreement dated October 1, 2025 · Official agreement

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Aetna affiliates can share protected health information with each other

The Aetna entities covered by this notice are designated a single affiliated covered entity for federal privacy purposes (the Aetna ACE). Members of the Aetna ACE can share protected health information (PHI) with each other for the treatment, payment and health care operations of the ACE and as allowed by HIPAA and this notice. A full list of members is available by contacting the Aetna Privacy Office by email.

Supporting quotations

These entities have been designated as a single affiliated covered entity for federal privacy purposes.
The members of the Aetna ACE can share Protected Health Information (PHI) with each other. We do this for the treatment, payment and health care operations of the Aetna ACE and as allowed by HIPAA and this Notice.
For a full list of the members of the Aetna ACE, contact the Aetna Privacy Office at PrivacyAetna@aetna.com.

Qualifications & exceptions

  • Sharing is described as among members of the Aetna ACE, not with outside parties; other disclosures are covered by separate sections.

Not stated here

  • The list of ACE members is not in the supplied text.

Sharing & Disclosure · Permission or license

Information can move in a sale, merger or contract transfer

Among the operational activities, Aetna lists transfers of contracts from and to other EAP vendors and facilitating a sale, transfer, merger or consolidation of all or part of Aetna Resources For Living with another entity, including due diligence related to that activity. In practice, this means information about EAP members may be used or disclosed when the business or its contracts change hands.

Supporting quotations

transfer of contracts from and to other EAP vendors; facilitation of a sale, transfer, merger or consolidation of all or part of Aetna Resources For Living with another entity (including due diligence related to such activity);

Qualifications & exceptions

  • Listed as an operational activity 'requiring use and disclosure'; the notice does not name any specific transaction or recipient.

Not stated here

  • Whether the other party must keep the information protected is not stated in this passage.

Sharing & Disclosure · Permission or license

Treatment: disclosure of PHI to health care providers

Aetna may disclose your protected health information to health care providers for the provision, coordination or management of your healthcare.

Supporting quotations

Treatment: We may disclose your Protected Health Information to health care providers for the provision, coordination or management of your healthcare.

Not stated here

  • The notice does not say whether the EAP itself provides treatment or which providers are meant.

Sharing & Disclosure · Permission or license

Disclosures to other covered entities and their business associates

Aetna may disclose personal information to other covered entities, or their business associates, for treatment, payment and certain health care operations purposes. As an example, it may disclose information to other health plans maintained by your employer, if it has been arranged for Aetna to do so, so that certain expenses can be reimbursed.

Supporting quotations

Disclosures to other covered entities: We may disclose personal information to other covered entities, or business associates of those entities for treatment, payment and certain health care operations purposes.
For example, we may disclose personal information to other health plans maintained by your employer, if it has been arranged for us to do so, in order to have certain expenses reimbursed.

Qualifications & exceptions

  • 'Certain health care operations' is not defined in this passage.

Sharing & Disclosure · Permission or license

Research disclosures with privacy measures

Aetna may disclose personal information to researchers, provided measures are taken to protect your privacy.

Supporting quotations

We also may disclose such information in support of:
Research – to researchers, provided measures are taken to protect your privacy.

Qualifications & exceptions

  • Listed among 'additional reasons for disclosure' that Aetna says it 'may' make.

Not stated here

  • The notice does not say what the privacy measures are or whether the research disclosure is of identifiable information.

Sharing & Disclosure · Permission or license

Business partners that assure they will protect the information

Aetna may disclose personal information to persons who provide services to it and who assure Aetna they will protect the information.

Supporting quotations

We also may disclose such information in support of:
Business partners – to persons who provide services to us and assure us they will protect the information.

Qualifications & exceptions

  • The protection is an assurance given to Aetna; the passage does not describe a contract or how the assurance is checked.

Sharing & Disclosure · Permission or license

Regulators and government agencies that regulate Aetna

Aetna may disclose personal information to state insurance departments, boards of pharmacy, the U.S. Food and Drug Administration, the U.S. Department of Labor and other government agencies that regulate it.

Supporting quotations

We also may disclose such information in support of:
Industry regulations – to state insurance departments, boards of pharmacy, U.S. Food and Drug Administration, U.S. Department of Labor and other government agencies that regulate us.

Qualifications & exceptions

  • The named agencies are examples; the passage ends with 'and other government agencies that regulate us'.

Sharing & Disclosure · Permission or license

Workers' compensation disclosures

Aetna may disclose personal information to comply with workers' compensation laws.

Supporting quotations

We also may disclose such information in support of:
Workers’ Compensation – to comply with workers’ compensation laws.

Not stated here

  • The passage does not name the recipient.

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Law enforcement, court orders and legal requirements

Aetna may disclose personal information to federal, state and local law enforcement officials, in response to a court order or other lawful process, and to comply with legal obligations and requirements.

Supporting quotations

We also may disclose such information in support of:
Law enforcement – to federal, state and local law enforcement officials.
Legal proceedings – in response to a court order or other lawful process.
As Required by Law – to comply with legal obligations and requirements.

Qualifications & exceptions

  • These are separate listed reasons: law enforcement, legal proceedings and 'As Required by Law'. The wording does not require a warrant or court order for the law enforcement item.
  • For substance use disorder information received through a Part 2 consent, the notice sets stricter limits on use in legal cases.

Not stated here

  • The notice does not say what conditions Aetna applies before releasing information to law enforcement.

Sharing & Disclosure · Permission or license

Public welfare disclosures

Aetna may disclose personal information to address matters of public interest as required or permitted by law, for example child abuse and neglect, threats to public health and safety and national security.

Supporting quotations

We also may disclose such information in support of:
Public welfare – to address matters of public interest as required or permitted by law (e.g., child abuse and neglect, threats to public health and safety and national security).

Qualifications & exceptions

  • The examples are introduced by 'e.g.' and are not exhaustive.

Sharing & Disclosure · Permission or license

Coroners, medical examiners, funeral directors and organ procurement groups

Aetna may disclose personal information about a deceased person to a coroner or medical examiner to identify the person, determine a cause of death or as authorized by law, and to funeral directors as necessary to carry out their duties. It may also respond to organ donation groups to facilitate donation and transplantation.

Supporting quotations

We also may disclose such information in support of:
Decedents – to a coroner or medical examiner for the purpose of identifying a deceased person, determining a cause of death, or as authorized by law; and to funeral directors as necessary to carry out their duties.
Organ Procurement – to respond to organ donation groups for the purpose of facilitating donation and transplantation.

Sharing & Disclosure · Context

Disclosed information may be redisclosed and lose HIPAA protection

The notice warns that protected health information disclosed as permitted by HIPAA may be subject to redisclosure by the recipient and no longer protected by HIPAA.

Supporting quotations

PHI disclosed as permitted by HIPAA may be subject to redisclosure by the recipient and no longer protected by HIPAA.

Qualifications & exceptions

  • The warning is phrased with 'may'; the notice does not say which recipients are covered by HIPAA themselves.