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.
Security & Safeguards · Company commitment
Aetna says it treats personal information as confidential
Aetna Resources For Living says it considers personal information confidential and protects its privacy in accordance with federal and state privacy laws and its own company privacy policies. The notice describes how Aetna may use and disclose information about you in administering your EAP services and explains your legal rights regarding that information.
Supporting quotations
Aetna Resources For Living1 considers personal information confidential. We protect the privacy of that information in accordance with federal and state privacy laws, as well as our own company privacy policies.
This notice describes how we may use and disclose information about you in administering your EAP Program services, and it explains your legal rights regarding the information.
This notice describes how medical information about you may be used and disclosed and how you can get access to this information.
Qualifications & exceptions
The commitment is stated at a general level and is tied to federal and state privacy laws and Aetna's own policies.
Not stated here
The 'own company privacy policies' that the commitment refers to are not supplied in this document.
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.
Sharing & Disclosure · Permission or license
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.
Data Access & Collection · Context
What 'personal information' and 'health information' mean
The notice defines 'personal information' as information that identifies you, such as your name and Social Security Number, as well as financial, health and other nonpublic information about you that Aetna obtains so it can provide EAP Program services. 'Health information' is information that identifies you and relates to your medical history, meaning the health care you receive or the amounts paid for it.
Supporting quotations
When we use the term “personal information,” we mean information that identifies you as an individual, such as your name and Social Security Number, as well as financial, health and other information about you that is nonpublic, and that we obtain so we can provide you with EAP Program services.
By “health information,” we mean information that identifies you and relates to your medical history (i.e., the health care you receive or the amounts paid for that care).
Qualifications & exceptions
The notice also uses 'PHI' and 'medical information' without a separate definition.
Not stated here
Whether 'Protected Health Information (PHI)' is meant to be the same as 'health information' is not stated.
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.
Data Access & Collection · Company practice
Aetna gets your information from your employer, insurers, TPAs and providers
To provide EAP services Aetna says it needs personal information about you and obtains it from many different sources, particularly your employer or benefits plan sponsor, other insurers, HMOs or third-party administrators (TPAs) and health care providers.
Supporting quotations
we need personal information about you, and we obtain that information from many different sources – particularly your employer or benefits plan sponsor, other insurers, HMOs or third-party administrators (TPAs) and health care providers.
Qualifications & exceptions
'Particularly' signals that the listed sources are examples, not an exhaustive list.
Use & Processing · Permission or license
Aetna may use and disclose your information in various ways, including those listed
In administering your EAP Program, Aetna says it may use and disclose personal information about you in various ways 'including' the uses described next (health care operations, payment, treatment, and disclosures to other covered entities). The word 'including' means the list is illustrative. The notice later adds that for situations other than those it describes Aetna will ask for your written authorization, and that stricter state or federal protections for sensitive information are followed where they apply.
Supporting quotations
In administering your EAP Program, we may use and disclose personal information about you in various ways, including:
Qualifications & exceptions
Modal wording is 'may', not 'will': the notice permits these uses and does not say each one happens for every member.
Later sections require written authorization for situations not described and require following stricter or more protective laws for sensitive information; those limits apply to this general permission.
Use & Processing · Permission or license
Health care operations: running the business, fraud detection, contract and company transfers
Aetna may use and disclose personal information for the operations of its health business, including quality assessment and improvement, licensing, accreditation by independent organizations, performance measurement and outcomes assessment, health services research, and preventive health, disease management, case management and care coordination. It also lists detecting and investigating fraud, administering payments, and other general administrative activities such as data information systems management and customer service.
Supporting quotations
Health care operations: We may use and disclose personal information during the course of running our health business – that is, during operational activities such as quality assessment and improvement; licensing; accreditation by independent organizations; performance measurement and outcomes assessment; health services research; and preventive health, disease management, case management and care coordination.
Other operational activities requiring use and disclosure include detection and investigation of fraud; administration of payments;
and other general administrative activities, including data information systems management, and customer service.
Qualifications & exceptions
'Such as' and 'include' mark the activities as examples. The permission is for operations, not stated to require your consent.
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.
Use & Processing · Permission or license
Payment: reviews, collection, cost-sharing and disclosure to your provider
To arrange payment for your EAP services, Aetna may use and disclose personal information to conduct utilization and medical necessity reviews, coordinate care, collect payments, calculate cost-sharing amounts, and respond to complaints, appeals and requests for external review. As an example, it may use your medical history and other health information to decide whether a treatment is medically necessary and what payment should be, and may disclose information to your provider during that process.
Supporting quotations
Payment: To arrange payment for your EAP services, we may use and disclose personal information in a number of ways – in conducting utilization and medical necessity reviews; coordinating care; collecting payments; calculating cost-sharing amounts; and responding to complaints, appeals and requests for external review.
For example, we may use your medical history and other health information about you to decide whether a particular treatment is medically necessary and what the payment should be – and during the process, we may disclose information to your provider.
Qualifications & exceptions
'In a number of ways' and 'for example' mean the activities are illustrative.
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.
Use & Processing · Permission or license
Treatment alternatives, reminders and other health-related benefits and services
Aetna may use or disclose personal information about you in providing you with treatment alternatives, treatment reminders or other health-related benefits and services.
Supporting quotations
We may use or disclose personal information about you in providing you with treatment alternatives, treatment reminders or other health-related benefits and services.
Qualifications & exceptions
The notice separately says it asks for your written authorization for marketing purposes that are unrelated to your benefit plan(s); this passage covers benefits and services, not unrelated marketing.
Not stated here
The notice does not say who provides these benefits and services or how often they are offered.
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.
Sharing & Disclosure · Permission or license
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.
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.
Account & Service Control · Procedure
Questions and requests go through the toll-free EAP number
For questions about the notice or requests related to your information, the notice says to contact Aetna using the toll-free EAP number provided by your benefits department.
Supporting quotations
If you have questions regarding this notice or requests related to your information, please contact us by using the toll-free EAP number provided by your benefits department.
Not stated here
The number itself is not printed in the supplied text; it comes from the member's benefits department.
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.
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.
Substance use disorder information: Aetna is not a treatment program
Aetna says it is not a substance use disorder treatment program but may receive or keep information about you that comes from one. If such a program provides the information through a 42 CFR Part 2 consent, including a consent for future uses and disclosures for treatment, payment and health care operations, Aetna says it will use or share the information in accordance with both the consent and HIPAA.
Supporting quotations
We are not a substance use disorder treatment program. We may receive or keep information about you that comes from a substance use disorder program.
If a substance use disorder program provides us this information through a 42 CFR Part 2 consent, including a consent for future uses and disclosures for treatment, payment, and health care operations, we will use or share that information in accordance with both the consent and HIPAA.
Qualifications & exceptions
Applies when the information arrives through a Part 2 consent.
Not stated here
The notice does not say what a Part 2 consent covers beyond the quoted description, or what happens to information that arrives without one.
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.
Account & Service Control · User right or choice
Right to ask for communications in a certain way or at a certain location
You have the right to ask Aetna to communicate with you in a certain way or at a certain location. For example, an adult dependent might want health information such as an Explanation of Benefits (EOB) and other claim information sent to a different address from the subscriber's. Aetna says it will accommodate reasonable requests.
Supporting quotations
You have the right to ask us to communicate with you in a certain way or at a certain location.
We will accommodate reasonable requests.
Qualifications & exceptions
Only reasonable requests are promised to be accommodated.
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.
Security & Safeguards · User right or choice
Right to be notified after a breach
You have the right to be notified following a breach involving your health information.
Supporting quotations
You have the right to be notified following a breach involving your health information.
Not stated here
The notice does not say how quickly or by what means you would be notified.
Account & Service Control · Procedure
How to make requests: fax or the toll-free EAP number
You may make any of the requests described, request a paper copy of the notice, or ask questions about the notice by fax at 1-800-678-9229 or by calling the toll-free EAP number provided by your benefits department.
Supporting quotations
You may make any of the requests described above, may request a paper copy of this notice, or ask questions regarding this notice by fax at 1-800-678-9229 or by calling the toll-free EAP number provided by your benefits department.
please contact us by using the toll-free EAP number provided by your benefits department.
Qualifications & exceptions
Some rights above require a written request; the notice does not say whether a fax counts as writing.
Not stated here
The toll-free EAP number itself is not printed in the supplied text.
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.
Account & Service Control · User right or choice
Stopping paper mail of EOBs and claim information through aetna.com
You may stop the paper mailing of your EOB and other claim information by visiting www.aetna.com, clicking Log In/Register and completing a one-time registration. You can then log in at any time to view past copies of EOBs and other claim information.
Supporting quotations
You may stop the paper mailing of your EOB and other claim information by visiting www.aetna.com and click “Log In/Register”. Follow the prompts to complete the one-time registration. Then you can log in any time to view past copies of EOBs and other claim information.
Qualifications & exceptions
The instruction repeats language that is written for health plan members; it is included in this EAP notice as written.
Not stated here
The notice does not say whether EAP members receive EOBs or can register at aetna.com.
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.
Security & Safeguards · Company commitment
Administrative, technical and physical safeguards
Aetna says it guards your information with administrative, technical and physical safeguards against unauthorized access and against threats and hazards to its security and integrity, and that it complies with all applicable state and federal law pertaining to the security and confidentiality of personal information.
Supporting quotations
We guard your information with administrative, technical and physical safeguards to protect it against unauthorized access and against threats and hazards to its security and integrity. We comply with all applicable state and federal law pertaining to the security and confidentiality of personal information.
Not stated here
The notice does not describe specific safeguards or certifications.
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.
Retention & Deletion · Company practice
Information is not destroyed when your employment or EAP services end
Aetna says it does not destroy personal information about you when your employment terminates or EAP services end. It may be necessary to use and disclose the information for the purposes described in the notice even after services end, although policies and procedures remain in place to protect against inappropriate use or disclosure.
Supporting quotations
Please note that we do not destroy personal information about you when your employment terminates or services under the EAP Program end. It may be necessary to use and disclose this information for the purposes described above even after services terminate, although policies and procedures will remain in place to protect against inappropriate use or disclosure.
Qualifications & exceptions
Continued use is described as 'may be necessary'; protective policies and procedures are said to remain.
Not stated here
No retention period or deletion process is stated.
Cross-references
qualifies (model-proposed): Aetna may use and disclose your information in various ways, including those listed — qualifies: The general uses and disclosures are not limited to the period of EAP services: Aetna says it does not destroy the information when services end and may need to keep using and disclosing it for the purposes described.
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.