Aetna International U.S.-based plans notice of privacy practices

Data Access & Collection · Context

What "personal information" means and why Aetna obtains it

The notice uses "personal data," "personal information" and "Information" to mean the same thing: any information that can directly or indirectly identify you or be related to you as an individual, including health information about things such as your medical history (the health care you receive or the amounts paid for it). Aetna says it obtains this information in order to provide you with, or administer, your healthcare plan.

Supporting quotations

(personal data and personal information are considered to mean the same for the purposes of this Privacy Notice)

we mean any information that can directly or indirectly identify, or be related to, you as an individual, including health information that relates to, among other things, your medical history (i.e., the health care you receive or the amounts paid for that care). We obtain this Information in order to provide you with, or administer, your healthcare plan.

Qualifications & exceptions

• "Among other things" means the health information examples are not an exhaustive list.

Data Access & Collection · Company practice

Aetna says it must receive and hold health information to deal with insurance

Aetna says it will be necessary to receive and hold your health personal information for dealing with your insurance, for example to arrange, underwrite and administer the insurance contract under which you benefit, to administer a claim under the contract, or to exercise a right or comply with an obligation.

Supporting quotations

It will be necessary to receive and hold your health personal information for dealing with your insurance for example:

arranging, underwriting, administering the insurance contract under which you benefit,

administering a claim under the insurance contract, or

exercising a right or complying with an obligation.

Qualifications & exceptions

• The items are introduced as examples ("for example"), so the list is not exhaustive.

Data Access & Collection · Company practice

Group plan: data comes from the plan sponsor and is kept after a quote

For group plans, Aetna says it gets some personal data from your plan sponsor when the sponsor requests an insurance quote, and keeps that information after any quote has been accepted and the group plan starts. The information includes your name, date of birth and country of residence. Aetna says it does not process the information for any other purpose unless you submit a claim under the policy.

Supporting quotations

Group Plans: we get some personal data from your plan sponsor when they request an insurance quote from us, and we retain that information after any quote has been accepted and they start the group plan with us.

This Information includes your name, date of birth and country of residence.

We do not process your Information for any other purpose unless you submit a claim under the policy.

Qualifications & exceptions

• The data named is "some" personal data, and the list says it "includes" name, date of birth and country of residence.

Not stated here

• The "no other purpose" sentence sits alongside the notice's listed purposes of onboarding you and administering the group plan; the notice does not explain how the two statements fit together.

Cross-references

• contrast (model-proposed): Group plan data processed on Aetna's legitimate interest — contrast: One passage says Aetna does not process group-plan data for any other purpose unless you submit a claim; the legal-basis passage says the data is processed to onboard you and administer the group plan. The notice does not reconcile them.

Data Access & Collection · Company practice

Individual plan: data from you, your broker, insurers, TPAs and providers

For individual plans, Aetna says it receives your personal data either directly from you or from an insurance broker you instructed. It may also receive some personal data from other insurers, brokers, third-party administrators (TPAs) and health care providers.

Supporting quotations

Individual Plans: where you have taken out an individual insurance plan with us, we will have received your personal data either directly from you or from an insurance broker that you instructed.

We may also receive some personal data from other insurers, brokers, third-party administrators (TPAs), and health care providers.

Please see above for the type of personal data received.

Qualifications & exceptions

• The additional sources are introduced with "may" and "some."

Not stated here

• The sentence refers the reader "above" for the type of personal data received. The only categories named above for any plan type are name, date of birth and country of residence for group-plan sponsor data, plus the general description of personal information.

Data Access & Collection · Company practice

Information comes from many sources; uses and disclosures are not limited to those listed

Aetna says that to administer your insurance cover and related services it needs to collect information about you, from many sources: particularly your employer or benefits plan sponsor, other insurers, brokers, third-party administrators (TPAs) and health care providers. In administering your health benefits it may use and disclose information about you in various ways, "including, but not limited to" the examples that follow, for both group and individual plans.

Supporting quotations

In order to administer your insurance cover, and/or any related services in connection with your contract, we need to collect Information about you.

We obtain this Information from many different sources

particularly your employer or benefits plan sponsor, other insurers, brokers, third-party administrators (TPAs), and health care providers.

In administering your health benefits, we may use and disclose Information about you in various ways, including, but not limited to:

Group and Individual Plans: We may disclose Information about you in various ways, including, but not limited to:

Qualifications & exceptions

• The sources are introduced with "particularly," so the list is not exhaustive.
• Uses and disclosures are stated as "including, but not limited to" the listed examples.

Not stated here

• Because the lists are not limited, the notice does not say what other uses or disclosures may occur.

Data Access & Collection · User right or choice

Right not to be subjected to pretext interviews, with very limited exceptions

The notice says you have the right, with very limited exceptions, not to be subjected to pretext interviews. A footnote marker follows the statement.

Supporting quotations

You have the right with very limited exceptions, not to be subjected to pretext interviews.

Qualifications & exceptions

• "With very limited exceptions."

Not stated here

• The notice does not describe the exceptions. The footnote the marker points to is covered with the end of the notice.

Cross-references

• contrast (model-proposed): Footnote: Aetna does not participate in pretext interviews — contrast: The rights list says there are very limited exceptions to the right not to be subjected to pretext interviews; the footnote says Aetna does not participate in them. The notice does not describe the exceptions.

Data Access & Collection · Company commitment

Footnote: Aetna does not participate in pretext interviews

A footnote at the end of the notice says Aetna does not participate in pretext interviews. It follows the earlier statement that you have the right, with very limited exceptions, not to be subjected to pretext interviews.

Supporting quotations

We do not participate in pre-text interviews.

You have the right with very limited exceptions, not to be subjected to pretext interviews.

Qualifications & exceptions

• The footnote does not repeat the "very limited exceptions" wording used in the rights list.

Not stated here

• The notice does not say what the exceptions in the rights list are, or how they square with the footnote's statement that Aetna does not participate in pretext interviews.