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

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

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Legal Rights & Agreement Rules · Context

Notice covers EU residents on Aetna International plans

This notice says it applies to EU residents whose plans are underwritten or administered by Aetna International, Inc. and Aetna Life Insurance Company. It describes itself as explaining how personal data about the member may be used and disclosed and how the member can get access to that information.

Supporting quotations

applies to EU residents who have plans underwritten or administered by Aetna International, Inc., Aetna Life Insurance Company
This Notice describe show personal data about you may be used and disclosed and how you can get access to this information.

Qualifications & exceptions

  • Applies to EU residents; the notice names "plans underwritten or administered by" the two named companies.

Not stated here

  • The notice does not say how residency is determined, or whether a member who is not an EU resident but has an Aetna International plan is covered by this notice or a different one.

Legal Rights & Agreement Rules · Context

Named Aetna companies are data controller for their insurance policies

The notice says Aetna International, Inc. and Aetna Life Insurance Company are considered the data controller for personal data processed in relation to health plans written under its insurance policies.

Supporting quotations

Aetna International, Inc., Aetna Life Insurance Company are considered the data controller for personal data processed in relation to health plans written under its insurance policies.

Qualifications & exceptions

  • The controller statement refers to "health plans written under its insurance policies."

Not stated here

  • The scope statement covers plans "underwritten or administered" by these companies, but the controller statement mentions only plans written under insurance policies; the notice does not say who is the controller for administered plans that are not written under its policies.
  • The notice does not explain what being the controller means for the member beyond the rights and contact details later in the notice.

Legal Rights & Agreement Rules · Context

Notice effective October 1, 2025

The notice states that it becomes effective October 1, 2025.

Supporting quotations

This Notice will become effective October 1, 2025.

Not stated here

  • The notice does not say whether it replaces an earlier version.

Legal Rights & Agreement Rules · Company commitment

Required disclosures: to you or your representative and to the U.S. HHS Secretary

Aetna says it must use and disclose your personal information to you or someone with the legal right to act for you (your personal representative) in order to administer your rights under the notice, and to the Secretary of the 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

  • Disclosure to the HHS Secretary is "as necessary" for HIPAA compliance and enforcement.

Legal Rights & Agreement Rules · Company commitment

Written authorization needed outside the described uses and disclosures

The notice says that in all situations other than those it describes, Aetna will ask for your written authorization before using or disclosing information about you. Its examples are marketing purposes that are unrelated to your benefit plan(s), disclosing any psychotherapy notes, and other reasons required by law.

Supporting quotations

In all situations other than those described above, we will ask for your written authorization before using or disclosing Information about you. For example, we will get your authorization:
For marketing purposes that are unrelated to your benefit plan(s),
Before disclosing any psychotherapy notes, and
For other reasons as required by law.

Qualifications & exceptions

  • The authorization requirement applies to situations "other than those described above," and the earlier lists of uses and disclosures are open-ended ("including, but not limited to").
  • The marketing example is limited to marketing "unrelated to your benefit plan(s)."

Not stated here

  • The notice does not list every situation that falls outside the described uses and disclosures.

Legal Rights & Agreement Rules · Restriction or exception

Stricter laws may limit use of sensitive health information

The notice says some state and federal laws may require special privacy protections, including requirements to obtain attestations from requestors, that limit the use and disclosure of certain sensitive health information. It lists 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 and sexually transmitted diseases. Where it applies to Aetna, Aetna says it will follow the law that is stricter or more protective of your PHI. For more information, contact the Aetna Privacy Office.

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.
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
We will follow the law that is stricter (or more protective of your PHI), where it applies to us.
please contact the Aetna Privacy Office.

Qualifications & exceptions

  • Stated as laws that "may" require protections; applies only where such a law applies to Aetna.
  • Aetna follows the stricter law "where it applies to us."

Not stated here

  • The notice does not identify the specific laws or say how these limits change the uses and disclosures described earlier.

Cross-references

Legal Rights & Agreement Rules · User right or choice

You may complain to the data protection agency without penalty

The notice says you may also have the right to take your complaint to the applicable data protection agency, and that you will not be penalized for filing a complaint.

Supporting quotations

You may also have the right to take your complaint to the applicable data protection agency. You will not be penalized for filing a complaint.

Qualifications & exceptions

  • Stated as "may also have the right," depending on the applicable agency.

Not stated here

  • The notice does not name the agency.

Legal Rights & Agreement Rules · Permission or license

Aetna may change this notice and its policies at any time, for all information it holds

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. The notice also says privacy regulations require Aetna to follow the terms of the notice currently in effect.

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.
to follow the terms of the Notice currently in effect.

Qualifications & exceptions

  • New terms apply to information already held as well as future information.
  • Aetna must follow the notice "currently in effect," which would be the changed version after a change.

Not stated here

  • The notice does not say how members are told about changes.