Life and disability notice of information practices

Aetna / CVS Health · Official agreement

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5 of 42 cards in Data Access & Collection

Data Access & Collection · User right or choice

Right, with very limited exceptions, not to face pretext interviews; Aetna says it does not participate in them

The notice says “you” have the right, with very limited exceptions, not to be subjected to pretext interviews, and the statement carries a footnote mark. After a divider line the notice says “We do not participate in pretext interviews,” which appears to be the text of that footnote. The notice does not define pretext interviews.

Supporting quotations

You have the right with very limited exceptions, not to be subjected to pretext interviews.1
We do not participate in pretext interviews.

Qualifications & exceptions

  • The right is stated “with very limited exceptions.”
  • The footnote statement is about Aetna’s own participation.

Not stated here

  • The exceptions are not described.
  • “Pretext interviews” is not defined.
  • The notice does not say whether anyone other than Aetna, such as an employer or agent, might conduct them.

Data Access & Collection · Context

NPI means identifiable information about an enrolled person; public and aggregate information is excluded

The notice defines “nonpublic personal information” (NPI) as information that identifies an individual enrolled in an Aetna Benefits Plan and relates to the person’s participation in the plan, physical or mental health or condition, provision of health care, employment, or payment of benefits to that person or the person’s beneficiary. NPI does not include publicly available information, or information reported in summarized or aggregate form that does not identify any individual. The rest of the notice’s promises about “NPI” (restricted access, confidentiality, disclosure rules) are tied to this definition.

Supporting quotations

Nonpublic personal information (“NPI”) is information that identifies an individual enrolled in an Aetna Benefits Plan and relates to the person’s participation in the Plan, the person’s physical or mental health or condition, the provision of health care to that person, the person’s employment, or payment of benefits to that person or the person’s beneficiary. NPI does not include publicly available information, or information that is available or reported in a summarized or aggregate fashion but does not identify any individual person.

Qualifications & exceptions

  • The definition covers information that both identifies an enrolled individual and relates to one of the listed subjects; the list is part of the definition, not examples.
  • Publicly available information and non-identifying summarized or aggregate information are outside NPI.

Not stated here

  • The definition speaks of an “individual enrolled in an Aetna Benefits Plan”; the notice does not say whether information about a dependent or beneficiary who is not enrolled counts as NPI, although Sections III and IV mention dependents and beneficiaries.
  • “Publicly available” is not defined.

Data Access & Collection · Company practice

Aetna collects information from you, your employer or plan sponsor, and previous benefits companies

Aetna says it collects information about you and your dependents and beneficiaries that it receives directly or indirectly from you, your employer or benefits plan sponsor, or previous benefits companies. The information arrives through applications, surveys or other forms, in writing, in person, by telephone or electronically. The examples given are name, address, social security number, date of birth, marital status, dependent or beneficiary information, employment information and medical history.

Supporting quotations

Like all benefits companies, we collect the following types of information about you and your dependents and beneficiaries:
Information we receive directly or indirectly from you, your employer or benefits plan sponsor, or previous benefits companies through applications, surveys, or other forms, in writing, in person, by telephone, or electronically (e.g., name, address, social security number, date of birth, marital status, dependent/beneficiary information, employment information, medical history).

Qualifications & exceptions

  • The items in parentheses are introduced by “e.g.,” so they are examples, not a complete list.
  • Applies to information about the member and the member’s dependents and beneficiaries.
  • Some of this information can reach Aetna “indirectly,” for example from an employer or a previous benefits company, rather than from the person.

Not stated here

  • The notice does not say which items are collected for every person versus only some, or how medical history is obtained.

Data Access & Collection · Company practice

Aetna collects information about your relationship and transactions with it, its affiliates, agents and others

Aetna says it also collects information about the person’s relationship and transactions with Aetna, its affiliates, its agents and others. The examples are underwriting and claims information, medical history, eligibility information, payment information, and service request, appeal and grievance information.

Supporting quotations

Information about your relationship and transactions with us, our affiliates, our agents, and others (e.g., underwriting and claims information, medical history, eligibility information, payment information, and service request, appeal and grievance information).

Qualifications & exceptions

  • The examples are introduced by “e.g.,” and are not a complete list.
  • The transactions can be with “others” as well as Aetna, its affiliates and its agents.

Not stated here

  • The notice does not say who “others” are or how information about transactions with them reaches Aetna.

Data Access & Collection · Company practice

Aetna collects information from consumer reporting agencies

Aetna says it collects information it receives from consumer reporting agencies, as one of the three types of information listed in Section III.

Supporting quotations

Information we receive from consumer reporting agencies.

Qualifications & exceptions

  • Listed without examples or limits; the notice does not tie it to a particular purpose.

Not stated here

  • The notice does not say what kind of information consumer reporting agencies supply, when it is requested, or for which plans or decisions.