Notice describes Aetna’s privacy practices for its life and disability plans
The document is titled “Notice of Information Practices” and says it contains important information about Aetna’s privacy practices, asking readers to review it carefully. Its opening says that, to administer its life and disability plans (which the notice calls the “Benefits Plans”), Aetna must collect and disclose nonpublic personal information. Aetna says it treats this information as private and confidential and has policies and procedures to protect it against unlawful use and disclosure. The notice says it describes the types of information Aetna collects, when and to whom it may disclose it, and additional important information. “Aetna” is a defined term: a footnote says it means the Aetna Inc. family of companies, including those doing business as Aetna Life (the footnote continues “Insurance Company.”).
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Notice of Information Practices
THIS NOTICE* CONTAINS IMPORTANT INFORMATION ABOUT AETNA’S PRIVACY PRACTICES.
PLEASE REVIEW IT CAREFULLY.
To effectively administer our life and disability plans (collectively the “Benefits Plans”), Aetna† must collect and disclose
nonpublic personal information. We consider this information private and confidential and have policies and procedures in place to protect the information against unlawful use and disclosure. This notice describes what types of information we collect, explains when and to whom we may disclose it, and provides you with additional important information.
† For purposes of this notice, “Aetna” refers to the Aetna Inc. family of companies, including those doing business as Aetna Life
Qualifications & exceptions
The notice is about the life and disability plans it calls the “Benefits Plans”; it does not say it covers other Aetna products.
“Aetna” is defined for this notice by a footnote as the Aetna Inc. family of companies, “including” those doing business as Aetna Life Insurance Company, so the defined group is broader than that one company.
Not stated here
The notice does not list which companies belong to the “Aetna Inc. family of companies.”
The notice does not say which employer plans or which life and disability products are covered.
Legal Rights & Agreement Rules · Context
Form number GR-68049 (2-25) appears; no effective date is stated
The first page header and the closing line both carry the form identifier “GR-68049 (2-25)”. The header also says “Page 1 of 2”. The text does not state an effective date, issue date or revision history for the notice.
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GR-68049 (2-25) Page 1 of 2
GR-68049 (2-25)
Qualifications & exceptions
The identifier is the only version marker in the text.
Not stated here
The notice does not say what “(2-25)” means, so no effective date is inferred from it.
The notice does not say how this form version relates to earlier or later versions.
Legal Rights & Agreement Rules · Context
Notice is provided for informational purposes only
The notice says it is provided to the member for informational purposes only. This follows its statement that it is not part of the member’s plan documents. The notice does not say what legal or contractual effect, if any, the practices it describes have.
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Schedule of Benefits, Group Insurance Certificate). It is provided to you for informational purposes only.
This Notice is not a part of your Plan Documents (Group Policy, Certificate/Evidence of Coverage, Booklet, Group Agreement,
Qualifications & exceptions
Read together with the previous line, “informational purposes only” is used about this notice, not about the plan documents.
Not stated here
The notice does not say whether the practices it describes are binding commitments or whether the plan documents say anything different.
The plan documents are not supplied here.
Legal Rights & Agreement Rules · Context
“Aetna” means the Aetna Inc. family of companies, including those doing business as Aetna Life Insurance Company
A footnote attached to the word “Aetna” in the opening says that for purposes of this notice, “Aetna” refers to the Aetna Inc. family of companies, including those doing business as Aetna Life Insurance Company. The notice’s “we” and “our” appear to refer to this group; the footnote does not say so in words.
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† For purposes of this notice, “Aetna” refers to the Aetna Inc. family of companies, including those doing business as Aetna Life
Insurance Company.
Aetna†
Qualifications & exceptions
“Including” means Aetna Life Insurance Company is an example of the group, not its only member.
“Affiliates” in Section V is a separate word and is not defined by this footnote.
Not stated here
The notice does not list the companies in the Aetna Inc. family or say whether CVS Health or other parent or sibling companies are inside the definition.
Legal Rights & Agreement Rules · Procedure
Notice is sent at enrollment in insured or full-risk plans, on material change and as required by law
Aetna says it plans to send the notice to members upon enrollment in any of its full risk or insured Benefits Plans, or when it receives their first claim if it does not know their identity at enrollment. It also plans to send it when its confidentiality practices are materially changed and at other times as required by law.
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We plan to send this notice to our members upon enrollment in any of our full risk or insured Benefits Plans (or when we receive their first claim, if we do not know their identity upon enrollment), when our confidentiality practices are materially changed, and at other times as required by law.
Qualifications & exceptions
The wording is “we plan to send,” and the enrollment trigger is stated for full risk or insured Benefits Plans.
Applies to members; employers get updates under a separate sentence.
Not stated here
The notice does not say how members of self-funded plans, which Section V mentions, receive it.
Legal Rights & Agreement Rules · Permission or license
Aetna reserves the right to change the notice; a new notice applies to all NPI it maintains
Aetna reserves the right to change the terms of the notice and to make the provisions of a new notice effective for all NPI it maintains. That includes information collected before the change. Aetna separately says it plans to send the notice again when its confidentiality practices are materially changed.
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We reserve the right to change the terms of this notice and to make the provisions of the new notice effective for all NPI we maintain.
Qualifications & exceptions
The new provisions apply to all NPI maintained, not only information collected after the change.
Sending a new notice is described as a plan tied to material changes.
Not stated here
The notice states no advance-notice period and no way to object to a change.
Legal Rights & Agreement Rules · Procedure
If members believe the policy was violated, they follow plan grievance procedures or call the toll-free number
If a member believes the notice’s policy has been violated with respect to information about the member or the member’s dependents or beneficiaries, Aetna asks the member to follow the grievance procedures described in the plan documents or to call the toll-free customer service number listed in Section I, which is 1-866-825-6944 for Life and Disability.
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If you believe this policy has been violated with respect to information about you or your dependents or beneficiaries, please follow the grievance procedures described in your plan documents or call our toll-free customer service phone number listed in Section I.
*Life and Disability toll free number: 1-866-825-6944
Qualifications & exceptions
Two routes are offered: the plan documents’ grievance procedures, or the phone number.
The notice calls its own content “this policy.”
Not stated here
The plan documents’ grievance procedures are not supplied here, so their steps and deadlines are unknown.
The notice does not name a regulator or any outside body to complain to.
Legal Rights & Agreement Rules · User right or choice
Members have the right to know the reasons for an unfavorable underwriting decision
Under “Other important information,” the notice says “you” have the right to know the reasons for an unfavorable underwriting decision.
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You have the right to know the reasons for an unfavorable underwriting decision.
Qualifications & exceptions
Stated as a right without a stated procedure.
Not stated here
The notice does not say how to ask for the reasons, who “you” is for group coverage (employee, employer or plan member), or how long a response takes.
Legal Rights & Agreement Rules · Context
Coverage may be underwritten or administered by Aetna Life Insurance Company
The notice says coverage may be underwritten or administered by Aetna Life Insurance Company. This is one of the companies the notice’s footnote includes in the defined term “Aetna.”
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Coverage may be underwritten or administered by Aetna Life Insurance Company.
“Aetna” refers to the Aetna Inc. family of companies, including those doing business as Aetna Life
Qualifications & exceptions
Stated with “may,” so it is not a statement that every plan is underwritten or administered by that company.
Not stated here
The notice does not say which plans are underwritten or administered by Aetna Life Insurance Company or by other Aetna companies.
Legal Rights & Agreement Rules · Permission or license
Examples of uses and disclosures: regulatory reporting, subpoenas, fraud reporting, litigation and third-party liability
Aetna lists performing mandatory regulatory compliance and reporting; responding to requests from regulatory authorities; responding to government agency or court subpoenas as required by law; reporting suspected or actual fraud or other criminal activity; conducting litigation, arbitration or similar dispute resolution; and performing third-party liability activities, including administration of social security and workers compensation offsets, and related activities.
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Performing mandatory regulatory compliance/reporting activities; responding to requests for information from regulatory authorities, responding to government agency or court subpoenas as required by law, reporting suspected or actual fraud or other criminal activity; conducting litigation, arbitration, or similar dispute resolution proceedings; and performing third-party liability (including administration of social security and workers compensation offsets), and related activities.
Qualifications & exceptions
Responding to subpoenas is qualified by “as required by law.”
Fraud or criminal reporting covers “suspected or actual” activity.
The list is introduced as examples.
Not stated here
The notice does not say who receives the reports or what limits apply to requests from regulatory authorities that are not subpoenas.
Legal Rights & Agreement Rules · Context
Notice says it is not part of the plan documents
The notice says it is not a part of the member’s plan documents, which it lists as the group policy, certificate or evidence of coverage, booklet, group agreement, schedule of benefits and group insurance certificate. It says the notice is provided for informational purposes only.
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This Notice is not a part of your Plan Documents (Group Policy, Certificate/Evidence of Coverage, Booklet, Group Agreement,
Schedule of Benefits, Group Insurance Certificate). It is provided to you for informational purposes only.
Qualifications & exceptions
The list of plan documents is given in parentheses and continues from this line of the notice into the next.
Not stated here
The notice does not say whether the plan documents or this notice controls if they differ.
The plan documents are not supplied here, so their privacy terms are not known.