This notice describes how medical information may be used and disclosed and how you can get access to it
The notice opens with a capitalized statement that it describes how medical information about you may be used and disclosed and how you can get access to this information, and asks you to review it carefully. Blue Shield of California says it understands the importance of keeping your personal information private and takes its obligation to do so very seriously.
Supporting quotations
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
At Blue Shield of California, we understand the importance of keeping your personal information private, and we take our obligation to do so very seriously.
Legal Rights & Agreement Rules · Company commitment
Blue Shield says the law requires this notice and that it is bound by the notice for all records containing your PHI
Blue Shield says federal and state law require it to give you this notice of its legal duties and privacy practices for your PHI, to maintain the privacy of your PHI, and to notify you if you are affected by a breach of unsecured PHI. It says that when it uses or discloses your PHI it is bound by the terms of the notice, and that the notice applies to all records it creates, obtains, and/or maintains that contain your PHI.
Supporting quotations
We are required by federal and state law to provide you with this notice of our legal duties and privacy practices as they relate to your PHI.
We are required to maintain the privacy of your PHI and to notify you in the event that you are affected by a breach of unsecured PHI.
we are bound by the terms of this notice, which applies to all records that we create, obtain, and/or maintain that contain your PHI.
Not stated here
This passage does not name the federal and state laws it refers to.
Legal Rights & Agreement Rules · Context
Blue Shield of California is an independent member of the Blue Shield Association; two form codes appear
One line states that Blue Shield of California is an independent member of the Blue Shield Association and carries the code A52389XLB_0125. A second line reads "H2819_25_077A_C Approved 02252025". The notice does not explain what the codes mean or how that approval line relates to the effective date given at the end of the notice.
Supporting quotations
Blue Shield of California is an independent member of the Blue Shield Association A52389XLB_0125
H2819_25_077A_C Approved 02252025
Not stated here
What the form codes mean is not stated.
How "Approved 02252025" relates to the effective date of 05/21/2025 stated at the end of the notice is not explained.
Legal Rights & Agreement Rules · User right or choice
You can ask for a paper copy of this notice at any time
You can ask for a paper copy of this notice at any time, even if you agreed to receive the notice electronically. Blue Shield says it will provide you with a paper copy promptly.
Supporting quotations
Get a copy of this privacy notice
You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.
Not stated here
"Promptly" is not tied to a number of days.
Legal Rights & Agreement Rules · User right or choice
You can raise questions or complaints about your privacy rights with Blue Shield
Under a heading about filing a complaint if you feel your rights are violated, Blue Shield says that if you have questions about your privacy rights or feel it has violated them, you may contact it. The contact details for the Blue Shield Privacy Office follow in the next part of the notice.
Supporting quotations
File a complaint if you feel your rights are violated
If you have questions about your privacy rights or feel we have violated your privacy rights, you may contact us at:
Legal Rights & Agreement Rules · Procedure
Privacy Office contact details for questions or complaints about your privacy rights
If you have questions about your privacy rights or feel Blue Shield has violated them, you may contact the Blue Shield of California Privacy Office by mail at P.O. Box 272540, Chico, CA 95927-2540, by phone at (888) 266-8080, on its hotline at (855) 296-9086, by fax at (800) 201-9020, or by e-mail at Privacy@blueshieldca.com.
Supporting quotations
File a complaint if you feel your rights are violated
If you have questions about your privacy rights or feel we have violated your privacy rights, you may contact us at:
Legal Rights & Agreement Rules · User right or choice
You can also file a complaint with the federal Office for Civil Rights
You can file a complaint with the Secretary of the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Room 509F HHH Bldg., Washington, D.C. 20201, calling (877) 696-6775, emailing OCRComplaint@hhs.gov, or visiting the complaints page at www.hhs.gov/ocr/privacy/hipaa/complaints/.
Supporting quotations
You can file a complaint with the Secretary for the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Room 509F HHH Bldg., Washington, D.C. 20201, calling (877) 696-6775, emailing OCRComplaint@hhs.gov, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/.
Legal Rights & Agreement Rules · Company commitment
Blue Shield says it will not retaliate against you for filing a complaint
Blue Shield says it will not retaliate against you for filing a complaint.
Supporting quotations
We will not retaliate against you for filing a complaint.
Not stated here
The sentence does not say whether this covers complaints made to Blue Shield, to the federal Office for Civil Rights, or both.
Legal Rights & Agreement Rules · Restriction or exception
Blue Shield says your health information cannot be used to investigate or penalize lawful reproductive health care
Under a list of health information Blue Shield says it may not use or share without your written authorization unless otherwise allowed by law, the notice states that your health information cannot be used or disclosed to conduct any criminal, civil or administrative investigation of, or impose liability on, you or anyone else, or to identify you or anyone else in connection with seeking, obtaining, providing or facilitating reproductive health care. This applies where that care is lawful under Federal law and the law of the state in which it is provided. Reproductive health care includes, but is not limited to, abortion-related services. The notice describes an exception for a lawful attestation in the example that follows.
Supporting quotations
Are there instances when we will not share your health information? We are not allowed to use or share the following types of health information without your written authorization unless otherwise allowed by law:
Reproductive health care
Your health information cannot be used or disclosed to conduct any criminal, civil, or administrative investigation or impose any liability on you or anyone else, or identify you or anyone else in connection with seeking, obtaining, providing, or facilitating reproductive health care, provided that the reproductive health care is lawful under Federal law and the law of the state in which the reproductive health care is provided. Reproductive health care includes, but is not limited to, abortion-related services.
Qualifications & exceptions
Applies only if the reproductive health care is lawful under Federal law and the law of the state in which it is provided.
The lead-in says these types of information may not be used or shared without written authorization "unless otherwise allowed by law".
An exception for a lawful attestation is described in the example that follows.
Not stated here
The bullet itself does not mention written authorization or any other exception; the lead-in and the example do.
Legal Rights & Agreement Rules · Restriction or exception
Substance use disorder records are not used against you in proceedings without authorization or a qualifying court order
Blue Shield says any substance use disorder treatment records will not be used or disclosed in civil, criminal, administrative or legislative proceedings against you unless you give written authorization, or unless a court orders the disclosure after giving you notice and an opportunity to object and the order is accompanied by a subpoena or other legal requirement compelling disclosure. Its example is a lawsuit in which someone asks for your substance use disorder treatment records: it will not provide them unless you tell it to in writing or a court orders it and issues a legal document requiring it.
Supporting quotations
Substance use disorder treatment
Any substance use disorder treatment records will not be used or disclosed in civil, criminal, administrative, or legislative proceedings against you unless you give written authorization, or unless a court orders the disclosure after giving you notice and an opportunity to object and the order is accompanied by a subpoena or other legal requirement compelling disclosure.
Example: If you are involved in a lawsuit and someone asks us for your substance use disorder treatment records, we will not provide them unless you tell us to in writing or a court orders it and issues a legal document requiring it.
Qualifications & exceptions
The rule concerns use or disclosure in proceedings against you.
A court order must follow notice to you and an opportunity to object, and be accompanied by a subpoena or other legal requirement compelling disclosure.
Not stated here
The passage addresses proceedings against you; it does not say here how these records are treated for other purposes, which an earlier passage says need written authorization except as expressly allowed by law.
Legal Rights & Agreement Rules · Company commitment
Blue Shield says it will obey privacy laws, including HIPAA and California law, and special laws for sensitive data
Blue Shield says it will obey any and all laws that require it to give you privacy protections, including HIPAA and any other federal or California privacy law. It notes there are special laws that protect some types of health information, such as, but not limited to, psychotherapy notes, reproductive and sexual health information, gender affirming care, mental health services, treatment for substance use disorders, genetic information, and HIV/AIDS testing and treatment, and says it will follow those laws.
Supporting quotations
We will obey any and all laws that require us to give you privacy protections, including HIPAA and any other federal or California privacy law. For example, there are special laws that protect some types of health information, such as, but not limited to, psychotherapy notes, reproductive and sexual health information, gender affirming care, mental health services, treatment for substance use disorders (SUD), genetic information, and HIV/AIDS testing and treatment. We will follow those laws.
Qualifications & exceptions
The list of specially protected types of information is introduced by "such as, but not limited to" and is illustrative.
Not stated here
The special laws are not named or described.
Legal Rights & Agreement Rules · Company commitment
Where federal and California standards differ, Blue Shield applies the one that gives your information more protection
Blue Shield says that to the extent federal and California privacy laws set different standards for certain health information, it will apply the standard that gives your health information the greater degree of protection and security, unless otherwise required by law. It adds that any disclosure of PHI beyond the provisions of the law is prohibited.
Supporting quotations
To the extent federal and California privacy laws set forth different standards for certain health information, we will apply the standard that affords your health information the greater degree of protection and security, unless otherwise required by law. Any disclosure of PHI beyond the provisions of the law is prohibited.
Qualifications & exceptions
The greater-protection rule applies "unless otherwise required by law".
It applies to "certain health information" where the two standards differ.
Legal Rights & Agreement Rules · Company commitment
Blue Shield says it must follow the duties and privacy practices in this notice and give you a copy
Blue Shield says it must follow the duties and privacy practices described in this notice and give you a copy of it.
Supporting quotations
We must follow the duties and privacy practices described in this notice and give you a copy of it.
Legal Rights & Agreement Rules · Context
The notice points to a federal web page for more information on notices of privacy practices
At the end of its responsibilities section the notice points to a web page of the U.S. Department of Health and Human Services for more information. That page is a link only and its content is not part of this source.
Supporting quotations
For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.
Not stated here
The linked page is not supplied, so its content is not part of this analysis.
Legal Rights & Agreement Rules · Permission or license
Blue Shield can change the notice and the changes apply to all information it has about you
Blue Shield says it can change the terms of the notice and that the changes will apply to all information it has about you. It says the new notice will be available on request and on its website, and that it will mail a copy to you.
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Changes to the Terms of This Notice
We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, on our web site, and we will mail a copy to you.
Qualifications & exceptions
Changes apply to all information Blue Shield has about you, not only information collected after the change.
Not stated here
No notice period before a change takes effect is stated, and the notice does not say when the copy will be mailed.
Legal Rights & Agreement Rules · Context
This notice states an effective date of 05/21/2025
The notice states its effective date as 05/21/2025. An earlier line carries the text "Approved 02252025", and the notice does not explain how the two relate.
Supporting quotations
Effective Date of this Notice: 05/21/2025
Not stated here
How the effective date relates to the earlier line "Approved 02252025" is not explained.
Legal Rights & Agreement Rules · Procedure
The notice repeats the Privacy Office mailing address, phone, hotline, fax and e-mail at its end
The notice ends by repeating the contact details of the Blue Shield of California Privacy Office: P.O. Box 272540, Chico, CA 95927-2540, phone (888) 266-8080, hotline (855) 296-9086, fax (800) 201-9020 and e-mail Privacy@blueshieldca.com.
Supporting quotations
Blue Shield of California Privacy Office P.O. Box 272540 Chico, CA 95927-2540 Phone: (888) 266-8080 Hotline: (855) 296-9086 Fax: (800) 201-9020 E-mail: Privacy@blueshieldca.com