Supplemental Notice of Insurance Information Practices

Last Updated:  February 9, 2024

Printable Version

Thank you for your interest in The Northwestern Mutual Life Insurance Company ("Northwestern Mutual") or the Northwestern Long Term Care Insurance Company ("NLTC"). Privacy has always been important to us, and this Notice should help to clarify how we collect, use, and disclose your information.

Our Family of Companies:

The Northwestern Mutual Family of Companies includes Northwestern Mutual, NLTC, Northwestern Mutual Investment Services, LLC, Northwestern Mutual Wealth Management Company, and members of our Field Sales Force.

Sources and Categories of Personal Information Northwestern Mutual May Collect:

Personal information may be collected directly and indirectly from you and/or any other proposed Insured and/or Payer by Northwestern Mutual and its agent or NLTC and its agent. Information may also be collected from third parties, such as medical professionals, medical care institutions, employers, business associates, friends and personal associates, data brokers and aggregators, consumer reporting agencies, and other insurance companies or insurance support organizations.

The categories of information that we may collect relate to personal identifiers; demographics; professional or employment information; education information; financial information; internet or network activity; profile information; product information; and audiovisual information. Examples of the types of information includes social security number, age, disabilities, cognitive functions, physical, emotional, and mental health status and history, occupation, avocations, driving record, other insurance, your goals, your online behaviors and activities when you interact with our websites or mobile app or when we investigate claims, network activity personal characteristics such as mode of living, reputation, income, policy and account numbers, educational background, school record, criminal history, and the use of alcohol, other drugs and tobacco. Such information will be collected during the factfinding or planning processes, in the application form, by letter, telephone, in writing, electronically, during the online application process, through interviews and referrals, through cookies, pixels and similar technologies, in any medical exams or tests required by Northwestern Mutual or NLTC, during interactions with our call centers, from third-parties such as medical providers, data brokers, insurance support organizations, consumer reporting agencies, research or analytics companies, marketing or media companies, and publicly available information sources, and through other direct contact with you. In some cases, we may request an investigative consumer report from a consumer reporting agency. This type of information would be obtained through interviews with people who know you.

Information obtained from a report prepared by an insurance support organization may be retained by the insurance support organization and disclosed to other persons. Also, other information obtained from third parties is used and disclosed by us as described in this Notice but is subject to the privacy policies of the third party when it originates with the third party and is not collected at the direction of Northwestern Mutual or NLTC.

In some cases, we may ask an insurance support organization or a consumer reporting agency to collect the information we need and submit a report to us. That organization may retain a copy of its report and may disclose its content to others for whom it performs such services. This is done only to the extent permitted by law and with appropriate authorization from you.

Categories and Description of Personal Information Disclosures to Non-Affiliates:

Northwestern Mutual and NLTC regard all your personal information as confidential. However, there are circumstances in which we may disclose any of the above information to other parties who are not part of our Family of Companies to the extent necessary to conduct our business and as permitted by law. You do not have the right to limit this sharing. The types of disclosures that occur as part of our general business practices include:

1. To reinsurers, if they also underwrite the application.
2. To persons or firms which perform business, professional, or insurance services or functions for us, subject to appropriate contractual restrictions on their use of the information.
3. To group policyholders for purposes of reporting claims experience or conducting an audit.
4. To other companies with your authorization to act on your or your employer's application for insurance, reinstatement of policies, change in insurance benefits, or to perform other insurance services.
5. To policyholders for purposes of providing information regarding the status of an insurance transaction.
6. To other insurance companies, support organizations, institutions, or others for the purpose of detecting criminal activity, fraud or material misrepresentation, and/or material nondisclosure.
7. To your attending physician or medical professional or facility to inform you of medical information of which you may not be aware or in response to your request for access to your personal information.
8. Aggregated data regarding age, amount of insurance, and claims experience in statistical form to organizations conducting actuarial, marketing, or other scientific research studies, audits, or evaluations.
9. To MIB, LLC ("MIB").
10. To insurance regulatory authorities.
11. To law enforcement agencies to help prevent or prosecute fraud, or to alert them that unlawful activity may have occurred, for information protection purposes, or as otherwise required or allowed by law.
12. For public health activities, such as the required reporting of disease, injury, birth and death, and for required public health investigations.
13. If we believe you to be a victim of abuse, neglect, or domestic violence, as required by law.
14. To a government oversight agency conducting audits, investigations, or civil or criminal proceedings, if required by law.
15. If required to do so by a court or administrative subpoena or discovery request; in most cases, you will have notice of such release.
16. To law enforcement, as required by law, to report wounds, injuries and crimes.
17. If you are a member of the military, as required by armed forces services.
18. If necessary for national security or intelligence activities.
19. To worker's compensation agencies, if necessary, for your worker's compensation benefit determination.
20. To others as permitted or required by law, or to provide products and services you have requested.
21. To other persons and companies, as directed by you through signed authorization.

Affiliate Sharing Among Our Family of Companies and Your Right to Opt-out of Sharing for Marketing Purposes:

Northwestern Mutual may disclose personal information among our Family of Companies for business purposes and marketing purposes, and NLTC may disclose personal information to Northwestern Mutual for NLTC business purposes other than marketing, without obtaining your prior consent or authorization as allowed by law, and the law does not allow customers to restrict these types of disclosures. We will not disclose personal information among our Family of Companies without your prior consent or authorization when your consent or authorization is required by law and neither Northwestern Mutual nor NLTC share medical information with Northwestern Mutual Investment Services, LLC, or the Northwestern Mutual Wealth Management Company.

You may restrict Northwestern Mutual's sharing of personal information among our Family of Companies for marketing purposes by exercising your right to opt-out. To exercise this right, call 866-950-4644 and when prompted say, "limit sharing."

Adverse Underwriting Decision:

If your application for insurance is declined, if the premium is rated, or if additional benefits applied for are not issued, you have the right to information about the underwriting of your policy. You may have already discussed these reasons with your agent prior to making an application, or new information may have come to light as part of the underwriting process.

Written requests for information must be submitted within 90 business days from the date Northwestern Mutual or NLTC mailed you notification of the underwriting decision. Within 21 business days of the receipt of your written request, we will send you the specific reasons for the underwriting determination, the specific personal and privileged information that supports that determination, and the names and addresses of the institutional sources that provided specific items of information. As permitted by law, we will disclose specific items of medical-record information supplied by a medical care facility or medical professional to the proposed Insured or to a licensed medical professional designated by the proposed Insured. We have the right to refuse to disclose specific items of privileged information if there is reasonable suspicion that the applicant, policyholder or proposed Insured has engaged in criminal activity, fraud, material misrepresentation or material nondisclosure.

Request to Access, Amend, Correct or Delete Your Recorded Personal Information:

You also have the right to learn upon written request the nature and substance of recorded personal information about you in our files, see or obtain a copy of that information, and learn the identity of those to whom we have disclosed the information in the last two years. As permitted by law, we will disclose specific items of medical-record information supplied by a medical care facility or medical professional to the proposed Insured or to a licensed medical professional designated by the proposed Insured. If the information was received from an institutional source, we will identify it. The information developed through MIB and any investigative consumer report must be disclosed following the procedures outlined in the MIB Notice or Fair Credit Reporting Act Notice provided with your application. Information we have collected in connection with or in anticipation of a claim or legal proceeding will not be made available.

You can request to correct, amend, delete, or dispute information in our files which you believe to be inaccurate or irrelevant by submitting a request at https://ConsumerRightsRequest.nm.com/ or by writing to the Privacy Office at the address below. All amendment requests must state the reasons for the amendment / correction request. Should you request an amendment to your information, please understand that we will not amend personal information about you that we did not create, unless we are notified of the need for amendment by the entity that created it. For example, requests to amend information in your medical records need to be directed to the medical provider or facility that created the information. Within thirty (30) business days from the date we receive your request, we will correct, amend, or delete the disputed information, or we will notify you that we are refusing your request and give you the reasons for the refusal. If we refuse your request, you can file a statement of disagreement and your reasons, which will become part of your file.

If we alter your file on your request or if you file a dispute, that information will be called to the attention of anyone having access to your file, or who has had access within the prior two years. Any rights a consumer, claimant, or beneficiary may have as described in this notice are not limited by Northwestern Mutual's standard privacy notice or NLTC's HIPAA privacy notice.

For Information Collected to Underwrite Long-Term Care Insurance and Long-Term Care Benefit Riders:

Please see the Notice of Privacy Practices for Protected Health Information on NorthwesternMutual.com that describes how we collect, use and disclose your protected health information, or write to the Privacy Office to request a copy.

Information Security:

We are committed to safeguarding the confidentiality and security of your information. Our policies and practices are designed to ensure that access to personal information is limited to authorized personnel, and we maintain strict measures to protect your privacy. If you wish to have further information regarding our information processing practices or if we can be of help in obtaining information or providing other assistance to you, please write to: