What information about my use of the supplementary health insurance does my employer see?

Data privacy is one of the most common concerns employees express before activating their supplementary health insurance. The short answer is: The employer sees very little—and what they do see is not personally identifiable.

What the employer actually receives

  • Aggregate usage rate: Roughly the percentage of the workforce that submitted at least one claim in a given year — without identifying individuals
  • Anonymized service distribution: Which service categories (dental care, eyeglasses, alternative medicine practitioners) are used and how often—as statistics, not on a per-person basis
  • Budget utilization rate: The average percentage of the available budget that is spent
  • Status information: Which employees are listed as insured (required for premium billing)

What the employer NEVER receives

  • What specific services an individual employee has used
  • Diagnoses or reasons for treatment
  • Submitted invoices or their amounts
  • Which doctors, alternative practitioners, or therapists were consulted
  • Family member data or the processing of their benefits
  • Pre-existing conditions or health declarations (if required at all)

Background on Data Protection Law

A strict separation between the employer and the insurer is required under data protection law. The GDPR and the professional confidentiality obligations of insurers prohibit the disclosure of individual health data to third parties—including the employer who finances the policy.

The insurer is the controller, as defined by the GDPR, for the processing of health data. The employer acts solely as the policyholder and does not have access to personal performance or diagnostic data.

What Employees Should Keep in Mind

From an employee's perspective, there are two issues related to data protection:

  • Registration: During the onboarding process, personal information is transmitted to the insurer (name, date of birth, and, if applicable, bank account information for reimbursements). The employer provides this information to the insurer.
  • App and Portal: When registering on the insurer’s portal, additional data is collected that is exchanged directly between the employee and the insurer—not through the employer.

Right to information

Employees have the right at any time to request information from the insurer regarding the data stored about them (Article 15 of the GDPR). This request is made directly to the insurer, not through the employer. The response typically includes all stored master data, submitted invoices, reimbursement history, and contract details.

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Related terms

Are employees required to undergo a medical examination?
No, most modern group health insurance policies do not require a medical examination at all. Even employees with pre-existing conditions are accepted without an examination. The requirements are that the insurer’s minimum enrollment threshold is met and that the employer covers the costs. In a few cases—such as very small groups, late enrollments, or family members enrolling outside the enrollment window—a simplified medical examination may apply.
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How do employees submit invoices to bKV?
Employees submit claims directly to the insurer—typically via an app, web portal, or mail. With app-based insurers, reimbursement takes 5 to 10 business days; with traditional paper submissions, it takes 2 to 4 weeks. The employer is not involved in the process and receives no information about individual claims.
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Do I need a pension plan?
A pension plan is not required by law, but it is strongly recommended. It provides legal certainty, prevents disputes over the inclusion or exclusion of individual employees, and protects against discrimination claims under the AGG. For small and medium-sized enterprises (SMEs), 3 to 8 pages are usually sufficient, often in the form of a single-page general commitment from the employer.
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