Why would it be? Is Allianz Life a covered entity? If so, why would it depend on the specific CRM being used?

Allianz Life publishes a HIPAA privacy notice at [0], which states:

> This notice applies to individuals who participate in any of the following programs under the closed line of business:

> • Long term care

> • Medical

> • Medical supplemental

> • Hospital income

> • Cancer and disease specific coverage

> • Dental benefits

> The Covered Entity’s actions and obligations are undertaken by Allianz employees as well as the third parties who perform services for the Covered Entity. However, Allianz employees perform only limited Covered Entity functions – most Covered Entity administrative functions are performed by third party service providers.

It sold long term care insurance policies until 2010.

(Disclosure, I happen to have worked at Allianz Life a long time ago, though I have no nonpublic information about any of this.)

[0] https://www.allianzlife.com/-/media/Files/Allianz/PDFs/about...