How long does my insurer keep my health scan results from my home computer?

When an applicant completes a contactless vitals scan from a laptop or phone at home, the decision arrives in minutes, but the data behind that decision does not disappear when the policy is issued. For the consumer, the question is simple and personal: how long does my insurer keep my health scan results from my home computer? For the compliance officer and chief medical officer reading the same question, the honest answer is more layered. There is no single number. How long insurance keeps health scan data is governed by an overlapping set of federal privacy rules, state insurance codes, model laws, and the carrier's own retention schedule, and the gap between what consumers assume and what carriers actually do has become a live regulatory risk.

Under HIPAA, covered entities must retain compliance documentation such as policies, risk analyses, and authorizations for a minimum of six years, while medical record retention itself is set by state law and can range from five to thirty years. Source: U.S. Department of Health and Human Services, HIPAA Administrative Simplification, 45 CFR 164.316.

How long insurance keeps health scan data: the layered answer

The retention clock for a home-collected health scan is not set by one authority. It is set by whichever obligation runs longest for a given data element, and those obligations rarely align neatly.

Three distinct timelines usually apply to a single scan:

• The underwriting record itself, which includes the scan output, derived vital signs, and the decision rationale, governed primarily by state insurance record retention statutes.
• The compliance and authorization documentation, including the consumer consent capturing how the scan would be used, governed under HIPAA's six-year documentation rule and, in some states, parallel health privacy statutes.
• The raw biometric source data, such as facial video frames used to derive vitals, which increasingly falls under biometric-specific and consumer health privacy laws with their own minimization and deletion expectations.

A carrier may legitimately need to keep the underwriting decision for many years to defend a contestability claim, while simultaneously being obligated to delete or de-identify the raw facial video much sooner under a data minimization principle. Treating all three as one undifferentiated bucket is where governance programs fail an examination.

What the source rules actually say

The table below summarizes the principal frameworks that determine how long insurance keeps health scan data, and what each one actually requires.

Framework	What it covers	Retention signal	Practical effect on scan data
HIPAA (45 CFR 164.316)	Compliance documentation, authorizations, risk analyses	Minimum 6 years from creation or last effective date	Consent and use documentation for the scan kept at least 6 years
State insurance record retention codes	Underwriting and claims records	Commonly 5 to 10+ years after policy termination	Decision record and supporting data held through contestability and audit windows
State medical record laws	Health records held by covered entities	5 to 30 years depending on state	Derived health values may inherit longer state minimums
NAIC Insurance Data Security Model Law (#668)	Nonpublic information including biometric records	Defined retention and destruction schedule; cybersecurity event records 5 years	Carrier must set and justify a schedule, not retain indefinitely
Washington My Health My Data Act (2024)	Consumer health data, broadly defined	Consumer authorizations retained 6 years; deletion rights apply	Raw biometric inputs subject to deletion requests and minimization

The pattern that emerges is not a fixed expiration date but a duty to define one. The NAIC Insurance Data Security Model Law, adopted in 2017 and now enacted in a majority of states, explicitly includes biometric records within its definition of nonpublic information and requires each licensee to maintain a schedule for retention and a mechanism for destruction when the data is no longer needed. The model does not pick the number for you. It makes the absence of a documented, defensible number a finding.

Industry applications for governance teams

For compliance and medical leadership, the consumer question reframes into an operational mandate: prove that every category of scan data has a stated retention period, a legal basis, and a destruction trigger. The insurtech regulatory framework around contactless health collection rewards specificity and punishes vagueness.

Mapping retention to data category

The most defensible programs separate scan data into tiers rather than applying a single policy. A workable structure:

• Raw biometric source (facial video, image frames): shortest retention, often deleted or de-identified after the vital signs are derived and quality-checked.
• Derived physiological values (heart rate, respiration estimates): retained with the underwriting record, governed by insurance and medical record minimums.
• Decision artifacts (model version, score, rationale, reviewer notes): retained through the contestability period and any applicable market conduct examination cycle.
• Consent and disclosure records: retained at least six years under HIPAA documentation rules and longer where state health privacy law extends the window.

Aligning with the insurtech regulatory framework

Carriers operating across multiple states face the strictest-rule problem. When one state requires seven years for medical records and another requires deletion of consumer health data on request, the governance program must reconcile both. The practical resolution is a retention matrix keyed to jurisdiction and data category, refreshed as new state health privacy laws take effect. Washington's My Health My Data Act, effective for most businesses on March 31, 2024, established that consumer health data can include data far broader than traditional medical records, and several states have since modeled similar measures.

Current research and evidence

The regulatory direction is documented and moving. The NAIC's Privacy of Consumer Financial and Health Information Regulation (Model #672) is under active amendment, with drafters targeting a full revised draft by the end of 2025 that introduces updated definitions for biometric and genetic data. Reed Smith's 2025 biometric compliance analysis tracked an expanding set of state biometric laws extending beyond the original Illinois template, several carrying explicit retention-schedule and destruction requirements that reach insurance use cases.

State-level activity reinforces the trend. Gordon Feinblatt's review of 2024 Maryland health care legislation noted Maryland increased its adult medical record retention requirement from five to seven years, a reminder that the floor is rising rather than relaxing. Meanwhile, the NAIC's August 2025 commentary on the Insurance Data Security Model Law reiterated that records supporting cybersecurity event investigations must be retained for at least five years, anchoring a baseline for incident-related scan data.

The evidence points one direction. Regulators are converging on a principle borrowed from data protection law worldwide: retain health data only as long as a documented purpose justifies, then dispose of it through an auditable process. The storage limitation concept, formalized in the EU General Data Protection Regulation, is increasingly the implicit standard examiners apply to U.S. carriers handling home-collected biometric scans.

The future of insurance health data retention

Three shifts are likely to define the next phase of insurance health data governance.

• From fixed schedules to purpose-bound retention. Expect examiners to ask How long data is kept. Why each period maps to a specific legal or business purpose, with raw biometric inputs facing pressure toward early deletion.
• From single-policy retention to tiered lifecycle management. Carriers will increasingly automate deletion of source media while preserving decision artifacts, treating the scan as a pipeline rather than a single file.
• From documentation on request to continuous evidence. The insurtech regulatory framework is moving toward living retention logs that show, on demand, when each data element was created, accessed, and destroyed.

For chief medical officers and compliance leaders, the strategic takeaway is that retention is no longer a back-office records function. It is a front-line examination exposure, and the carriers that win regulatory trust will be the ones that can answer the consumer's plain question with a precise, defensible schedule.

Frequently asked questions

How long does an insurer actually keep a home health scan?

There is no universal figure. Consent and compliance documentation must be kept at least six years under HIPAA, underwriting decision records are typically held five to ten or more years under state insurance codes, and raw biometric inputs increasingly face shorter retention or deletion under state health privacy laws. The applicable period is the longest obligation for each specific data element.

Does HIPAA set the retention period for the scan itself?

Not directly. HIPAA sets a six-year minimum for compliance documentation such as authorizations and risk analyses, but the retention of the health record itself is governed by state law, which can range from five to thirty years.

Can a consumer request deletion of their scan data?

In some jurisdictions, yes. Laws such as Washington's My Health My Data Act grant deletion rights over consumer health data, though carriers may retain certain records where a competing legal obligation, such as contestability or examination requirements, applies. Governance teams must reconcile these competing duties in a documented matrix.

What do regulators expect carriers to document?

Examiners expect a written retention and destruction schedule that names each data category, states its retention period and legal basis, and shows an auditable disposal mechanism. The NAIC Insurance Data Security Model Law treats the absence of such a schedule as a deficiency.

Circadify is building toward this space by helping carriers, reinsurers, and managing general agents operationalize defensible retention schedules for contactless health and biometric data within a documented compliance framework. For deeper compliance guides and regulatory insights tailored to payers and insurers, visit circadify.com/industries/payers-insurance.