Yesterday, the Privateness Protections (H) Working Group of the Nationwide Affiliation of Insurance coverage Commissioners (“NAIC”) held its first assembly for the reason that Spring Nationwide Assembly in March. The working group seeks public touch upon its path ahead because it reconsiders its choices for revising the NAIC’s present privateness framework. A number of choices are being thought of. Firstly, ought to the working group proceed the work it paused final yr on the proposed unitary privateness mannequin #674[1]? Alternatively, ought to the working group revise both or each of the prevailing privateness fashions #670[2] and/or #672[3]? Moreover, a coalition of business commerce associations, ACLI, AHIP, APCIA, NAMIC, and the Huge I[4], submitted to the working group their very own proposed mannequin act revising the preexisting mannequin regulation #672.[5] Presumably, this revised mannequin would change the prior proposed mannequin #674 as a unitary privateness mannequin for all licensed insurance coverage entities and insurance coverage strains of enterprise. The general public remark interval for these questions and the proposed business draft is 2 weeks, expiring Thursday Could 30. The working group will meet in closed session on June 6 to debate acquired feedback and can convene a public assembly on Wednesday June 12 to debate feedback acquired on the working group’s path ahead.
Final summer season, the working group paused its work on draft 1.2 of the proposed unified privateness mannequin act #674 as a number of states publicly introduced that they might not assist the draft. Since then, the working group obtained an extension of its cost to replace the privateness framework and has moved slowly since. As an illustration, over the autumn and winter the working group mentioned with business particular issues and at yesterday’s assembly the working group heard a presentation on the state and federal privateness regulation panorama.
Locke Lord will proceed to observe developments on the working group. You probably have any questions, please attain out to the writer or your Locke Lord companion.
See additionally final summer season’s NAIC’s Work on Privacy Model Grinds On and NAIC Picking Up Steam as it Drafts New Privacy Model.
[1] Insurance Consumer Privacy Protection Model Law (#674).
[2] Insurance Information and Privacy Protection Model Act (#670).
[3] Privacy of Consumer Financial and Health Information Regulation (#672).
[4] American Council of Life Insurers, America’s Well being Insurance coverage Plans, American Property Casualty Insurance coverage Affiliation, Nationwide Affiliation of Mutual Insurance coverage Firms, and the Affiliation for Impartial Brokers.
[5] A replica was circulated on to members. A replica ought to be uploaded to the working group web site imminently.
