Yesterday, the Privateness Protections (H) Working Group of the Nationwide Affiliation of Insurance coverage Commissioners (“NAIC”) held its first assembly because the 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 present privateness fashions #670[2] and/or #672[3]? Moreover, a coalition of trade 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 traces of enterprise. The general public remark interval for these questions and the proposed trade draft is 2 weeks, expiring Thursday Could 30. The working group will meet in closed session on June 6 to debate obtained feedback and can convene a public assembly on Wednesday June 12 to debate feedback obtained on the working group’s path ahead.
Final summer time, 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’d not help 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 trade particular issues and at yesterday’s assembly the working group heard a presentation on the state and federal privateness legislation panorama.
Locke Lord will proceed to watch developments on the working group. In case you have any questions, please attain out to the writer or your Locke Lord accomplice.
See additionally final summer time’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 Corporations, and the Affiliation for Impartial Brokers.
[5] A replica was circulated on to individuals. A replica needs to be uploaded to the working group web site imminently.
