Joint Trade Comments to NAIC re: the Revised Privacy Protections Model Act

Dear Chair Beard, Vice Chair Weyhenmeyer, and Members of the Privacy Protections Working Group:

The undersigned joint trades appreciate the Privacy Protections (H) Working Group (PPWG or Working Group) requesting feedback on the appropriate path forward for the working group to accomplish your charges "to draft a new/revised Privacy Protections Model Act to replace/update NAIC models such as Model #670 and/or Model #672."

Privacy is an important matter, and an insurance-specific approach must accomplish several goals simultaneously: reconcile with the context of the insurance industry, align with the broader landscape for other financial institutions nationally, and consider certain state and federal requirements. More specifically, a privacy model law ultimately developed by the NAIC must be operationally practical, reasonable, and workable. It must ensure that its provisions are integrated and work well together and achieve the intended objective of protecting consumers while allowing licensees to meet their business obligations.

In the May 15 email from PPWG Chair Beard, comments were sought on two questions as a basis for helping the Working Group chart its path forward. To streamline your consideration, we have consolidated our joint trade response.

Download the joint comment letter to read the full text.