On February 1, the NAIC’s Privacy Working Group’s new privacy model germinated. After months of development, the exposure draft, titled “Insurance Consumer Privacy Protection Model Law #674” (Proposed Model), has finally reached daylight. The Proposed Model is intended to replace existing Model 670 (NAIC Insurance Information and Privacy Protection Model) and Model 672 (Privacy of Consumer Financial and Health Information Regulation). The Proposed Model fertilizes state insurance privacy laws by:
- Seeking to harmonize the various consumer privacy protections put in place in the roughly 30 to 40 years since Models 670 and 672 were developed;