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Ohio Adopts National Association of Insurance Commissioners’ (NAIC) Insurance Data Security Model Law

Data Matters

On December 19, 2018, Ohio adopted the National Association of Insurance Commissioners’ (NAIC) Insurance Data Security Model Law. The Act is designed to “establish standards for data security and for the investigation and notification to the Superintendent of Insurance of a cybersecurity event.”.

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$10,000,000 civil penalty for disclosing personal data without consent

Data Protection Report

The claims related to the company’s sharing personal data without consumer consent and making it very difficult for consumers to cancel their subscriptions to this telehealth service. The order also requires that the company destroy personal data for which it had not received consent and to create a document retention and destruction policy.

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Over-Retention of Personal Data

Data Protection Report

The declining cost of electronic data storage may have caused some company executives to conclude that retaining personal data forever is “cheap.” The matter involved one of France’s largest insurers, SGAM AG2R LA MONDIALE, which was subject to an inspection by the French data protection authority (the CNIL), in 2019.

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NYDFS Imposes Fine of $5 Million on Carnival for Cybersecurity Breaches

Hunton Privacy

(“Carnival”), the world’s largest cruise-ship operator, for violations of the Cybersecurity Regulation (23 NYCRR Part 500) in connection with four cybersecurity events between 2019 and 2021, including two ransomware events. . NYDFS also found that Carnival had failed to implement basic protocols to prevent data breaches.

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Regulatory Update: NAIC Summer 2019 National Meeting

Data Matters

The National Association of Insurance Commissioners (NAIC) held its Summer 2019 National Meeting (Summer Meeting) in New York City from August 3 to 6, 2019. The amended regulation took effect on August 1, 2019, for annuity products and will become effective on February 1, 2020, for life insurance products.

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Regulatory Update: NAIC Spring 2019 National Meeting

Data Matters

The National Association of Insurance Commissioners (NAIC) held its Spring 2019 National Meeting (Spring Meeting) in Orlando, Florida, from April 6 to 9, 2019. The March 7, 2019, exposure drafts of the CFR Model Laws have been revised to address those comments as well as certain other comments received from interested parties.

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Regulatory Update: NAIC Fall 2019 National Meeting

Data Matters

The National Association of Insurance Commissioners (the NAIC) held its Fall 2019 National Meeting (Fall Meeting) in Austin, Texas, from December 7 to 10, 2019. 2019 Revisions to the Credit for Reinsurance Model Law and the Credit for Reinsurance Model Regulation.