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PIA National supports protection of sensitive consumer data using a harm trigger and other methods that are flexible, risk-based, and practical for small businesses.

PIA National has been a key voice for independent insurance agents as the National Association of Insurance Commissioners (NAIC) considers the passage of a data security model law. PIA National has been encouraging regulators to clearly define the terms (in the most recent draft, “data breach,” “data breach without use of personally identifiable information,” and “licensee”) used in the model. Additionally, PIA National has been advocating for the interests of independent agents by focusing its feedback on the essential issue of scalability and alerting commissioners to the grave repercussions that could be facing their policyholders if the final draft of the model requires unrealistic actions be taken by small businesses. Most recently, PIA National offered comments in favor of bifurcating the model and addressing only the issue of data security (and not data breach) in the current model draft and recommended caution be exercised in considering the use of the recent New York-promulgated regulation (23 NYCRR 500) as a model for the NAIC.

PIA Letters & Comment