Construction Update: NAIC’s Privacy Protections and Cybersecurity Working Groups Keep Building

Carlton Fields
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Carlton Fields

The NAIC’s privacy protections and cybersecurity working groups have continued their building efforts.

Project 1: New Privacy Model

Construction Stage: Framing.

The NAIC Privacy Protections Working Group has continued framing out its new draft privacy model. With some plumbing and electric installed for sections related to third-party service provider arrangements and consumer rights, it’s clear from discussions that some change orders are needed. As with prior building efforts, there are conflicting visions of what the new privacy model should look like. From the blueprints, it appears likely we will see features such as enhanced disclosure and privacy rights and a greater focus on vendor oversight and contracting. When it comes to the specifics, however, much of what was proposed in the draft sections might not pass inspection.

Project 2: Cybersecurity Event Reporting Portal

Construction Stage: Design.

Among the NAIC Cybersecurity Working Group’s building plans is working with architects to determine how to construct their vision for a Confidential Cybersecurity Event Repository & Portal. The portal seeks to provide licensees with a single reporting mechanism for cybersecurity events.

For both working groups, construction delays are expected.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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