Is there ever a situation where a commercial policy might cause a company to become subject to the requirements of the financial privacy regulation?
One instance where a commercial policy might trigger the requirements of the financial privacy regulation is when an individual (i.e., not another business) files a claim on the commercial policy. In that situation, the Department would consider the individual claimant to have obtained an insurance service from the commercial policy company for a personal purpose. Therefore, the claimant would be a “consumer” of the company, and the consumer is entitled to the appropriate notices and an opportunity to opt-out before the company may disclose the claimant’s nonpublic personal financial information. However, if the company does not disclose that information, no notice or opt-out requirements in the regulation are triggered.
Related Questions
- Is there ever a situation where a commercial policy might cause a company to become subject to the requirements of the financial privacy regulation?
- Can our insurance company satisfy the notice requirements by posting its privacy policy on its website?
- Are personal excess or umbrella coverages subject to the financial privacy regulation?
