PIA Comments on Draft NAIC Data Security Model Law

PIA recently commented on the National Association of Insurance Commissioners’ (NAIC) Cybersecurity Task Force’s Preliminary Working and Discussion Draft of its Insurance Data Security Model Law. PIA’s comments expressed reservations about the model law approach generally and expressed concern about the need for a model law that would be passed with the expectation of adoption in some form in each state, in light of the fact that state laws on this subject already exist in 47 jurisdictions. PIA is also aware of potential conflicts between the Preliminary Draft, existing state law, and existing federal law. PIA continues to monitor this important issue and intends to provide verbal feedback on the Preliminary Draft at the forthcoming NAIC National Meeting in New Orleans.