Privacy Compliance Survey

DATE: July 5, 2001 RE: Privacy Compliance Survey NOTE: This bulletin was only addressed to Alabama-domiciled Insurers. As part of this state's efforts to determine general compliance with the new privacy protections mandated by 15 U.S.C. Sections 6801, et seq., being Title V of Public Law 106-102, commonly known as the "Gramm-Leach-Bliley Act", this state is participating in a coordinated privacy compliance survey with other states. This approach is being utilized as an alternative to each state developing its own survey and distributing a state specific survey to each company operating within its jurisdiction. Because this effort is being centrally facilitated through the National Association of Insurance Commissioners, you must access the survey through the NAIC web site. The survey is posted under the "What's New" section on the upper right side of the NAIC home page. Pursuant to this state's examination authority, this survey must be completed in an electronic format via the Internet by Friday, July 27, 2001. Please note the following items as you complete the survey: The survey can only be completed once per company. Multiple responses cannot be submitted to this state or other states. If a group holding company is adopting and implementing a common privacy compliance strategy for all companies within a group, a group holding company may respond on behalf of all or some of its member companies regardless of where the member companies are domiciled. The group holding company must identify, by name and NAIC company code, the companies within the group holding company to which a response applies strategy for all companies within a group, a group holding company may respond on behalf of all or some of its member companies regardless of where the member companies are domiciled. The group holding company must identify, by name and NAIC company code, the companies within the group holding company to which a response applies. Because this survey is being used by multiple states, the survey questions are general in nature and do not reference any state specific privacy statute/regulation. The purpose of the survey is to obtain a general status report regarding your company's compliance plan in your state of domicile as an indicator of your overall privacy compliance in multiple jurisdictions. Based upon the survey results, this state will identify and prioritize what companies should be contacted for further regulatory review to ensure compliance with the privacy protections. Because of this, it is very important that the survey be accurately completed in a timely manner. A copy of this bulletin was also transmitted via electronic mail to all Alabama-domiciled insurers with an E-Mail address on file. In some cases, this may result in insurers receiving more than one notice. All insurers are urged to take steps necessary within their organization to verify that only one response is filed for each insurer. If you have questions, please contact Reyn Norman at Reyn.Norman@insurance.alabama.gov or (334) 241-4119 or Tim Mullen [NAIC staff support for the Market Conduct and Consumer Affairs (D) Committee] at TMullen@naic.org or (816)783-8260.