In April and May, the NAIC Privacy Protections Working Group held the first three of its biweekly calls to discuss its recipe for a new privacy model, “Insurance Consumer Privacy Protection Model Law #674.” During the meetings, the working group considered whether the recipe needed to (a) include, as an ingredient, a private right of action; (b) clarify the HIPAA safe harbor; (c) leave more or less room for “secret sauce” (i.e., revise its confidentiality provisions); (d) revisit its kitchen…
By: Carlton Fields
By: Carlton Fields
