Gramm-Leach-Bliley Act (GLBA)
Federal law requiring financial institutions, including insurers, to protect consumer financial information privacy and disclose their data-sharing practices.
FAQs
- Does GLBA apply to independent insurance agents as well as carriers?
- Yes. GLBA applies to all 'financial institutions,' a broadly defined category that includes entities significantly engaged in financial activities. Independent insurance agencies that handle consumer financial information—which includes virtually all personal lines and many commercial lines agencies—are covered by GLBA and must provide privacy notices, honor opt-out requests, and implement information security programs.
- What is 'non-public personal information' under GLBA?
- NPI under GLBA is any personally identifiable financial information that a consumer provides, that results from a transaction with the financial institution, or that the institution otherwise obtains in connection with providing a product or service. This includes insurance applications, claims information, financial account details, Social Security numbers, and data derived from combining public information with non-public information.
- How does GLBA interact with state insurance privacy laws?
- GLBA explicitly preserves states' authority to impose stricter privacy protections for insurance consumers. The NAIC's Privacy of Consumer Financial and Health Information Model Regulation implements GLBA requirements for insurance through state law, often with additions specific to the insurance context. California, Vermont, and several other states have privacy laws more restrictive than the GLBA baseline. Insurance companies must comply with the most stringent applicable law.
Related Terms
Data Breach Notification
Legal requirements obligating organizations—including insurers and agencies—to notify individuals and regulators when personal data is compromised.
State Insurance Department
The state regulatory body with primary authority over insurance regulation—licensing insurers, reviewing rates and forms, and enforcing insurance laws.
Record Retention
Regulatory and legal requirements specifying how long insurers and agents must retain insurance records—policies, claims files, and communications.
AI Model Governance
The policies, procedures, and controls an insurer implements to ensure AI and ML models are accurate, fair, explainable, and regulatory-compliant.
