For exclusive
use by members of the
Independent Insurance Agents of Maryland, Inc.
[IMPORTANT:
Be sure to read the special IIAM overview regarding the GLB Privacy Information
and understand the issues involved, prior to drafting your sample letter.]
The privacy of the personal information we
collect from customers and potential customers is very important to [fill
in name of agency]. You have received this notice in accordance with federal and
state laws. This notice is to
provide you with our understanding of types of non-public personal information
about you that we may collect, how we use it and how we protect that
information.
I.
Information we collect:
[Instructions: include all that apply]
We collect non-public personal information about you from the following sources:
1. Information
we receive from you on applications for insurance or from other insurance forms
you complete.
2. Information
we receive from the companies we represent which provide insurance policies to
you.
3. Information
from consumer reporting agencies.
4. Information
about your transactions with us, the companies we represent, or (our affiliates)
[use the phrase in parentheses only if affiliated with other agency entities,
that is two agencies under common control]
5. Information
from other sources, such as employers or government agencies.
6. Information from visits from to our website.
The type of information we collect is related to the insurance you request from us and may include your name, address, social security number, driver’s license number, ownership of property, marital status, health information, and other information required to get insurance coverages for you.
II.
Information we may disclose:
[Instructions: without
separate legal advice, we advise you never to disclose non-public personal
information unless under a service agreement or joint marketing agreement.
Choose one of the following:]
[If you have no service agreement or
joint marketing agreement]
We do not disclose any non-public personal
information except as permitted by law.
[If you have either a service
agreement or joint marketing agreement or both]
We may disclose the following types of
information to entities that [PICK ONE: a.
provide marketing services on our behalf; or b. with whom we have joint
marketing agreements; or c. provide marketing services on our behalf and/or with
whom we have joint marketing agreements.]
[Instructions:
Then list the types of information by example, i.e., name, address,
social security number, driver’s license number, property, or the types of
information listed in paragraph I above.]
III.
Information we share with third parties.
[Instructions: We
do not recommend you share non-public personal information with non-affiliate
third parties except as allowed under the service provider or joint marketing
agreements exceptions. Such a
practice will avoid the necessity of providing an opt-out notice.]
A.
[If the agency has no service or joint marketing
agreement and provides no information to non-affiliate third parties.]
We disclose non-public personal information to
non-affiliated third parties only as permitted by law.
[If the agency has service
agreements and/or joint marketing agreements and provides information only for
those purposes.]
We may disclose certain information to
entities with which we have marketing services agreements or to other
institutions with which we have joint marketing agreements.
Such information may include:
[Then list the categories of
information from Section I and give examples, such as name, address, social
security number, etc.]
B.
[If providing information to non-affiliated third
parties not covered by marketing services agreements or joint marketing
agreements, then the agency must also provide the following:] We may share certain non-public personal information about
you with non-affiliated third parties for purposes not exempted by federal or
state law and regulation. You have
the right to instruct us not to share your non-public personal information with
these non-affiliated third parties. If
you wish to instruct us not to share your non-public personal information with
non-affiliated third parties, you may opt-out of those disclosures and instruct
us not to make any disclosures not expressly permitted by federal and state law
and implementing regulations.
IV. Our
procedures to protect your private information.
We restrict access to non-public personal
information to those employees, agents, representatives or parties who need to
know the information in order to provide the insurance products requested by our
customers.
We have policies and procedures that give
direction to our employees, and to agents and representatives acting on our
behalf, regarding how to protect and use non-public personal information.
In addition, we maintain physical, electronic and procedural safeguards
to protect non-public personal information.
----More
detailed sources, such as those published by the Independent Insurance Agents of
America, Inc., are available at www.iiaa.org
and should be reviewed by those agents having further questions or complicated
corporate structures.
----IMPORTANT:
The sample forms are intended to address only the situation, likely to be
encountered in stand-alone agencies, that is, agencies operated as one entity or
multiple agencies operated under common ownership, but involving only insurance
agencies. Any insurance agency that
is affiliated