Connecticut Insurance Department Issues Guidance on Big Data Use by Insurers | Hinshaw Privacy & Cyber Bytes - Insights on Compliance, Best Practices, and Trends


The State Department of Connecticut has issued a notice reminding all companies and individuals licensed by the department to use technology and big data responsibly and transparently, and in full compliance with federal and state anti-discrimination laws.

Given the potentially transformative nature of big data, the department reiterated regulatory concerns on the following three general issues:

  1. Internal data provision: How big data is used by insurers as a precursor or part of algorithms, predictive models, analysis processes, data collection, product design, marketing, sales, management, rating and underwriting activities, regardless of whether the parties use their data or have their own algorithms and / or processes for the joint development of algorithms, models or processes from third-party developers or providers.


    The department defined the big data ecosystem as broad, diverse, and rapidly evolving from a variety of sources including consumer intelligence, social media, credit and alternative credit information, retail history, geo-location tracking and telematics, cellular, satellite, behavioral monitoring, psychographic , biographical, demographic and firmographical data, sensors, wearable devices and RFID.

  2. Internal data management: Governance of big data throughout the precursor to its use in the insurance industry, where that data resides and is used in the insurance industry, and how that data is then transferred to industry archives, offices, data monetization mechanisms, or additional processes inside or outside the insurance industry Ecosystem.


    The department also emphasized the importance of data accuracy, context, completeness, consistency, timeliness, relevance and other critical factors for responsible and secure data management.

  3. Risk management and compliance: How big data algorithms, predictive models and various processes are inventoried, risk assessed / classified, risk management, validated for technical quality and controlled throughout their life cycle in order to achieve mandatory compliance.

Due to the transient nature of big data usage, the department provided guides with examples of the types of information it can request during audits specific to data broker usage, with an explicit focus on data source, storage , Curation and documentation.


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