Privacy Activism

Posts Tagged ‘ITS’

Pay as You Drive – Automobile Insurance Comments

Monday, August 10th, 2009

“Pay As You Drive” Automobile Insurance:
Comments on the Need to Guard Personal Privacy

July 9, 2009

Comments submitted to the California Department of Insurance by:
Privacy Rights Clearinghouse
PrivacyActivism

Daniel M. Goodell, Senior Staff Counsel
California Department of Insurance
45 Fremont Street 21st Floor
San Francisco, California 94105
e-mail: PubComments.2008-020@insurance.ca.gov.

RE: Pay-Drive Usage-Based Auto Insurance – File No. REG-2008-00020

Dear Mr. Goodell:

The Privacy Rights Clearinghouse(1)  and PrivacyActivism(2)  appreciate the opportunity to comment on the California Department of Insurance (DOI) proposed amendments to the pay-drive insurance regulations. Both groups are California-based nonprofit organizations.

We direct our comments as follows:

1. Introduction
2. Onboard Technology
3. Secondary Uses of Data – Information Creep
4. Security of Personally Identifiable Information
5. Looking Ahead
6. Conclusions and Recommendations
(more…)