Part 1
Lead reactivation
How your list is checked, ranked and worked — what leaves your side, what never does, and the rules your industry adds.
What we take, where it goes, and who sees it.
For agency principals, operations and compliance
Lead reactivation works the quotes your agency has already generated — people who asked for a price on their home, car, life cover or business, were followed up once or twice, and then were not. We rank them by likelihood to book a conversation and work the list from the top, so your licensed agents spend their time on the people most likely to come back.
Every one of those records is regulated: by your state’s insurance privacy and data security rules, by producer licensing and advertising law, and by federal and state telemarketing law. This document sets out, control by control, how the engagement keeps your agency inside those rules — and which decisions stay with you. It is written to be filed with your vendor due diligence, and to answer the questions your carriers will ask.
Sections 02 to 06 are the plain-English part. They show the whole system in pictures, explain the four things the ranking looks at, and follow one example lead from your agency system to your agent’s desk. The sections after them are the detail your compliance contact will check.
01
Commitments
Ten commitments, before the detail
- 01 · Direct identifiers never reach an AI provider — Names, phone numbers, emails, addresses, policy and driver’s license numbers stay in a secure environment. The AI provider sees a random ID and a few short facts, nothing more.
- 02 · Nothing goes out without your approval — A licensed person at your agency approves every template before use, with your carrier’s review where your appointment requires it. Our review sits on top of yours.
- 03 · Every message stays in your records — Outreach goes out in your agency’s name, through your channels, or is logged to your agency system as it is sent. Nothing off the record.
- 04 · No evidenced consent, no text message — Consent, opt-outs, Do Not Call status and quiet hours are checked at the moment of sending. Opt-outs are permanent.
- 05 · Your data serves your engagement only — No model training, no reuse across clients, no sale, no outside enrichment without your written instruction.
- 06 · Breach notice within 72 hours — As soon as possible and no later than 72 hours. Your deadline to the commissioner runs from the day after we tell you, so we tell you fast.
- 07 · Return and destruction, certified — At the end of the engagement your data, including the identity key, is returned or destroyed, and we confirm it in writing.
- 08 · No quotes, no coverage advice — Messages invite a conversation with your licensed agent. No prices, coverage recommendations, comparisons or promises of savings. Health-related leads are never worked.
- 09 · A fee structure your agency chooses — A flat fee or a results-based fee, with how each is treated under producer licensing rules set out in section 14.
- 10 · Evidence on request — Every control here has something you can inspect. We complete your due diligence questionnaire, and your carriers’, during onboarding.
02
The whole picture
The system on one page
The system works in three zones. Names and contact details stay on your side. Our scoring works only with a random ID and a few short facts. The results come back to your side, where your agency approves and sends.
G1 — the agreement and intake review — clears before any data moves. G7 covers retention and destruction.
Dashed gold-edged boxes, marked G1 to G7, are compliance gates. Nothing passes a gate until it clears. Section 03 lists what each one checks.
03
Step by step
From our first conversation to the first message
Seventeen steps in five phases. The gate marks show where a compliance check has to clear before the work moves on.
Onboard (before any data)
- 01 First conversation — How your agency works its quotes today
- 02 Agreement — Roles, purpose, subprocessors, 72-hour notice
G1 - 03 Intake review — Lead sources, consent, privacy notice, carriers
G1 - 04 Secure environment — In your environment, or our workstation
Prepare (on your side)
- 05 Map your stages — Your statuses to eight shared stages
- 06 Check the list — Opt-outs, Do Not Call, claims, health lines
G2 - 07 Swap names for IDs — A random ID; the key stays with you
- 08 Notes into facts — Fixed-list answers; health details removed
G3
Rank (Tez scoring)
- 09 Score — Intent, Opening, Reachability, Fit
- 10 Tier and reasons — A to D, with the top reasons
- 11 Short summary — Why call, and an opening line, checked
G4 - 12 Next step — Channel by consent, and timing
Act (on your side)
- 13 Match back — The ranked list appears in your agency system
- 14 Your approval — Licensed staff approve the wording
G5 - 15 Send — Re-checked at sending; in your name
G6
Learn (ongoing)
- 16 Record outcomes — Booked, quoted, bound; a held-back group
- 17 Improve and report — Your ranking only; results you can check
G7
| Gate | When | What has to be true to pass | Who decides |
|---|---|---|---|
| G1 | Before any data | Signed agreement; your lead sources, consent wording, privacy notice and opt-out records reviewed; your licensed states, lines, carrier advertising rules and fee model confirmed | Your agency and Tez |
| G2 | As the list arrives | Opt-outs, Do Not Call, open claims, complaints, any health-related lead and anyone hostile are set aside and never ranked | Software, on your rules |
| G3 | Before anything leaves your side | Only approved facts cross: no names, contact details, policy numbers, notes, health details, exact figures or exact dates | Software, checked by Tez |
| G4 | After a summary is drafted | No personal data, no prices or coverage claims, nothing the facts do not support | Software, then your agent |
| G5 | Before any outreach | A licensed person at your agency approves the wording and the batch, and your carrier where it requires | Your agency |
| G6 | At the moment of sending | Consent for that channel, Do Not Call, quiet hours in the lead’s time zone, opt-outs | Software, on your channels |
| G7 | Throughout, and at the end | Outcomes kept by random ID, used for your agency only, returned or destroyed at termination | Tez, certified to you |
04
The ranking
How the list is put in order
Every lead is checked first, then looked at through four factors. The factors combine into one score, and the list is sorted by it. The sorting is plain arithmetic, not an AI model, so every score can be explained in a sentence.
| Factor | The question it answers | What it looks at, for an insurance agency |
|---|---|---|
| Intent | How serious were they, and how long ago? | How far they got: quote requested, quote delivered, application started. Time since the last real conversation. Whether they replied before. How many follow-ups have already been tried. |
| Opening | Is there a real reason to get back in touch? | The reason they paused: price, timing, their current carrier. A date they named, such as a renewal or a house closing. Whether it has passed. |
| Reachability | Can we reach them, and are we allowed to? | A working email or phone. Consent on file for each channel. Do Not Call status, and whether the three-month inquiry window has passed. |
| Fit | Can your agency still write it? | A state and line you are licensed and appointed for. Whether the risk fits your carriers’ appetite, as a yes or no only. Whether they want a line you still offer. |
How the ranking gets better
- 01It starts from your team’s experience — Your agents tell us how often each kind of paused quote comes back. Those estimates set the first odds. Until your results come in, the scores are educated estimates, and we say so.
- 02It corrects itself from your results — As quotes are accepted and policies bound or declined, the odds for each reason move toward what actually happened at your agency.
- 03It becomes a model of your agency alone — After about 300 recorded outcomes, the ranking is fitted to your agency’s results. It is never trained on, or pooled with, another agency’s data.
- 04A held-back group keeps us honest — With your agreement, about one lead in ten is held back and not contacted for a set period. Comparing the two groups shows what the outreach actually changed, rather than what would have happened anyway.
05
A worked example
One lead, from your agency system to your agent
Marcus Reed is fictional; his record, a home and auto quote never bound, is shaped like a real one. Follow it through the four cards, left to right and top to bottom.
1 · Your agency record (stays with you)
| Field | Value | Note |
|---|---|---|
| name | Marcus Reed | key table |
| phone | (512) 555-0172 | key table |
| marcus.r@example.com | key table | |
| record ID | PR-0048213 | key table |
| status | Quoted — not bound | becomes a stage |
| note | Liked the bundle; home policy renews in August — call back then | becomes facts |
| premium | $3,140 a year, quoted | becomes a tier |
| last contact | February 11, 2026 | becomes days |
2 · What we receive (leaves your side)
| Field | Value | Note |
|---|---|---|
| ID | s_4Rt8wP1c | random |
| stage | Quote delivered | Intent |
| days since | 237 | Intent |
| reason | Timing | Opening |
| condition | Yes, a renewal · now passed | Opening |
| reach | Email yes · text no consent | Reachability |
| fit | Licensed state yes · lines offered yes | Fit |
| value tier | 2 of 3, only if you opt in | optional |
Never leaves your side: his name, phone, email, record ID, the note itself, the premium figure, exact dates.
3 · What comes back (back to you)
| Field | Value | Note |
|---|---|---|
| ID | s_4Rt8wP1c | |
| score | 74 · tier A | |
| reasons | + named a renewal · + quote delivered · − 237 days since contact | |
| reason line | Quote delivered; paused for a renewal that has now passed. | fixed wording |
| summary | He liked the quote but was waiting for his current policy to renew. That date has passed. A good opener is to ask how the renewal went. | AI, checked |
| next step | Email, Wednesday morning his time |
4 · In your agency system (stays with you)
| Field | Value | Note |
|---|---|---|
| record | Marcus Reed · tier A · 74 | matched back |
| fields | Reason line, summary and next step added to his record | |
| draft | “Hi {first_name}, …” with his name filled in only at sending, signed by your agency | placeholder |
| flags | Text blocked, no consent · Do Not Call check required | G6 |
No text consent on file, so the next step is email. His quote request is over three months old, so a Do Not Call check comes before any call. His agent sees his name here, in your own system, for the first time.
- 01His note became a few facts — “Renews in August” left only as “a renewal, now passed,” worked out on your side. Had the note said “asked about life cover, diabetic,” the health detail would have been removed and the record held for a person.
06
The suggestion
How the “why call” note is written and checked
Each lead comes back with a reason line in fixed wording and a short summary drafted by an AI model, both written only from the facts in card 2 of section 05. The AI writes; it does not decide. The order comes from arithmetic, and your agency approves anything sent.
The four checks at gate G4
- No personal data — The draft may not contain a name, number, email or address. Names appear only as a placeholder, filled in on your side at sending.
- No prices, no coverage claims — No premiums, rates, savings, carrier comparisons, coverage statements or guarantees. The draft invites a conversation with your licensed agent, nothing more.
- Nothing made up — Every statement in the summary must trace back to one of the facts it was given. A statement that does not is treated as a failure.
- Your never-say list — Phrases and topics your agency or your carriers rule out are blocked, on top of the general rules above.
07
Roles
Your agency stays the licensee
Your insurance department enforces privacy under rules built on the Gramm-Leach-Bliley Act and the NAIC’s privacy models. Your agency is the licensee; Tez I Solutions is a service provider under the service-provider exception (Model 672, section 15), on a contract that limits our use to this engagement. Someone who asked for a quote is a consumer under these rules, so the dormant list is covered in full.
| Obligation | Your agency | Tez I Solutions |
|---|---|---|
| Privacy notices and opt-outs | Owns, including the notice sharing with us relies on | Honours your suppression and opt-out lists |
| Approval of communications | A licensed person approves before use; your carrier where required | Submits templates; never alters approved wording |
| Licensed activity | Your licensed staff quote, advise and bind | Never quotes, advises or binds; routes every coverage question to you |
| How leads were obtained | Warrants it in the agreement | Records the consent source and enforces it at send time |
| Security of data we hold | Oversees, with due diligence | Operates the controls in sections 10 and 11 |
| Notice to the commissioner and consumers | Owns, on your state’s clock | Notifies you within 72 hours and supports the investigation |
| Vendor due diligence | Performs and documents, including for carriers | Completes questionnaires and supplies evidence |
| Access and deletion requests | Receives and instructs | Executes within your deadline and confirms |
| Return or destruction | Instructs | Executes and certifies in writing |
The exception assumes your privacy notice reached the consumer, so we check it at intake. In the 27 states and Puerto Rico that have adopted the NAIC Insurance Data Security Model Law (668), you must choose service providers with due diligence and require them to protect your data; most others apply a safeguarding rule based on Model 673.
08
Data
What we take, and what we never take
The least data that lets the list be ranked and worked. Where a figure carries signal, we keep a tier.
| Data | How it is handled | Reaches the AI |
|---|---|---|
| Name, phone, email, postal address | Held only in the encrypted key table on your side; used to address a message at sending. | No |
| Policy and license numbers, VINs, SSN, date of birth, bank details | Excluded from the export. If one appears in a note, the record is quarantined and the value removed. | No |
| Health, medical and underwriting details | Not requested. Removed from notes before they are read; the record is held for a person. | No |
| Quoted premiums, coverage amounts, property values | Only if your agency agrees: turned into a three-level tier on your side. The figure never leaves. | No |
| Quote, contact and renewal dates | Converted to intervals — “8 months since last contact.” | Interval only |
| Lead source, line, stage, status, producer | Kept as categories; producer names replaced with codes. | As categories |
| Call and quote notes | Read on your side and turned into fixed-list answers (section 09). | Fixed-list answers only |
| Consent records and opt-outs | Kept as an append-only history and enforced at send time. | No |
| Claims, credit-based scores, driving records; protected traits | Not requested, not used to rank, not sent. | No |
09
The privacy layer
Where AI sits, and what it sees
| Station | What happens | Holds or sees |
|---|---|---|
| 01 · Your agency — Your agency system | Full records stay here. Only the agreed fields are read. | Holds: everything, as today |
| 02 · Secure env. — Separation, and notes into facts | A local model with no outside connection answers fixed questions about each note. The key lives only here. | Holds: identifiers, key table, notes |
| 03 · Tez scoring — Ranking, then a short summary | Ranking is arithmetic in our own code. Anthropic’s Claude words a summary from the facts. | Sees: random ID, fixed-list facts |
| 04 · Your channels — Approved, then sent | Names filled in on your side; consent checked; sent in your agency’s name. | Holds: the message, as your record |
Notes are the most sensitive part of a record and the most useful. So they are read where they already are, and only short answers leave. Five layers make sure of it.
| Layer | What it does |
|---|---|
| 1 · Field allow-list | Only approved columns are read. Structured identifiers are separated by rule, not by a model’s judgement. |
| 2 · Identifiers stripped first | Phone numbers, emails, policy, license and card numbers, Social Security numbers, amounts, dates and health terms are removed before the local model reads a note. |
| 3 · Fixed questions, fixed answers | The local model answers set questions — why they paused, whether they named a date, which kind of event — by choosing from a list your agency has seen. It cannot write free text; no question asks about health or habits. |
| 4 · Unsure means a person decides | An answer the model is not confident about is not guessed. The record is held for a person to review. The process fails closed. |
| 5 · Final scan | Every record is scanned again before it leaves. A record carrying anything outside the approved fields is held back, not sent. |
10
Where it runs
Two ways to run the secure environment
The secure environment is where identifiable data lives during the engagement, and your agency chooses where it sits. In both options the key table never leaves it, and the AI provider receives only a random ID and fixed-list facts.
| Inside your environment | On a Tez-operated workstation | |
|---|---|---|
| Where raw data sits | Your infrastructure; it never leaves your perimeter | An encrypted workstation operated by Tez, in a separate encrypted volume per agency |
| Access | You control it. We use a named, least-privilege account you can revoke at any time | One named individual, with multi-factor authentication |
| Network | Your controls | Outbound limited to the AI provider and your sending channels |
| Logging | Your logging stack | Access log kept for the engagement, provided on request |
| Notes on life leads | Read in place, like any other note | Stay with you unless your counsel approves (health details; Model 672, section 18) |
| Suits | Agencies with an IT team or managed IT provider | Agencies without capacity to host it |
Workstation standard, when Tez operates it
- Encrypted at rest — Full-disk encryption, plus a separate encrypted volume for each agency’s data.
- Dedicated and locked down — An OS account used only for client data, multi-factor sign-in, screen lock, current patches, endpoint protection.
- No cloud sync — Client data is never stored in a synced folder or consumer cloud backup, and is excluded from sync by configuration.
- Wiped at the end — The agency’s volume is destroyed at termination and the destruction certified in writing.
11
Security and incidents
The controls, and what happens if one fails
| Control | Evidence you can ask for |
|---|---|
| Written information security program, modelled on Massachusetts 201 CMR 17.00 and the NAIC data security model | The program document |
| Encryption in transit and at rest | Configuration record |
| Multi-factor authentication on every account that touches your data | Account inventory |
| Access limited to named individuals, reviewed quarterly | Access list and review log |
| Access to your data logged | Log extract |
| Background check for anyone with access, on your request | Written confirmation |
| Raw data held only for the life of the engagement | Retention schedule |
| Return or destruction within 30 days of termination | Signed certificate |
| Cyber liability insurance, where your contract requires it | Certificate of insurance |
| Written incident response plan, reviewed each year | The plan and its last review |
For agencies licensed in New York, the same controls answer the third-party service provider terms in 23 NYCRR 500.11 — multi-factor authentication, encryption and prompt notice — which apply even under the small-agency exemption.
If something goes wrong
- 01 · Contain — Stop sending, revoke the affected credential, isolate the system.
- 02 · Notify you within 72 hours at the latest — Which records and fields, what window, what we have done. Your deadline to the commissioner starts the day after we tell you.
- 03 · Preserve evidence — Logs, send records and the consent history are kept intact for your investigation and your report.
- 04 · Support your notice, never pre-empt it — Notice to the commissioner and to consumers is your agency’s decision, on your state’s clock. We never contact your customers about it.
12
Advertising and licensing
The rules every message is checked against
Every message goes out in your agency’s name, and your agency stays responsible for it. These are the rules each template is checked against before a licensed person at your agency approves it.
- 01Licensed work stays with licensed people — Selling, soliciting or negotiating insurance needs a producer license (NAIC Model Act, section 3); Florida counts describing coverage or premiums as solicitation. We draft outreach in your name; your licensed staff approve it and answer every question on coverage, price or terms.
- 02Nothing that could mislead — Unfair trade practices laws (NAIC Model 880) bar misrepresenting a policy’s benefits, terms or price. Drafts carry no coverage claims, prices or savings.
- 03Your name and license, where required — Every message identifies your agency. In California, emails about licensed activity carry the license number (Insurance Code 1725.5). Each state’s disclosure rules are confirmed at gate G1.
- 04Carrier approval for life and captive agencies — Life advertising is the carrier’s responsibility as well as yours, with carrier approval before use (NAIC Model 570, section 3). Captive agencies use carrier-approved wording.
- 05No inducements, no replacement — No gifts or prizes for a quote unless your counsel clears it. Nothing urges a lead to replace an existing life policy (NAIC Model 613); that goes to your agent, as do claims and anything health-related.
- 06Fair treatment, and AI your carriers can examine — Fit uses no protected trait or stand-in for one (section 04). The NAIC AI bulletin and Colorado’s SB21-169, which reaches marketing, expect carriers to examine vendors’ AI; we document ours for any carrier that asks.
13
Consent
No evidenced consent, no text message
Insurance marketing is among the most litigated areas of the Telephone Consumer Protection Act — the FCC’s one-to-one consent rule, vacated in 2025, was challenged by an insurance marketing group. The party that sends a message can be liable for it directly, and courts now read the statute for themselves rather than defer to the FCC. So consent is enforced in software at the moment of sending, not left to policy.
- 01 · A consent history, not a checkbox — Each lead’s consent is an append-only record of source, wording, channel and date. Contactability is derived from it, never overwritten.
- 02 · Checked when the message sends — Consent, suppression, Do Not Call and quiet hours are rechecked at sending, not at list-building. Yesterday’s opt-out holds today.
- 03 · Aged and bought leads without evidenced consent — Email, or your agents calling directly — not text. A quote request over three months old is no established business relationship for Do Not Call.
- 04 · Do Not Call and reassigned numbers — Checked against the National Do Not Call Registry and the FCC Reassigned Numbers Database. Results dated and stored.
- 05 · Quiet hours and state law — 8am to 9pm in the lead’s local time, narrower where required. Florida, Oklahoma, Maryland, Washington and Texas SB 140 rules applied by state.
- 06 · Opt-out everywhere, permanently — STOP, a request in any words, or one made to your agent is honoured on every channel and survives any re-import. Email unsubscribes within 10 business days.
14
How we are paid
Two fee models, and how each is treated
We offer two models. Fees are set in conversation and are not in this document. What belongs here is how each model is treated under producer licensing law, which bars paying commission to an unlicensed person for selling, soliciting or negotiating insurance (NAIC Model Act, section 13). Tez I Solutions does not hold an insurance producer or agency license.
Model A: Flat monthly fee
A fixed fee for operating the service. It does not depend on quotes, policies bound, premium or commission.
- Licensing. A fee not tied to any sale is a payment for a service, not a share of commission. It is the model the licensing rules leave room for.
- Limits. It does not license anything: coverage, price and terms stay with your licensed staff, whatever the fee.
- The simplest model to approve, document and explain to a carrier.
Model B: Results-based fee
A share of revenue attributed to reactivated leads, measured from your agency system’s own records.
- Licensing. A payment that depends on policies sold is restricted where the payee is unlicensed. Texas bars a referral fee based on the customer’s purchase (Insurance Code 4005.053). Florida bars purchase-dependent referral fees and limits commission sharing to licensed, appointed agents (626.112, 626.753). New York’s regulator bars fees paid on placement, whether a share or a set amount.
- Offered only where your counsel approves the structure in writing for each state you write in.
15
Subprocessors and contract
Who else touches the data, and what we sign
| Subprocessor | What it holds | When |
|---|---|---|
| Anthropic (Claude API) | A random ID and fixed-list facts only. No names, contact details, notes or exact figures. Not used for training by default under Anthropic’s commercial terms; zero data retention requested where offered; can run through your own cloud provider instead | Every engagement |
| Your agency system and messaging providers | Records and messages, as they do today | Every engagement, under your contracts |
| Messaging provider operated by Tez | Phone numbers and message content | Only if you do not send through your own texting channel, and only with every message logged to your agency system |
| Operator console hosting | Named in your agreement, with what it holds | Where your team uses our console |
The full list is an exhibit to your agreement. We give 30 days’ notice before adding or changing a subprocessor.
What the agreement contains
- Roles and purpose — Your agency as licensee, Tez as service provider; use limited to this engagement, as Model 672, section 15 requires.
- No secondary use — No training, no sale, no reuse across clients, no enrichment without written instruction.
- Security exhibit and 72-hour notice — The controls in sections 09 to 11, as binding terms, including those 23 NYCRR 500.11 asks for.
- Consent warranty — Your agency’s representation of how the leads were obtained, including from lead vendors.
- Privacy requests — Access, correction and deletion within your deadlines, including state privacy laws for data outside their insurance and GLBA exemptions.
- Audit, return and destruction — Reasonable audit and questionnaire rights, for you and your carriers; return or certified destruction at termination.
16
Regulatory map
Each rule, and where it is addressed
| Rule | What it requires here | Section |
|---|---|---|
| GLBA; state insurance privacy rules (NAIC Models 670 and 672) | Service-provider sharing, reuse limits, health information | 07 08 10 15 |
| NAIC Insurance Data Security Model Law (668); safeguarding rule (673) | Security program, vendor oversight, notice to the commissioner | 01 07 11 |
| New York 23 NYCRR Part 500 | Third-party service provider terms, 72-hour notice | 11 15 |
| Producer licensing laws (NAIC Model 218; Texas, Florida, New York) | Licensed activity; no sale-based pay to unlicensed persons | 12 14 |
| Unfair trade practices (NAIC Model 880) | No misrepresentation, no inducements | 06 12 |
| Life advertising and replacement (NAIC Models 570 and 613) | Carrier approval, replacement duties | 12 |
| California Insurance Code 1725.5 | License number in emails | 12 |
| NAIC AI model bulletin; Colorado SB21-169 | Vendor AI documentation; no unfair discrimination | 04 12 |
| TCPA and the FCC Do Not Call rules | Consent, revocation, Do Not Call, quiet hours | 13 |
| State telemarketing laws | State consent and calling-hours rules | 13 |
| CAN-SPAM | Unsubscribe, address, accurate headers | 13 |
| Massachusetts 201 CMR 17.00, New York SHIELD Act | Written security program, encryption | 10 11 |
| State comprehensive privacy laws | Access, deletion, no sale, for data outside their exemptions | 15 |
| NIST IR 8053, SP 800-188 | De-identification practice | 08 09 |
17
References
Every requirement, traced to its source
Each commitment in this document rests on a primary source: a statute, a regulation, an NAIC model, a regulator’s own guidance, or a court decision. NAIC models bind only where a state has adopted them, often with changes. Links were current in October 2026.
| Insurance privacy | Relied on for | Sections |
|---|---|---|
| Gramm-Leach-Bliley Act, 15 U.S.C. 6801–6809, incl. 6805(a)(6) (law.cornell.edu/uscode/text/15/chapter-94) | Federal basis for protecting consumers’ nonpublic information; enforcement for insurance by state insurance regulators | 07 08 |
| NAIC Privacy of Consumer Financial and Health Information Regulation, Model 672 (content.naic.org/sites/default/files/model-law-672.pdf) | Applicants are consumers (4F); service-provider exception (15); reuse limits (13); authorization for health information (18) | 07 08 10 15 |
| NAIC Insurance Information and Privacy Protection Model Act, Model 670 (content.naic.org/sites/default/files/model-law-670.pdf) | Disclosure to a service provider; limits on marketing disclosures of health and personal-habit information | 07 09 |
| NAIC Privacy Protections (H) Working Group, 2026 Summer National Meeting summary (content.naic.org/sites/default/files/national_meeting/2026-sunm-summary-h-ppwg.pdf) | Revised Model 672 exposed for comment on July 24, 2026 | 18 |
| California Consumer Privacy Act, Cal. Civ. Code 1798.100 et seq., incl. 1798.145(e); other state privacy laws’ insurance and GLBA exemptions | Why privacy-request handling covers data outside those exemptions | 15 |
| Data security | Relied on for | Sections |
|---|---|---|
| NAIC Insurance Data Security Model Law, Model 668 (content.naic.org/sites/default/files/model-law-668.pdf) | Vendor oversight (4F); 72-hour notice (6A); deadline from the vendor’s notice (6D) | 01 07 11 |
| NAIC, Implementation of Model 668, status as of August 31, 2026 (content.naic.org/sites/default/files/legal-adoption-map-668-idsm.pdf) | 28 adopting jurisdictions: 27 states and Puerto Rico | 07 |
| NAIC Standards for Safeguarding Customer Information Model Regulation, Model 673 (content.naic.org/sites/default/files/model-law-673.pdf) | Safeguards and service-provider oversight where Model 668 is not adopted | 07 |
| NYDFS, 23 NYCRR Part 500 Cybersecurity Requirements (dfs.ny.gov/cybersecurity/requirements) | Third-party service provider policy (500.11); 72-hour notice (500.17); limited exemption (500.19) | 11 15 |
| Massachusetts 201 CMR 17.00 (mass.gov/regulations/201-CMR-1700-standards-for-the-protection-of-personal-information-of-ma-residents) | Written security program, encryption on laptops and in transit, service-provider contracts | 10 11 |
| New York SHIELD Act, N.Y. Gen. Bus. Law 899-aa and 899-bb | Reasonable safeguards and breach notice for New York residents’ data | 11 |
| Licensing and advertising | Relied on for | Sections |
|---|---|---|
| NAIC Producer Licensing Model Act, Model 218 (content.naic.org/sites/default/files/model-law-218.pdf) | License to sell, solicit or negotiate (3); “solicit” defined (2); no commission to unlicensed persons (13) | 12 14 |
| Texas Insurance Code 4005.053 and 4001.051 (statutes.capitol.texas.gov/Docs/IN/htm/IN.4005.htm) | No referral fee based on purchase; when a referral is not acting as an agent | 14 |
| Florida Statutes 626.112 and 626.753 (leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0600-0699/0626/Sections/0626.112.html) | Solicitation defined; no purchase-dependent referral fee; commission sharing only with licensed agents | 12 14 |
| New York Insurance Law 2116; DFS Office of General Counsel Opinion 07-05-12 (dfs.ny.gov/insurance/ogco2007/rg070512.htm) | No referral compensation to non-licensees upon placement, as a share or a set fee | 14 |
| NAIC Unfair Trade Practices Act, Model 880 (content.naic.org/sites/default/files/model-law-880.pdf) | Misrepresentation, false advertising, rebates and inducements | 06 12 |
| NAIC Advertisements of Life Insurance and Annuities Model Regulation, Model 570 (content.naic.org/sites/default/files/model-law-570.pdf) | Insurer and producer both responsible; approval before use | 12 |
| NAIC Life Insurance and Annuities Replacement Model Regulation, Model 613 (content.naic.org/sites/default/files/model-law-613.pdf) | Duties when a new policy replaces an existing one | 12 |
| California Insurance Code 1725.5 | License number on emails involving licensed activity | 12 |
| AI and fair treatment | Relied on for | Sections |
|---|---|---|
| NAIC Model Bulletin, Use of Artificial Intelligence Systems by Insurers, December 2023 (content.naic.org/sites/default/files/cmte-h-big-data-artificial-intelligence-wg-ai-model-bulletin.pdf.pdf) | Covers marketing; due diligence and documentation for third-party AI (section 4) | 12 |
| NAIC, Implementation of the AI Model Bulletin, August 2026 (content.naic.org/sites/default/files/legal-adoption-map-ai-model-bulletin.pdf) | Which states have adopted the bulletin | 12 |
| Colorado SB21-169, C.R.S. 10-3-1104.9; Colorado Division of Insurance Regulation 10-1-1 (doi.colorado.gov/for-consumers/sb21-169-protecting-consumers-from-unfair-discrimination-in-insurance-practices) | Marketing as an insurance practice; no unfair discrimination through data, algorithms or models | 12 |
| Telemarketing and email | Relied on for | Sections |
|---|---|---|
| Telephone Consumer Protection Act, 47 U.S.C. 227 (law.cornell.edu/uscode/text/47/227) | Consent for marketing texts and calls; statutory damages; sender liability | 13 |
| FCC rules, 47 CFR 64.1200 (ecfr.gov/current/title-47/chapter-I/subchapter-B/part-64/subpart-L/section-64.1200) | Prior express written consent, Do Not Call, the established business relationship (3 months after an inquiry), quiet hours, revocation | 13 |
| National Do Not Call Registry; FCC Reassigned Numbers Database (donotcall.gov · reassigned.us) | The two checks run before any number is contacted | 13 |
| Insurance Marketing Coalition Ltd. v. FCC, No. 24-10277 (11th Cir., January 24, 2025) | Vacatur of the FCC’s one-to-one consent rule | 13 |
| Facebook, Inc. v. Duguid, 592 U.S. 395 (2021); McLaughlin Chiropractic Associates v. McKesson Corp. (U.S. Supreme Court, June 2025) | Scope of the autodialer definition; courts not bound by FCC interpretations | 13 |
| Florida Telephone Solicitation Act, Fla. Stat. 501.059; Texas SB 140 (2025), Tex. Bus. & Com. Code ch. 302 | State rules that treat texts as solicitation, applied by the lead’s state | 13 |
| CAN-SPAM Act, 15 U.S.C. 7701 et seq.; FTC compliance guide (ftc.gov/business-guidance/resources/can-spam-act-compliance-guide-business) | Unsubscribe within 10 business days, physical address, accurate headers | 13 |
| De-identification and AI providers | Relied on for | Sections |
|---|---|---|
| NIST IR 8053, De-Identification of Personal Information, 2015 (nvlpubs.nist.gov/nistpubs/ir/2015/NIST.IR.8053.pdf) | Quasi-identifiers, re-identification risk, why pseudonymization is reversible | 08 09 |
| NIST SP 800-188, De-Identifying Government Datasets, 2023 (csrc.nist.gov/pubs/sp/800/188/final) | Generalization of figures into bands; de-identification as risk reduction | 08 09 |
| NIST SP 800-122, Guide to Protecting the Confidentiality of PII, 2010 (csrc.nist.gov/pubs/sp/800/122/final) | Classifying which fields are identifying and how sensitive each is | 08 |
| Anthropic, Commercial Terms of Service (anthropic.com/legal/commercial-terms) | No training on commercial API inputs and outputs by default | 09 15 |
18
Limits
What this document is not
- 01Not legal advice — Your agency principal and counsel decide how these rules apply to your agency, state by state. This document tells them what we do so they can.
- 02Not a SOC 2 report — We do not hold a SOC 2 attestation. We complete your due diligence questionnaire, and your carriers’, and provide the policies and evidence behind each control instead.
- 03Not a licensed agency — Tez I Solutions does not hold an insurance producer or agency license. We do not sell, quote, negotiate or bind insurance, and we do not advise on coverage.
- 04Not for health lines — Health, Medicare, ACA marketplace, disability and long-term care leads are out of scope. They are set aside at gate G2 and never ranked, drafted for or contacted; a lead who raises one is passed to your agency.
- 05Not permanent — Current as of October 2026. Rules in this area are moving — the FCC’s consent revocation rules, the NAIC’s rewrite of its privacy model, and state adoption of its data security and AI models among them. We review this document at least once a year and whenever a rule it relies on changes.
- 06Not a promise of results — A score says which quotes to work first, not who will buy. Until your agency’s own outcomes are recorded, the odds behind it are estimates drawn from your team’s experience.
Part 2
AI services
How we handle your data inside your AI tools.
AI services puts a standing AI engineer across the AI tools your business already pays for — ChatGPT, Claude, Copilot, Gemini and the AI inside the software you use. We connect those tools to your CRM, inbox, calendar and files, build the workflows that do the repeat work, set up your processes and brand voice inside them, train your team, and look after the accounts. The tools stay yours, under your own contracts with each vendor. That changes how data protection works. In lead reactivation we keep names and contact details away from the AI provider by design. Here, a tool connected to your CRM will see the records it needs to do its job, names included. So the protections in this document are about something else: whose account it is, what each connection can reach, what the vendor's terms allow, who approves a workflow before it goes live, and how our access ends. Sections A1 to A6 are the same for every business we work with. Your industry's page adds sections A7 and A8: what your industry's rules mean for your AI tools, and where those rules come from.
A1
Commitments
Ten commitments, before the detail
- 01 · Your accounts, on business terms — We work only in accounts your business owns, on business plans. Never in a personal or consumer account — ours, yours or an employee's.
- 02 · A named user, never a shared password — You add us as a named user with our own sign-in and multi-factor authentication. We never ask for a shared password, and you should never send one to us by email.
- 03 · The least access that does the job — Each connection reaches only the data its workflow needs. Admin rights are used for set-up tasks, logged, and reduced afterwards.
- 04 · Nothing goes live without your approval — Every connection, workflow and set of instructions is approved by you, in writing, before it is switched on. So is every change to one that is already running.
- 05 · Automated where it is routine, a person in the loop where it is not — Routine, rule-based work can run on its own once you have approved it: sorting and tagging, summaries for your team, filing, and fixed-wording notices such as an appointment reminder from a template you signed off. Anything that needs a decision or a judgement — a reply written for a particular customer, a price, a term, a commitment, or anything your industry's page marks for review — has a person on your side in the loop before it goes anywhere. Each workflow's data sheet (A3) states which kind it is. Where your industry's page requires a person to review every customer message, that rule applies instead.
- 06 · Your data stays in your tools — We build and test inside your workspace. We do not copy your business data into Tez's own AI accounts. Where we need examples outside your tools, we use made-up records.
- 07 · Your data serves your business only — No reuse across clients, no sale, no training of anything by us. Prompts, instructions and workflows built from your material are yours and are not reused for anyone else.
- 08 · Vendor data settings confirmed in writing — During onboarding we read each tool's current data terms, set its controls with you, and give you a written record. We re-check it whenever a vendor changes its terms.
- 09 · Incident notice within 72 hours — As soon as possible and no later than 72 hours, or sooner where your industry's page says so.
- 10 · Access removed, everything handed over — At the end, our access is removed, every credential we created is revoked or rotated, and every workflow is documented and handed over. We confirm it in writing within 30 days.
Evidence on request: every control in this document has a record you can inspect, listed in section A5. If you send us a security questionnaire, we complete it during onboarding.
A2
Accounts and access
Whose accounts, and how we get in
The AI tools, the systems they connect to and the accounts that run them all belong to your business. We are given access to them; we never hold them. That is what makes the work portable: if we part ways, everything keeps running and nothing has to be moved out of our name.
Nothing in this section starts before you have decided to work with us. The first session is a conversation. We do not ask for logins, exports or files beforehand.
Who owns what
| Item | Who owns it | How we handle it |
|---|---|---|
| AI subscriptions and workspaces | Your business — in its name, on its payment method | We administer them for you. If a new tool would genuinely pay for itself, we say so and why, and it goes on your account, not ours. |
| The owner or super-admin role | Your business keeps it, with at least one person on your side who is not us | We take the lowest role that does the work. Admin rights for a set-up task are logged and reduced when the task is done. |
| Our sign-in | A named user for each Tez person, in your directory or invited as a guest | Multi-factor authentication on. No shared logins. Never a password by email, text or chat. |
| Connections — API keys, app authorisations, service accounts | Created in your accounts, owned by you | Each one is named, listed in the access record (A5), scoped to its workflow, and stored where you control it — never pasted into a document or a message. |
| Personal and consumer AI accounts | Their owners | Not used for business work. If the audit finds business work in personal accounts, we tell you and recommend moving it to business seats. We never connect your systems to a personal account. |
How access is set up
- 01 · You decide what we need — We list the systems and the role each one needs, and why. You agree or strike items out.
- 02 · You add us — Usually by adding us as a user, on a call where we walk through it together. A password is never sent.
- 03 · We confirm the safeguards — Multi-factor authentication on, role as agreed, sign-in recorded in the access record.
- 04 · Reviewed every quarter — We go through the access record with you and remove anything no longer needed.
- 05 · Removed at the end — Section A5 sets out how access ends.
Roles
| Obligation | Your business | Tez I Solutions |
|---|---|---|
| Contracts with AI vendors | Holds them; the vendor processes your data under them | Reads the data terms and records them for you (A4) |
| Who on your team uses which tool | Decides | Sets up the seats and permissions you decide |
| Approval of workflows and changes | Approves before anything goes live | Proposes, documents and builds; never switches on without approval |
| Review of customer-facing output | Your people review before sending | Builds the review step into the workflow |
| Industry rules — licensing, records, supervision, privacy notices | Owns them | Builds to them as set out on your industry's page (A7) |
| Security of the access we hold | Oversees | Operates the controls in A5 |
| Notice to customers or regulators after an incident | Decides | Tells you within 72 hours and supports the investigation |
| Privacy requests from your customers | Receives and instructs | Helps find and remove the data in the tools we set up, within your deadline |
Where a state privacy law reaches your business, we act as your service provider or processor for the access we hold, and the agreement says so.
A3
What the tools can see
Connections, scopes, and what stays out
An AI tool connected to one of your systems can see whatever that connection lets it see. An assistant that searches your files can surface anything the person using it is allowed to open — Microsoft says of its own Copilot that it "only surfaces organizational data to which individual users have at least view permissions." So the work starts with permissions, not prompts.
Before anything is connected
- Who can see what — Before an assistant is pointed at a shared drive, inbox or CRM, we review who can open what. Folders that are open to everyone but should not be are fixed first, with your approval.
- One data sheet per workflow — Every workflow gets a written sheet: what it reads, what it writes, who sees the result, and where a person reviews it. You approve the sheet before we build.
- Add-ons are vendors too — A plug-in, connector, custom GPT or agent from a third party is another company handling your data. None is installed without your approval and a record of its data terms.
What a data sheet looks like
Illustration — not real client data.
| Workflow | Reads | Writes | Who sees the result | Human in the loop |
|---|---|---|---|---|
| Morning summary of new inquiries | CRM records created in the last 24 hours: name, source, service asked about, notes | One summary in the office manager's inbox | Office manager | Read before anyone acts on it |
| First-draft reply to a quote request | The single inquiry being answered; your approved reply templates and brand voice | A draft in the shared inbox — never sent | The person replying | Edited and sent by a person |
| Meeting notes to CRM | The transcript of a meeting the attendees agreed to record | A note on the matching CRM record | The account owner | Checked before it is saved |
What stays out by default
Unless your written decision says otherwise, after we have shown you what the vendor's terms and your industry's rules say, these are kept out of every prompt, instruction file and connection:
- Social Security numbers, tax IDs, driver's licence and other government ID numbers
- Full bank account and card numbers
- Passwords, access codes, gate, door and alarm codes
- Health information
- Anything your industry's page (A7) marks as restricted
Where a connection would expose one of these — a folder of scanned IDs, a CRM field holding card numbers — the connection is narrowed to leave it out, or not built.
Before a workflow goes live
| Check | What has to be true |
|---|---|
| Data sheet | Approved by you, in writing |
| Access | The connection reaches only what the sheet lists |
| Test | Run on made-up records, or on a small set of real ones you choose, with the results shown to you |
| Human in the loop | Marked on the data sheet. In place wherever a decision or judgement is involved: a reply written for a particular customer, a price or a term, or anything your industry's page marks for review. Routine, rule-based steps you have approved may run without one |
| Owner | A named person on your side who can pause it |
| Documentation | Written up and stored where you keep it |
AI tools make mistakes. Every workflow is built on the assumption that a draft can be wrong, which is why the review step is part of the design rather than a suggestion.
A4
Model providers and training
What the vendors do with your data, and how we check
When your team or a workflow uses ChatGPT, Claude, Copilot or Gemini, the vendor processes that data under its contract with your business. Tez is not a reseller or partner of any AI vendor, and not a party to those contracts. Whether a vendor trains its models on your data, how long it keeps prompts, whether its staff can review them, and where it processes them are set by the vendor's terms and by the plan you are on. Those terms change. So we do not promise what a vendor will do. We promise what we will do.
What we do
- 01 · List every tool — Each AI tool and AI feature you pay for, the plan it is on, and who holds a seat.
- 02 · Read the current terms — For each one we record what the vendor says about training on your data, retention, human review, where data is processed, and which admin controls exist. Each entry carries the date and the address of the page we read.
- 03 · Set the controls with you — Where a tool offers a choice — training opt-outs, retention periods, chat history, which add-ons are allowed — we recommend the most protective setting that still does what you need, and you decide.
- 04 · Give you the record — The settings record is yours, in writing. Your compliance contact can file it with your vendor reviews.
- 05 · Re-check when terms change — When a vendor changes its data terms, we re-read them, update the record and tell you if anything moved. We also re-check the whole record at least every six months.
What the main vendors said when we checked
Read on each vendor's own page on 6 October 2026. This is the vendor's statement to its customers, not a commitment by Tez. If it changes, the vendor's current terms govern, and we update your record.
| Vendor | What its page said | Where |
|---|---|---|
| Anthropic — Claude, under its Commercial Terms | "Anthropic may not train models on Customer Content from Services." The Commercial Terms cover Anthropic's API and the business offerings that reference them, not its consumer plans. Effective June 17, 2025. | anthropic.com/legal/commercial-terms |
| OpenAI — API | Data sent to the API is not used to train or improve OpenAI's models unless you opt in, as of March 1, 2023. Abuse-monitoring logs are kept for up to 30 days by default. | developers.openai.com/api/docs/guides/your-data |
| OpenAI — ChatGPT business plans | Read during onboarding against OpenAI's published terms for your plan, and recorded the same way. | openai.com/enterprise-privacy |
| Microsoft — Copilot | "Prompts, responses, and data accessed through Microsoft Graph aren't used to train foundation LLMs." Copilot only surfaces data a user already has permission to view. | learn.microsoft.com/en-us/microsoft-365/copilot/microsoft-365-copilot-privacy |
| Google — Gemini in Google Workspace | Your content "is not human reviewed or otherwise used for Generative AI model training outside your domain without permission." | knowledge.workspace.google.com/admin/gemini/generative-ai-in-google-workspace-privacy-hub |
| AI inside your other software | Each vendor's own terms — your CRM, phone system or accounting software. Recorded the same way during onboarding. | Each vendor's data or AI terms page |
Consumer plans and personal accounts
Consumer plans run on different terms from business plans — Anthropic's Commercial Terms, for one, state that they do not cover its consumer offerings. We do not do business work in consumer or personal accounts, and we do not rely on a consumer plan's settings to protect business data.
Our own tools
We use AI tools of our own to write code and documentation. Your business data does not go into them. Anything we build for you is built and tested in your workspace, or against made-up records.
A5
Records, security and incidents
What we keep, how it is protected, and what happens if something fails
Records you can inspect
Records describe what we built and changed. They live in a location your business owns, and they do not contain your customers' data.
| Record | What it holds |
|---|---|
| Access record | Every Tez sign-in and every connection we created: system, role or scope, date added, date reviewed, date removed |
| Settings record | Each tool's plan, data terms as read on a given date, and the controls set (A4) |
| Workflow register | Every live workflow, with its approved data sheet (A3), its owner on your side and its documentation |
| Change log | Every change to a live workflow or connection: what changed, why, when, who approved it |
| Training record | Who was trained, on which tools and processes, and when |
Changes to something already running
Every change to a live workflow is described, approved by you, tested, logged and reversible — the previous version is kept. If a vendor update breaks a workflow, or a workflow starts doing something it should not, we may pause it at once to stop harm, and tell you the same day. We do not change what a workflow does without your approval.
Security controls
| Control | Evidence you can ask for |
|---|---|
| Written information security program, modelled on Massachusetts 201 CMR 17.00 | The program document |
| Multi-factor authentication on every account we use to reach your systems | Access record |
| Access limited to named individuals, reviewed with you quarterly | Access record and review log |
| Tez devices: full-disk encryption, screen lock, current patches, endpoint protection | Configuration record |
| Your data is not stored on Tez devices or in our cloud storage; where a task needs a file locally, it is deleted when the task ends | Written procedure |
| Background check for anyone with access, on your request | Written confirmation |
| Cyber liability insurance, where your contract requires it | Certificate of insurance |
| Written incident response plan, reviewed each year | The plan and its last review |
If something goes wrong
An incident includes a workflow sending or showing data to the wrong person, a connection reaching more than its sheet allows, a suspected compromise of a Tez sign-in, and a vendor incident we learn of that affects your workspace.
- 01 · Contain — Pause the workflow, revoke the affected credential or connection, and stop the exposure.
- 02 · Notify you within 72 hours at the latest — Which systems and data, what window, what we have done. Sooner where your industry's page sets a shorter time. Updates follow as we investigate.
- 03 · Preserve evidence — Logs, the change log and the vendor's audit records are kept intact for your investigation.
- 04 · Support your notice, never pre-empt it — Whether customers or regulators are told is your decision. We never contact your customers about it. A vendor's own incident notice comes to you under your contract with that vendor.
When the engagement ends
| Step | What happens |
|---|---|
| Access removed | Every Tez user and role removed from every system, checked against the access record |
| Credentials ended | Every key, app authorisation and service account we created is revoked, or rotated and handed to you |
| Nothing in our name | Anything that ended up in a Tez name is transferred to you first — by design there should be nothing |
| Handover pack | The workflow register, data sheets, settings record, change log and plain-English run notes, so your team or the next provider can keep it running |
| Written confirmation | Within 30 days of the end of the engagement |
Everything we build is yours — documented and portable. If we part ways, it keeps working and your team knows how it runs.
A6
Limits
What this document is not
- 01 · Not legal advice — Your counsel or compliance officer decides how your industry's rules apply to your business. This document tells them what we do so they can.
- 02 · Not a SOC 2 report — We do not hold a SOC 2 attestation. If you send a security questionnaire, we complete it and provide the policies and evidence behind each control instead.
- 03 · Not the vendor — We do not run the AI vendors' systems or set their terms. Their security, retention, outages and incidents are governed by your contract with them. We are not a reseller, partner or certified provider of any AI vendor.
- 04 · Your obligations stay yours — Using AI tools does not move your duties to us: licensing, supervision, record keeping, privacy notices and your staff's use of AI remain your business's responsibility. We build to them, as your industry's page sets out.
- 05 · Not a promise about AI output — AI tools can be wrong, and confidently so. That is why anything that needs a judgement has a person in the loop, and why no workflow makes a decision your business would otherwise make.
- 06 · Not permanent — Current as of October 2026. Vendor terms and the rules on AI change often. We review this document at least once a year, and whenever a vendor term or rule it relies on changes.
A7
Insurance
What your industry's rules mean for your AI tools
An agency's management system holds nonpublic personal information on every applicant, and often health details too. Insurance regulators oversee how agencies protect it and which vendors can reach it — and some have begun asking how AI is used across the insurance life cycle, marketing included. A second set of rules governs what may be said: discussing coverage is licensed activity, and an AI tool that drafts an answer about a policy is drafting it for a licensed producer. These are the rules that bear on your AI tools, and what we do about each. NAIC models bind only where your state has adopted them.
| Rule | What it means for AI tools | How we handle it |
|---|---|---|
| GLBA; NAIC privacy models 670 and 672 [1][2][3] | Applicants who only asked for a quote are consumers. Information may go to a service provider under contract, but reuse is limited, and health information generally needs the person's authorisation before it is used for marketing. | Health and medical details are kept out of every AI connection used for marketing or outreach. Our use is limited to your engagement, in writing. |
| NAIC Insurance Data Security Model Law (668); safeguarding rule (673) [4][5] | Your agency must oversee third-party service providers, and in adopting states notify the commissioner within 72 hours of determining a cybersecurity event — a clock that can start from a vendor's notice. AI vendors that hold your data are service providers. | Incident notice to you within 72 hours at the latest. The settings record and access record (A4, A5) are written for your vendor oversight file. |
| New York 23 NYCRR Part 500 [6] | DFS-licensed agencies need a third-party service provider policy, multi-factor authentication and 72-hour notice. | Multi-factor authentication on every Tez sign-in. We answer your third-party questionnaire and supply the evidence behind each control. |
| Producer licensing — NAIC Model 218; Texas, Florida, New York [7] | Soliciting or negotiating insurance needs a licence. A chatbot or workflow that discusses coverage, compares policies or quotes terms to a consumer is doing licensed work on your behalf. | AI tools draft; a licensed person at your agency reviews and sends anything that discusses coverage, price or policy terms. No workflow answers coverage questions directly to a consumer. |
| NAIC Unfair Trade Practices Act (880) [8] | No misrepresentation of policy terms, no misleading comparisons, no rebates or inducements. AI tools paraphrase coverage loosely. | Drafts may invite a review or a conversation. Statements about what a policy covers come from carrier-approved wording only. |
| Life advertising and replacement — NAIC Models 570 and 613 [9][10] | Life and annuity advertising may need carrier approval before use, and replacement triggers specific duties. | Life and annuity drafts are routed for your carrier approval process. No workflow suggests replacing an existing policy. |
| California Insurance Code 1725.5 [11] | Emails involving licensed activity must show the licence number. | Your licence number is set in the tools' instructions and every email template for California business. |
| NAIC AI model bulletin; Colorado SB21-169 [12][13] | Addressed to insurers, and they cover marketing. Carriers may ask agencies for documentation of AI used on their business, and Colorado bars unfair discrimination through algorithms. | No AI tool targets or sorts people by race, religion, sex, disability or other protected traits, or proxies for them. We write a short description of each workflow for you to give a carrier that asks. |
In practice
- A workflow may draft a renewal-review reminder from the policy's renewal date and line. A licensed agent reviews it; it never states what the policy covers.
- An assistant may help staff find the right carrier form or procedure. It is not connected to medical underwriting files.
- A meeting-note tool may summarise a review call into your agency system. Health details mentioned on the call are not carried into marketing workflows.
- When a carrier asks how your agency uses AI, the workflow register (A5) gives you the answer in writing.
A8
Sources
Where these rules come from
1. Gramm-Leach-Bliley Act, 15 U.S.C. 6801–6809 — https://www.law.cornell.edu/uscode/text/15/chapter-94 2. NAIC Privacy of Consumer Financial and Health Information Regulation, Model 672 — https://content.naic.org/sites/default/files/model-law-672.pdf 3. NAIC Insurance Information and Privacy Protection Model Act, Model 670 — https://content.naic.org/sites/default/files/model-law-670.pdf 4. NAIC Insurance Data Security Model Law, Model 668 — https://content.naic.org/sites/default/files/model-law-668.pdf · NAIC, Implementation of Model 668 — https://content.naic.org/sites/default/files/legal-adoption-map-668-idsm.pdf 5. NAIC Standards for Safeguarding Customer Information Model Regulation, Model 673 — https://content.naic.org/sites/default/files/model-law-673.pdf 6. NYDFS, 23 NYCRR Part 500 Cybersecurity Requirements — https://www.dfs.ny.gov/cybersecurity/requirements 7. NAIC Producer Licensing Model Act, Model 218 — https://content.naic.org/sites/default/files/model-law-218.pdf · Texas Insurance Code 4005.053 and 4001.051 — https://statutes.capitol.texas.gov/Docs/IN/htm/IN.4005.htm · Florida Statutes 626.112 — https://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0600-0699/0626/Sections/0626.112.html 8. NAIC Unfair Trade Practices Act, Model 880 — https://content.naic.org/sites/default/files/model-law-880.pdf 9. NAIC Advertisements of Life Insurance and Annuities Model Regulation, Model 570 — https://content.naic.org/sites/default/files/model-law-570.pdf
- 01NAIC Life Insurance and Annuities Replacement Model Regulation, Model 613 — https://content.naic.org/sites/default/files/model-law-613.pdf
- 02California Insurance Code 1725.5 (official text at leginfo.legislature.ca.gov)
- 01NAIC Model Bulletin, Use of Artificial Intelligence Systems by Insurers, December 2023 — https://content.naic.org/sites/default/files/cmte-h-big-data-artificial-intelligence-wg-ai-model-bulletin.pdf.pdf · NAIC, Implementation of the AI Model Bulletin — https://content.naic.org/sites/default/files/legal-adoption-map-ai-model-bulletin.pdf
- 02Colorado Division of Insurance, SB21-169 — https://doi.colorado.gov/for-consumers/sb21-169-protecting-consumers-from-unfair-discrimination-in-insurance-practices