California Consumer Privacy Act: What you need to know

The California Consumer Privacy Act of 2018 (CCPA) went into effect on January 1, 2020. The law creates new consumer rights relating to the access to, deletion of, and sharing of personal information that is collected by businesses. It is important for distributors doing business in California to understand the law and its ramifications, and why Zurich may be requesting information from you on behalf of our mutual customers.

CCPA broadens the definition of personal information and gives California residents enhanced rights over their personal information.

Under the law, California residents will have a legal right to:

• Know the information that has been gathered about them and what it is used for
• Know with whom their information has been shared
• Request access to, or copies of, their files
• Correct or amend the contents of their information
• Delete contents of their information under certain conditions

The process by which these rights are exercised by California residents, aka Data Subjects, is known as a Data Subject Request (DSR). Businesses typically must respond to DSRs within 45 days of receipt, and must provide easily accessible, cost-free methods for exercising these rights.

Why Zurich may need information from you

When Zurich receives a DSR, we will contact you, typically via email, identifying the information we need to respond to the request. We will need your timely assistance in responding to DSRs submitted to us by our mutual customers. For example, we may need personal information you may have about a Data Subject, what it is used for, where it is located, what its retention is and with whom such information has been shared.

What to do if you receive a DSR inquiry from a mutual customer

Distributors receiving a DSR may instruct the customer to submit their request via one of the following methods:

• Submit request directly through Zurich’s Data Subject Request portal on zurichna.com.
• Ask you, as the broker, or a power of attorney to submit a DSR request on their behalf via the DSR portal
• Use our toll-free number to contact Zurich North America’s Customer Inquiry Center (800-382-2150). A Zurich representative will use the DSR portal to submit the request.

What is considered personal information under CCPA?

The CCPA applies to any information about an identifiable person residing in California as well as their devices, households and even details about the type of car they drive or their gym membership. Simply put, personal information now includes any information that pertains to an individual (such as resume, dietary restrictions, a workers' compensation claim number, a Producer ID number, etc.).

Questions? Please contact the Zurich North America Information Governance and Privacy Office at privacy.office@zurichna.com.