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)Â and PrivacyActivism(2)Â 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
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