MEMO  
  To: All General Agents  
  From: Ryan Sykes, Vice President, UA General Agency Division
Jim Savo, FLMI, Vice President of Operations, General Manager
Omar Borrego, ESD Director of Recruiting
 
  Re: Consumer Privacy Laws  
  Notice and Effective Date: February 12, 2020  
  Purpose  
  Your agreement with Globe Life And Accident Insurance Company (“Company”) states that you must conform to the rules, regulations, and practices of the Company. At times, you might come into possession of personal information (“PI”) about the Company’s leads, prospects, and policyholders (collectively, “consumer”), such as the application, policy contract, claims, and medical information is highly confidential and is subject to various legal privacy protections. This Consumer Privacy Laws Memo further clarifies the rules, regulations, and practices of the Company regarding consumers’ PI and your obligations under privacy laws with respect to the use, maintenance, and disclosure of PI.  
  New and Existing Applicable Privacy Laws  
  For all resident and non-resident California appointed agents, the California Consumer Privacy Act (“CCPA”) (Cal. Civ. Code 1798.100 – 1798.199), effective January 1, 2020, provide California residents increased transparency into, and control over, how businesses use and share their PI. Specifically, these laws grant consumers privacy rights such as: (i) the right to know what information businesses are collecting about them, (ii) the right to tell a business not to share or sell their PI, and (iii) the right to tell a business to delete their PI (certain exceptions may apply), (collectively, “Consumer Privacy Requests”).  
  The CCPA is applicable to the Company and some of these privacy rights are already available under existing state and federal privacy laws for our policyholders and prospective customers’ PI, including but not limited to (as applicable): the Gramm-Leach-Bliley Act (Pub. L. 106-102), Regulation S-P (17 CFR 248), HIPAA Privacy Regulations (45 CFR Parts 160 and 164, et al.), and other similar laws, as each may be amended from time to time (collectively, “Privacy Laws”).  
  What are your obligations under these Privacy Laws?  
 
  • You agree to not use, sell, retain, disclose, or share PI of any consumer except as necessary to perform the business purposes of the Company, as required by law, or with the prior written consent of the Company; to comply with any and all applicable privacy laws regarding such PI; and to surrender such records to the Company upon request without retaining copies.
  • You agree to take all appropriate and necessary steps to protect and safeguard the privacy and confidentiality of consumer PI data that you have access to, regardless of the source of such data.
  • You agree to not maintain, store, record, or preserve PI data in any medium outside of the systems provided by the Company.
  • You also agree to immediately report to the Company of any breach or unauthorized disclosure of PI.
  • If you receive an inquiry regarding a Consumer Privacy Request directed at the Company, or any similar requests, you should direct the inquiring party to the Company’s toll free number of 1-800-742-6787 and/or the web form at www.globelifeinsurance.com/contact in order to allow the individual to submit their Consumer Privacy Request. To the extent needed, you will also reasonably cooperate to allow the Company to authenticate, record, investigate, process, execute, resolve and respond to all such Consumer Privacy Requests, providing to the Company all information reasonably required as soon as reasonably practicable.
  • Upon the termination, for whatever reason, any right of access to PI will immediately end and you shall immediately return the PI to the Company, or with the Company’s prior permission, destroy all PI.
 
  Certification  
  Please review to make sure that you can conform to these Privacy Laws. If for any reason you cannot meet these obligations, contact us at askcompliance@Globe.Life. Otherwise, we will treat this Consumer Privacy Laws Memo as updating the requirements of your agreement with the Company and your certification of agreeing to such update. If you violate any of your obligations under the Privacy Laws, the Company may terminate your agreement and may consider other penalties or remedies depending upon the severity of the violation.  
  We appreciate your cooperation.  
  Questions/Concerns  
  If you have questions or in the event a policyholder or prospective customer reaches out to you regarding their rights under the Privacy Laws, please contact askcompliance@Globe.Life.  

 
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Sent by Aurea on behalf of United American Insurance Company, Globe Life Insurance Company of New York, and Globe Life and Accident Insurance Company, Employee Services Division.

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