California Department of Insurance Sponsors Privacy Legislation

The California Department of Insurance is sponsoring Senate Bill 354 (Limon), the Insurance Consumer Privacy Protection Act of 2025 (ICPPA).   

​The legislation, which would cover title insurance licensees and their third-party service providers, is ostensibly intended to “establish a modern privacy rights framework for insurance licensees.” The bill would not repeal the existing insurance privacy law enacted in 1980 as the Insurance Information and Privacy Protection Act (IIPPA), which exempts title insurance.

CLTA has expressed opposition to the measure unless it is amended to continue the exemption for title insurance under current law on the basis that the title industry’s use of personal and publicly available information differs substantially from that of other lines of insurance, and that the bill would have significant detrimental effects on the real estate industry in California.

Senate Bill 354 covers a wide array of privacy practices, including the establishment of consumer rights relating to personal and publicly available information, oversight of third-party service providers, data minimization, record retention and deletion, opt-in standards and limits on sensitive personal information, among many others. The proposal also imposes obligations with respect to notices to consumers and adverse underwriting decisions.

In addition to opposition from CLTA, the legislation is opposed by a wide array of insurance industry organizations, which assert that the bill poses significant challenges for insurers and, in some instances, could have unintended negative consequences for consumers.