We hope that these FAQs provide the information agents need to understand the new legal obligations for our relationships and the purpose for the DPA. If you have further questions, we invite you to email our dedicated mailbox for this DPA process at firstname.lastname@example.org. Our staff makes every effort to respond to inquiries in five business days.
The Data Protection Addendum (DPA) amends our contracts with our third party service providers, including agents, to include new privacy and cybersecurity requirements. The new requirements stated in the DPA focus on compliance with California Consumer Protection Act (CCPA) and New York Department of Financial Services (NYDFS) Cybersecurity regulations, as well as some other forthcoming laws. The addendum sets expectations for how sensitive Transamerica consumer and business information is processed and protected as required under those laws.
The benchmark for the definition of a “service provider” is (1) whether the third party performs services on behalf of Transamerica, and (2) whether the third party has access to non-public information (customer data). The agent relationship meets that regulatory definition.
Even if you don’t currently have non-public information in your possession, agents still meet the definition of a “service provider”, because they have access to that information.