Bulletin: SLS2019007

Date:
December 30, 2019
To:
All Issuing Offices
RE:
GENERAL - Privacy of Personal Information; Updated Privacy Notice [Revised 1-2-20]

Dear Associates:

The new sweeping California Consumer Privacy Act (CCPA) law takes effect January 1, 2020. As the CCPA applies to California residents who may conduct business out of state, this bulletin applies to all transactions.

The CCPA may be read in its entirety at https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180SB1121. For further CCPA amendments and updates, please review current legislative information.

The CCPA provides consumers (that are California residents as defined) with significant rights with regard to businesses that collect, maintain and/or sell that consumer’s personal information. If a consumer is deemed a legal California resident, these consumer rights extend to wherever that consumer is conducting business, e.g., a California resident purchasing a vacation home in Colorado. The most relevant consumer rights under the CCPA are: (1) right to access, i.e., learn what personal information was collected by the business in the past 12 months; (2) right to know, i.e., learn what specific categories of personal information that will be collected by the business and purposes for which these categories will be used; and (3) right to deletion, i.e., request the deletion of the consumer’s personal information collected by the business.

The CCPA places significant requirements on businesses that collect, maintain and/or sell personal information of California residents.

In compliance with the CCPA, Stewart has provided a supplemental to include with Stewart’s existing Privacy Policy.

Stewart’s existing Privacy Notice for Stewart owned offices may be found at https://www.vuwriter.com/en/forms/2014-1/FM123554119600000002.html?search=privacy&searchType=allwords.

Stewart’s existing Privacy Notice for use by Independent Agencies and Unaffiliated Escrow Agents may be found at https://www.virtualunderwriter.com/en/forms/2009-3/FM123554119600000000.html

Beginning January 1, 2020, Stewart’s Privacy Policy Notice consists of both the document linked above as well as the new CCPA supplemental. Both documents should be included any time you currently provide Stewart’s Privacy Policy. This supplemental should be provided in all states, NOT JUST CALIFORNIA.

Stewart’s new CCPA Supplemental Privacy Policy is found here

[Supplemental link] [Stewart Privacy Policy with CCPA Supplemental]

These Privacy Notices are not intended to replace or substitute for mandated state specific privacy notices and must be provided in addition to those notices.

For Stewart’s direct operations and affiliated companies, your strict adherence to this bulletin is required.

For Stewart’s independent agents, this bulletin is only intended to provide information regarding the CCPA. If, however, you provide Stewart’s privacy policy in connection with your business you must update Stewart’s privacy policy to include the CCPA Supplement. This bulletin and its attached links are not otherwise intended to require changes to your internal policies or processes.

Please contact Mary Thomas in Stewart’s Legal Services Department at compliance@stewart.com with any questions.

If you have any questions relating to this or other bulletins, please contact a Stewart Title Guaranty Company underwriter.

For on-line viewing of this and other bulletins, please log onto www.vuwriter.com.

THIS BULLETIN IS FURNISHED TO INFORM YOU OF CURRENT DEVELOPMENTS. AS A REMINDER, YOU ARE CHARGED WITH KNOWLEDGE OF THE CONTENT ON VIRTUAL UNDERWRITER  AS IT EXISTS FROM TIME TO TIME AS IT APPLIES TO YOU, AS WELL AS ANY OTHER INSTRUCTIONS. OUR UNDERWRITING AGREEMENTS DO NOT AUTHORIZE OUR ISSUING AGENTS TO ENGAGE IN SETTLEMENTS OR CLOSINGS ON BEHALF OF STEWART TITLE GUARANTY COMPANY. THIS BULLETIN IS NOT INTENDED TO DIRECT YOUR ESCROW OR SETTLEMENT PRACTICES OR TO CHANGE PROVISIONS OF APPLICABLE UNDERWRITING AGREEMENTS. CONFIDENTIAL, PROPRIETARY, OR NONPUBLIC PERSONAL INFORMATION SHOULD NEVER BE SHARED OR DISSEMINATED EXCEPT AS ALLOWED BY LAW. IF APPLICABLE STATE LAW OR REGULATION IMPOSES ADDITIONAL REQUIREMENTS, YOU SHOULD CONTINUE TO COMPLY WITH THOSE REQUIREMENTS.

References

Bulletins Replaced:
None
Related Bulletins:
None
Underwriting Manual:
None
Exceptions Manual:
None
Forms:
None