The NAIC Model Data Security Law: Securing Green Screen Access to Policyholder Data

To comply with the NAIC Model Data Security Law, insurers must secure host system access to policyholder data by modernizing access controls, enforcing robust authentication, and generating audit-ready logs. Failing to address vulnerabilities in legacy mainframe access exposes sensitive information and risks regulatory penalties. Modernizing critical system access not only protects policyholder trust but also streamlines compliance, making it possible to detect unauthorized activity in real time and respond quickly to evolving threats.

Regulators have established the National Association of Insurance Commissioners (NAIC) Model Data Security Law to address escalating risks. This framework outlines strict requirements for data protection, access control, and incident response. Many insurers find compliance challenging. Highly reliable mainframes often rely on legacy access methods that lack modern security controls.

To align with the NAIC Model Data Security Law, insurers should consider these practical strategies:

• Modernize access controls for core systems, moving beyond legacy passwords to advanced, centralized identity and access management (IAM).
• Integrate mainframe and green screen access with enterprise IAM platforms and best practices for unified policy enforcement.
• Enforce the principle of least privilege, so employees only access data and applications needed for their role.
• Automate user provisioning and de-provisioning to quickly update or revoke access as job roles change.
• Implement multi-factor authentication (MFA) at every host session to prevent unauthorized access, even if passwords are compromised.
• Enable single sign-on (SSO) for streamlined, secure employee access to host applications.
• Deploy solutions that generate comprehensive, centralized, and immutable audit logs for every host session.
• Integrate log data with SIEM tools for continuous monitoring, rapid incident response, and easy audit reporting.

These steps help insurers close compliance gaps, protect sensitive policyholder data, and build a resilient foundation for digital insurance operations.

What is the NAIC Model Data Security Law?

The NAIC Model Data Security Law defines strict standards for data security, breach notification, and the investigation of cybersecurity events in insurance. Insurers must create and maintain a written information security program based on a clear risk assessment.

Access controls are a core component of this law. You must restrict access to nonpublic information and continuously monitor your systems for unauthorized activity or potential breaches.

Legacy green screen emulators leave sensitive policyholder data exposed. Without modern access controls and continuous monitoring, every connection is a potential vulnerability – putting trust and compliance at risk.

Legacy mainframes process billions of transactions and hold vast amounts of personally identifiable information (PII), financial records, and health data. While mainframe architectures can be robust, traditional "green screen" emulators often serve as weak points, leaving sensitive data vulnerable.

The risks of legacy access in the modern insurance landscape

Relying on static passwords for mainframe access leaves policyholder data open to cyberattack strategies like phishing and credential stuffing, as well as potential social engineering. Legacy authentication methods simply can’t keep up with today’s increasingly complex threat landscape.

When organizations rely on outdated access controls, they increase their risk of compliance gaps. Traditional emulators often operate outside of modern security perimeters. They require separate credential management, which fragments security workflows. This fragmentation creates blind spots. It becomes harder to enforce consistent security policies. Enabling dynamic access controls or effectively tracking user behavior is also more difficult.

Bridging the gap between legacy and modern security systems is vital – fragmented controls around core applications can result in compliance failures. Integrating your legacy infrastructure with modern security tools is essential to safeguard policyholder data and meet NAIC requirements.

How to modernize access controls for compliance

To modernize access controls for compliance, insurers should integrate legacy host applications with centralized IAM strategies. This approach secures access pathways without replacing core systems, making it easier to enforce consistent policies and close security gaps.

Modern integration has key benefits:

• Enforces the principle of least privilege by mapping host access permissions to IAM roles, ensuring employees only reach the data and applications essential for their jobs.
• Automates provisioning and de-provisioning, making it easy to quickly update or revoke access when roles change or employees depart.
• Reduces administrative complexity and eliminates the risks associated with dormant accounts. 

Implementing multi-factor authentication for enhanced defense

Multi-factor authentication (MFA) is now essential for protecting nonpublic information under the NAIC Model Data Security Law. As credential threats evolve, MFA adds a critical security layer, blocking unauthorized access and strengthening your overall data defense.

Adding MFA to legacy systems can be challenging. Modern solutions for securing host system access solve this with session-based MFA. When employees start a host session, a secondary authentication is triggered through your IAM provider. Users must verify their identity – using biometrics, hardware tokens, or authenticator apps – before being granted access.

Session-based MFA authenticates users at the moment of access, ensuring only verified individuals reach sensitive mainframe data. This approach meets Zero Trust requirements and NAIC standards, blocking unauthorized entry even if network credentials are compromised.

Integrating MFA with single sign-on (SSO) also streamlines the user experience. Key benefits include:

• Employees authenticate once into the enterprise portal for quick, secure access to host applications.
• Passwordless entry reduces credential fatigue and the risk of password-related breaches.
• Simpler workflows drive higher user adoption rates.
• Fewer password resets and lockouts mean reduced support tickets.
• Teams spend less time on access issues and more time serving customers. 

Generating audit-ready logs to prove compliance

Generating audit-ready logs is essential for compliance with the NAIC Model Data Security Law. Insurers must maintain clear, detailed records of all system access and user actions to ensure rapid incident response and demonstrate full regulatory adherence.

Traditional emulators often create logs that are inconsistent and fragmented. These disorganized logs are difficult and time-consuming to organize. When incidents occur, this lack of clarity hinders investigations. It can also delay required reporting to state agencies.

A modernized host access strategy should include:

• Comprehensive, immutable audit trails for every host session
• Detailed log capture of exact connection times, accessed applications, and session duration
• Centralized, standardized logging formats to streamline monitoring and reporting
• Integration-ready logs for use with SIEM tools, supporting real-time threat detection and rapid response

Centralized, standardized logs make it easy to integrate with SIEM tools, enabling real-time threat detection and rapid, accurate compliance reporting. 

Partner with Rocket^® to secure policyholder data

Securing policyholder data is essential for meeting NAIC Model Data Security Law requirements and maintaining trust. Invest in solutions that protect sensitive information without disrupting core business systems.

Rocket^® Software understands the unique demands of insurance IT modernization. With Rocket^® Secure Host Access, you can link green screen access to modern IAM solutions such as Okta, Microsoft Entra ID, or Ping Identity. This strategy extends advanced security protocols directly to the mainframe. Every user who tries to access policyholder data is evaluated against your organization’s overall security policies before they gain access. This approach delivers true defense in depth for your mainframe workflows.

Implementing Rocket^® Secure Host Access gives you centralized control, session-based MFA, and clear audit trails. You can meet NAIC requirements, strengthen compliance, and protect policyholder data – all while ensuring secure, efficient mainframe access.