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The policy authorizes collection of driver behavior data including vehicle speed, braking and acceleration patterns, seatbelt status, and trip duration, and states that this data may be disclosed to General Motors Insurance for usage-based insurance purposes with affirmative consent.
This analysis describes what General Motors's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes that granular driving behavior metrics may be used to inform insurance rate determinations when the user provides affirmative consent, creating a direct link between vehicle operation data and financial product pricing that has implications for insurance regulatory compliance and consumer disclosure requirements.
The updated statement narrowed its definition of personal information from 'identifies, relates to, or could reasonably be linked to you' to 'describes, relates to, or could reasonably be linked to you.' This language change affects which information GM must treat as personal information under the policy. The revised de-identification section reorganizes prior language, now stating GM 'may use technical measures to remove information that could reasonably identify you or your vehicle' and requires 'the same safeguards from any third parties we share it with.' The policy clarifies that its protections apply to personal information dealers disclose to GM, but do not cover dealers' independent data practices. Cruise is no longer listed as a GM affiliate exempt from this privacy statement, though the scope of privacy protections for Cruise users depends on whether Cruise now operates under this statement or maintains separate privacy terms.
View change record →The agreement authorizes collection of driver behavior data including speed, braking, acceleration, and seatbelt status, and states that with affirmative consent this data may be disclosed to General Motors Insurance to influence insurance quotes or policy rates through usage-based insurance programs.
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"Driver Behavior Information Information about how you drive a vehicle that is linked or reasonably linkable to you, such as vehicle speed, seatbelt use information, information about braking and acceleration habits, and related trip time and duration. We may also collect Seatbelt Information (whether the driver or passenger seatbelts are latched or unlatched) while the vehicle is in use to deliver OnStar services as set forth in the OnStar Services Consent available. General Motors Insurance when you have given your affirmative consent to disclose Driver Behavior Information or Precise Geolocation Information for usage-based insurance offers or to help determine your rate for an insurance quote or policy.Excerpt from General Motors's GM Privacy Statement
(1) REGULATORY LANDSCAPE: The use of driver behavior data for insurance rate determination engages state insurance regulatory frameworks in each state where GM Insurance operates. The FTC Act applies to unfair or deceptive practices in data-driven insurance pricing. California's CPRA classifies certain behavioral data as sensitive personal information, and its use for insurance pricing may require compliance with both CPRA and California Department of Insurance regulations. The document's requirement for 'affirmative consent' before disclosing driver behavior data to GM Insurance aligns with heightened consent standards under several state privacy laws. (2) GOVERNANCE EXPOSURE: High. The intersection of vehicle telematics data with insurance rate determination creates regulatory exposure across both privacy law and state insurance regulatory frameworks. The affirmative consent requirement stated in the policy must be operationally verified to confirm that consent is obtained in a manner that satisfies applicable state insurance and privacy standards. (3) JURISDICTION FLAGS: California, New York, and other states with active insurance regulatory oversight of telematics-based underwriting create heightened exposure. States that restrict or require disclosure of telematics data use in insurance pricing may impose obligations beyond those described in this policy. Illinois BIPA may be relevant if any biometric identifiers are derived from driver behavior monitoring. (4) CONTRACT AND VENDOR IMPLICATIONS: The relationship between GM and General Motors Insurance for purposes of driver behavior data disclosure should be governed by a data sharing agreement that specifies the scope of permitted use, consistent with the policy's stated affirmative consent requirement. The policy notes that General Motors Insurance is a separate entity with its own privacy statement, which should be reviewed to confirm alignment. (5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm that the affirmative consent mechanism for driver behavior data disclosure to GM Insurance is implemented in a manner that satisfies applicable state insurance regulatory and privacy law standards. The consent record should document the specific data categories consented to, the disclosed purpose, and the date of consent. Any changes to the scope of driver behavior data used for insurance pricing should trigger a consent refresh review.
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This provision establishes that granular driving behavior metrics may be used to inform insurance rate determinations when the user provides affirmative consent, creating a direct link between vehicle operation data and financial product pricing that has implications for insurance regulatory compliance and consumer disclosure requirements.
The agreement authorizes collection of driver behavior data including speed, braking, acceleration, and seatbelt status, and states that with affirmative consent this data may be disclosed to General Motors Insurance to influence insurance quotes or policy rates through usage-based insurance programs.
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