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Generic AI vs. ennablAI.
If your agency is going to use AI, use AI built for insurance. We uploaded the same GL policies to a general-purpose AI and to ennablAI, then asked the same coverage question.
Generic AI
BIPA exposure on a fingerprint timeclock is likely carved out of this GL almost entirely. Here's the read:
- • Both 24-25 and 25-26 Travelers GL policies include endorsement CG D9 44 01 23 — "Exclusion: Violation of Biometric Information Privacy Laws" — barring BI, PD, personal and advertising injury arising out of any alleged BIPA violation.
- • Travelers would almost certainly point to this exclusion and deny both defense and indemnity under the CGL for a fingerprint-scan class action.
- • The exclusion is broad enough to sweep in "any other" alleged injury in the same suit (invasion of privacy, negligence, statutory damages) when pleaded alongside a BIPA count.
- • The prior 24-25 term doesn't realistically create a second tower — same exclusion, plus a non-cumulation endorsement reducing the current limit by amounts paid under prior Travelers policies.
- • Worth checking EPLI, cyber/privacy liability, tech E&O, or management liability elsewhere in the program — but on this GL package alone, the likely Travelers position is "no coverage due to the biometric privacy exclusion."
Based on the GL package alone. Confirm with a licensed coverage attorney before advising the insured.
ennablAI
Insurance-specificBottom line: excluded on both years. There's no second limit to lean on. The insured needs standalone BIPA cover before the rollout.
Suggested next actions
- Get a BIPA-specific quote — Coalition, At-Bay, Beazley, Tokio Marine HCC. $1M–$5M limits, $25K–$250K retentions, defense usually inside the limit.
- Tighten operational hygiene before rollout: written consent before first scan, public retention/destruction schedule, no sale/lease of biometric data, BIPA-mirroring vendor contract.
- Offer a non-biometric fallback (PIN or badge) for any employee who refuses consent — cleanest defense to a 15(b) suit.
ennablAI grounds every finding in the document you upload and cites the page it came from.
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