On October 16, 2019 the IIF responded to the IAIS Draft Issues Paper on the Use of Big Data Analytics in Insurance issued on September 2, 2019. The Draft Issues Paper builds on the IAIS November 2018 Issues Paper on Increasing Digitalisation in Insurance and its Potential Impact on Consumer Outcomes by focusing more specifically on issues related to the use of personal and other data by insurers as a result of digitalisation. The paper highlights the increased availability of alternative data sources and insurers’ use of algorithms and advanced analytics capabilities to make decisions based on patterns, trends and linkages, which is collectively referred to as “Big Data Analytics.” The IAIS makes observations about the potential implications for supervisors of insurers’ use of Big Data Analytics.