15.3 Relations With Clients, Government, and the Public

Relations With Clients, Government, and the Public

Quick Answer: Hold the CDI bail identification card, show it when transacting, and never loan it out (10 CCR 2077.1). The card identifies the licensee to jails; it does not authorize a fishing expedition in jail records. PC 11105.6 is the authorized channel for aliases and booking photographs after a bench warrant or forfeiture for the licensee's own client. GLBA, implemented at 10 CCR 2689.1 through 2689.24, requires privacy notices and an opt-out before sharing nonpublic personal financial information with nonaffiliates. PC 1299.07(g) independently forbids handing a bail fugitive's personally identifiable information to immigration enforcement without a valid judicial warrant or court order.

Privacy in a bail practice is not one statute. It is how the licensee treats three audiences: the people who pay, the people who run jails and courts, and everyone else.

Clients: fiduciary confidentiality plus GLBA notices

CIC 1733 treats money received as an insurance agent, broker, or solicitor as held in a fiduciary capacity. Chapter 3 covers the money. The ethics overlay for this chapter is the information that travels with the money. An indemnitor's tax return, a defendant's medical fact mentioned at the window, a co-signer's employer, and a collateral deed are not marketing content. They are client information received in the insurance transaction. IIPPA 791.13 is the closed disclosure list. Fiduciary culture is the reason a licensee does not need a 791.13 exception to know that gossip is still a bad idea.

Federal Gramm-Leach-Bliley Act privacy rules apply to insurance licensees as financial institutions. CDI implemented them at 10 CCR 2689.1 through 2689.24, effective March 24, 2003. CDI's own summary of those regulations is the version to memorize:

• Licensees generally must provide consumers a notice describing privacy practices at the time of policy application and annually thereafter.
• Notices must clearly and conspicuously describe the categories of personal information collected, the categories disclosed, and the categories of third parties who may receive it.
• If the licensee wants to disclose personal financial information to nonaffiliated third parties, it must provide a clear and conspicuous opt-out notice and a cost-free method to reply.
• 10 CCR 2689.8 requires that an opt-out notice clearly state in 16-point boldface type IMPORTANT PRIVACY CHOICES, or similarly highlight the purpose of the notice.
• Insurance producers are responsible for providing notices only if they collect or disclose information in ways other than as set forth in the insurer's notice. If the agent only collects what the surety's notice already describes and does not share beyond that notice, the surety's form can carry the load. If the agent sells the indemnitor list to a local car dealer, the producer is outside the surety's notice and the producer-notice duty is the agent's.
• Nonpublic personal medical record information may not be disclosed without prior written consent.
• Licensees must maintain standards for safeguarding nonpublic personal information.
• Noncompliance may be enforced under CIC 791.15 and other Commissioner authorities.

GLBA does not let a licensee skip IIPPA. It does not let a licensee skip 2069. It is the financial-privacy overlay: notice, opt-out for nonaffiliate sharing of nonpublic personal financial information, consent for medical-record NPI, and safeguards.

Stockton scenario. The surety's privacy notice says the company shares NPI with its appointed agents and with reinsurers. The agent wants to email a weekly clients-who-might-need-immigration-help spreadsheet to a private notario. That is a disclosure of personal financial and identifying information to a nonaffiliated third party, it is outside the surety's notice, it likely violates 791.13, and if any row is a bail fugitive and the notario is using it for immigration enforcement, it is also PC 1299.07(g).

Government: identify yourself; do not fish; do not leak

CDI issues a Bail Identification card to every individual licensee. CDI's Bail FAQ states the card is required to do business in California, should be presented to identify the licensee and demonstrate that licensing requirements have been met, and that jails will require the ID card when on site. The application packet requires a passport-type photo not older than six months. Replacement requests go on form LIC 268-C with the required fee.

10 CCR 2077.1 is the conduct rule behind that card:

• Keep the identification card in possession.
• Upon request, show it to any person with whom the bail licensee transacts bail.
• Do not permit any other person to use the card for any purpose.
• Return the card to the commissioner immediately upon the termination of all of the holder's bail licenses.

CIC 1820 separately requires that every bail license be prominently displayed in the office of the licensee. The wall license and the pocket ID are different objects. The wall license does not get the agent through the jail sally port. The pocket ID does not satisfy 1820.

What the card is not: it is not a search warrant, a CORI subscription, or permission to browse the jail computer, demand a random inmate's booking jacket, or stand at records and see who got booked tonight in order to solicit. Chapter 4 already taught inbound-solicitation and public-authority rules (10 CCR 2074 through 2080, 2075, 2078). This chapter adds the privacy point: identification is not authorization to fish.

PC 11105.6: the authorized channel versus pretext

PC 11105.6 is the authorized records channel. Upon the request of a licensed bail agent or bail bond licensee (as described in PC 1276 and 1276.5), a local law enforcement agency may furnish:

1. The individual's known aliases
2. The booking photograph
3. Information identifying whether the individual has been convicted of any violent felony as defined in PC 667.5(c)
4. An unaltered copy of the booking and property record, excluding any medical information

All of the following circumstances must exist:

• (a) The information is from the record of a person for whom a bench warrant has been issued, or for whom a bail forfeiture has been ordered.
• (b) That person is a client of the agent or licensee.
• (c) The agent or licensee pays the agency a fee equal to the cost of providing the information.
• (d) The information is confidential. The recipient shall not disclose its contents other than for the purpose for which it was acquired. A violation of (d) is a misdemeanor.

Agencies may, not must. The Los Angeles County Sheriff's Department public records FAQ restates the same list. Do not treat a local custom that is more generous than 11105.6 as a statewide entitlement, and do not treat the statute as a right to sit down with the police report.

11105.6 versus pretext. Asking records, with the CDI identification card, after a forfeiture on the licensee's own client, and paying the fee, is the authorized channel. Pretending to be a defense investigator, a journalist, or the inmate's sister to pull the same booking photo the day after arrest — before any warrant or forfeiture, or on someone who is not the licensee's client — is a pretext interview if the agent is gathering it in connection with an insurance transaction (CIC 791.03) and is independently outside 11105.6. The exam will try to blend those facts. Separate them.

Fresno scenario. The client failed to appear, the court forfeited, and a bench warrant issued. The agent presents the CDI identification card, requests aliases and the booking photo, pays the sheriff's cost fee, and uses the photo to identify the person at a recovery. That is lawful 11105.6. The agent then posts that photo on Instagram captioned with the indemnitor's full name and employer. That redisclosure is not the purpose for which the photograph was acquired. 11105.6(d) makes it a misdemeanor, and 791.13 still applies to the indemnitor's personal information.

San Diego scenario. The agent has no client in the jail. The agent shows the identification card and asks the clerk to pull tonight's bookings so the office can see if anyone needs a bond. The card identifies the licensee. 10 CCR 2074 and 2079 still forbid jailhouse solicitation, and 11105.6 does not apply because there is no bench warrant or forfeiture on the agent's client. That is a fishing expedition.

The public, and the SB 805 privacy overlay

Relations with the public include everyone who is not a client and not a lawful government requester: reporters, neighbors, employers, immigration contractors, and social media. Default answer is 791.13 (no disclosure unless a paragraph applies) plus 2069 (no impending-arrest leaks) plus 11105.6(d) (no mugshot gossip).

SB 805, the No Vigilantes Act, signed September 20, 2025, and described in CDI Bulletin 2025-15 (October 1, 2025), added privacy duties that this chapter teaches without repeating Chapter 14's recovery-tactics material. PC 1299.07(f) — do not use the recovery position for immigration enforcement except pursuant to a valid judicial warrant or court order — belongs with recovery. PC 1299.07(g) belongs here: an individual authorized by PC 1299.02 to apprehend a bail fugitive shall not disclose or provide in writing, verbally, or in any other manner, personally identifiable information of any bail fugitive that is requested for purposes of immigration enforcement, except pursuant to a valid judicial warrant or court order. Subdivision (h) defines immigration enforcement to include efforts to investigate, enforce, or assist in investigating or enforcing federal civil immigration law, and federal criminal immigration law that penalizes presence, entry, reentry, or employment in the United States.

A phone call from someone who just needs the date of birth and the mother's address to check status is a 1299.07(g) request. A valid judicial warrant or court order is the exception. An administrative immigration detainer is not a judicial warrant. Do not invent a law-enforcement-courtesy exception that the statute does not contain. PC 1299.07(i) addresses governmental entities exchanging citizenship or immigration-status information under 8 U.S.C. 1373 and 1644; that clause is about governmental entities, not about a bail licensee volunteering a file.

Putting the three audiences on one desk

Sacramento trap. A person in plain clothes at the jail asks to see whoever you just posted and flashes a generic federal credential. 2077.1 requires the licensee to show the CDI card when asked by a person with whom the licensee transacts bail. It does not require opening the file. Ask whether they have a judicial warrant or court order. If the request is for immigration enforcement and they do not, 1299.07(g) stops the disclosure. If they want operational details of a pending arrest the agent was told about, 2069 allows disclosure only in accordance with a lawful inquiry of a law enforcement or judicial officer — not a fishing request.

The professional picture is simple enough for a 75-question exam: identify yourself, use the authorized records statute, keep what you get, give the privacy notice, and do not become a leak, a marketer of NPI, or a volunteer immigration researcher.