| Link(s): | CII sets out vision for vulnerability data sharing Data sharing across the distribution chain roundtable |
Context
The CII has outlined a vision for transforming how vulnerability data is shared across the insurance and personal finance distribution chain to meet the Financial Conduct Authority’s (FCA) requirements. In a new report summarising a recent roundtable held in May, the CII calls for a shift from compliance-focused approaches to outcome-driven data sharing, recognising the need for common standards and a system that promotes sharing data to create customer value.
Key points to note and next actions
- In its Managing Vulnerability in Insurance Roundtable Summary Report published in April, the CII identified a gap between the work currently being done on vulnerability within the sector, and tangible benefits to customers who are experiencing vulnerability.
- The approach represents a shift from penalties and incentives, demonstrating how firms can build stronger customer relationships and commercial value through providing a more personalised service.
- The report outlines a vision centred on creating a seamless experience where vulnerability data flows efficiently across the distribution chain in almost real time.
- Under the proposed model, customers would grant permission once for their vulnerability information to be shared appropriately, with subsequent firms receiving only the specific adjustments needed to provide tailored support, rather than sensitive characteristics of vulnerability.
- The report addresses widespread misconceptions about GDPR compliance, with many firms displaying excessive caution. The CII clarifies that explicit consent is not always required, and that ‘legitimate interest’ and ‘substantial public interest’ tests can apply to vulnerability data management aimed at improving customer outcomes