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Is your data ready for Rule 13?

By: Jake Solomon, Insurance SME at JMR Software

Data plays a pivotal role in the relationship between insurers and consumers. Throughout the insurance process there is a constant tension between the need for openness and accessibility of data, whilst maintaining tight security, managing people’s privacy, and ultimately protecting consumer rights. 

Today in a digitally driven world where data needs to sit at the heart of everything, we believe it creates huge challenges and incurs greater costs for those intermediaries with legacy systems. 

Rule 13 of the Policy Protection Rules (PPR)on Data Management requires that the Insurer must have access, at all times, but certainly as and when required, to data that is up-to-date, accurate, reliable, secure and complete and this includes data in intermediary systems. The ultimate aim of the new legislation is based on ‘treating the customer fairly’ and hence the reason for access to data. 

However, ‘access’ goes further than providing the insurer access to the intermediaries’ system, but also requires the insurer to be able to interrogate information on all policy, claims, communication and complaints data. Interpreted in this way it also encapsulates rules 16, 17 and 18 as they are all interrelated. In fact, documents, SMS, email, are all important pieces of information that is very pertinent in order to effectively manage the policyholder data. 

Rule 13 impacts the insurer as they need to store additional information, but also third parties who need to ensure the information is provided and that access is made available. Intermediaries need to have the mechanisms in place by 1 Jan 2020 when Rule 13 comes into effect.

With time running out it also delivers some immediate challenges. Different Insurers may require different data to be transferred and may want data to be structured in a specific way. This means there is no standardised method or one solution for everyone. Each engagement needs to be customised and the data needs to be tailored for each intermediary insurer solution. Additional mandates may also need to be in place to pass the additional policyholder information. For example, personal information, including banking details, across to the Insurer in order to comply to regulations such as the POPI Act 2019.

In order to be compliant to Rule 13 as well as based on interpretation Rules 16, 17 and 18 of the Act, the Intermediary would need to have a system in place that provides tailored functionality so that each Insurer receives the required data. JMR’s CloudCover Insurance Systems with an integrated or standalone Complaints Management system provides all the functionality to comply to Rule 13.

Difficulties may also exist for the insurer in cases where they need to take over the premium collection and payments to track the financial transactions. This involves the need to maintain a transaction-based policyholder account where additional information such as the last premium date collected, premiums raised, premium collected, unpaids, double debits, broker fees, binder fees and other fees need to be collected.

Data management has been front and centre with recent GDPR legislation introduced across Europe, the POPI Act 2019, but also in this new legislation released in January 2018 that has led to updates on the Policyholder Protection Rules (PPRs) which for those with legacy systems could cause concerns. To not fall foul of the law, intermediaries should consider migrating to the Cloud as a way of overcoming not only the legislative challenges, but also operational and other customer driven needs. 

Ultimately, there is a growing need for systems that enable secure access to policy data from any location in real time. JMR Software CloudCover Solutions can provide this level of data on demand that could give insurers, intermediaries and other relevant stakeholders the appropriate policy, claims, communication and complaints information and documentation that they require, daily, monthly or as required.

Companies need to act now and JMR Software is well positioned to either help businesses to move onto a rapidly deployed cloud-based solutions or assist with the best strategy to provide the data required to the insurer.


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