Compliance Training (Continued Professional Development for Insurance Intermediaries)
Leading Title Insurance
Contents Overview
.................................................................................................................................................................................................. 3
Chapter 1
Insurance Distribution Directive (IDD)................................................................................................................4
Test......................................................................................................................................................................................... 5
Chapter 2
Regulatory Bodies for UK-based Financial Services Companies.........................................................6
Test.........................................................................................................................................................................................8
Chapter 3
The General Data Protection Regulation (GDPR)..........................................................................................9
Test....................................................................................................................................................................................... 14 Test answers ................................................................................................................................................................................................ 15
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OVERVIEW As of 1 October 2018, the Insurance Distribution Directive (IDD) replaces the Insurance Mediation Directive in all EU states.
Who is in scope? Insurance distribution means to sell, propose to sell, advise on or carry out other work preparatory to the conclusion of an insurance contract including dealing with claims after an insurance event. The IDD regulates the activities of insurance intermediaries, insurance companies, their employees, ancillary insurance intermediaries as well as online distribution.
What is Continued Professional Development (CPD)? The IDD introduces a minimum of 15 hours continuing professional development (CPD) for staff, in order to demonstrate that they possess appropriate knowledge and ability in order to complete their tasks and perform their duties adequately. The new requirements aim to ensure employees meet the knowledge and training requirements, which will lead to on-going and consistent consumer protection benefits across different distribution channels. Ensuring employees are competent and knowledgeable will reduce the likelihood of mis-selling of insurance and reduce misconduct risks.
Who has to complete CPD? The CPD requirement applies to the following:
•
people directly involved in the carrying out of First Title’s insurance distribution activities;
•
those responsible for the supervision of such employees; and
•
those within the management structure with responsibility for the firm’s insurance distribution activities.
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Chapter 1 INSURANCE DISTRIBUTION DIRECTIVE (IDD) Key Points The European Insurance Distribution Directive (IDD) is a revision of the Insurance Mediation Directive (IMD), which was introduced by the FSA in 2005. The IDD was originally scheduled to be implemented by 23 February 2018, however, the EU Council has delayed the application of the new rules to 1 October 2018. The IDD introduces a new requirement for those who sell, advise on and transact insurance contracts to all types of insurance customers. One of the main changes is the requirement for all people within this scope to complete at least 15 hours of continuing professional development per year.
At the moment, the FCA is requiring that in-scope AIIs comply with virtually the same requirements as insurance intermediaries. This is because: •
It is important that services are provided to customers by competent employees. This is a key customer protection, and it should be in place regardless of the category of firm.
•
Staff working for AIIs usually have a primary responsibility that is unconnected to insurance (for example, to sell cars or electrical goods which are the firm’s primary business).
Main provisions •
Requires brokers and employees of companies that sell insurance to do at least 15 hours of training and CPD per year.
•
Introduces new product governance requirements, which are largely in line with the FCA’s product governance requirements.
•
Requires firms that sell insurance on a non-advised basis to make sure that the product they are selling fulfils the customers most fundamental needs.
•
Imposes new duties on insurance companies that are selling products through companies that are not authorised by the FCA.
The directive applies to all those who sell, advise on, or conclude insurance contracts, and those who assist in administering or performing them. Customers of these firms range from individual consumers to large multinational corporations. The IDD covers not only insurers and Insurance Intermediaries, but puts Ancillary Insurance Intermediaries within scope too.
•
Requires general insurance firms in the retail and small corporate market to provide customers with Insurance Product Information Documents (IPIDs), which are similar to Key Features Documents.
•
Requires insurance intermediaries to disclose the nature and basis of the remuneration they receive in relation to the insurance contract.
Ancilliary insurance intermediaries (AIIs)
Professional standards
The IDD introduces this concept for firms who meet the following requirements:
The IDD requires firms to ‘possess appropriate knowledge and ability in order to complete their tasks and perform their duties adequately’.
Overview and background of the IDD – previously known as the Insurance Mediation Directive (IMD-2) Like the IMD it replaces, the new Directive allows member states to set higher standards (“gold plate”) if they see fit. This allows the UK to maintain its rules for, for example, retail investment advisers.
Scope
• •
•
the firm’s principal professional activity is not insurance distribution. the firm only distributes insurance products which are complementary to goods and services they provide as their primary professional activity; and the insurance products concerned do not cover life assurance or liability risks, unless that cover complements the good or service which the intermediary provides as its principal professional activity.
•
At least 15 hours of professional training or development per year.
•
There are specific areas in which the practitioner must be able to demonstrate knowledge:
- the insurance market, applicable laws governing insurance distribution; - claims handling, complaints handling, assessing customer needs, appropriate financial competency; and -
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business ethics standards / conflict of interest management.
Chapter 1 Competency Test Question
1
What is the minimum amount of Continued Professional Development (CPD) the IDD prescribes?
2
What does IPID stand for?
3
What was the name of the Directive the IDD replaces?
4
Complete the missing parts of the sentence: ‘The directive applies to all those who sell, advise on, or .................. insurance contracts, and those who assist in ............... or performing them’
Answer
Is this True or False? 5
‘The IDD only applies to the people who sell the insurance.’
6
Do insurance intermediaries need to disclose the amount of commission they receive in relation to the insurance contract?
7
Name two areas where an insurance practictioner must be able to demonstrate knowledge to meet the IDD requirements.
8
Would the IDD apply to a search insurance provider?
9
What is the final implementation date of the Insurance Distribution Directive?
10
Would the Insurance Distribution Directive apply to a policy purchased in the EU?
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Chapter 2 REGULATORY BODIES FOR UK-BASED FINANCIAL SERVICES COMPANIES First Title Insurance plc (FT) is authorised by the Prudential Regulatory Authority. FT is dual regulated by the Financial Conduct Authority and the Prudential Regulation Authority.
Historical Regulator – FSA After a series of market failures and the ensuing fierce criticism for the lack of regulatory protection, the government felt obliged to update the supervisory framework of the financial services industry and pass responsibility for financial stability to the Bank of England. From 1 April 2013 the Financial Services Authority has been replaced by the ‘twin peaks’ of the Financial Conduct Authority (FCA) and the Prudential Regulatory Authority (PRA), with the latter overseen by the Bank of England. A third new body, the Financial Policy Committee, reports directly to the Bank of England and is able to force banks to cut lending to certain sectors to relieve systemic risks building up in the economy.
FCA The authority has significant powers, including the power to regulate conduct related to the marketing of financial products. It is able to specify minimum standards and to place requirements on products. It has the power to investigate organisations and individuals. In addition, the FCA is able to ban financial products for up to a year while considering an indefinite ban; it will have the power to instruct firms to immediately retract or modify promotions which it finds to be misleading, and to publish such decisions. The authority is responsible for regulating the consumer credit industry from 1 April 2014, taking over the role from the Office of Fair Trading. Appointed Representatives are authorised through the FCA.
PRA The Prudential Regulation Authority (PRA) is responsible for the prudential regulation of banks, building societies, credit unions, insurers and major investment firms. The PRA’s role
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is defined in terms of two statutory objectives: to promote the safety and soundness of the firms it regulates and, specifically for insurers, to contribute to the securing of an appropriate degree of protection for policyholders. In promoting safety and soundness, the PRA focuses primarily on the harm that firms can cause to the stability of the UK financial system. A stable financial system is one in which firms continue to provide critical financial services – a precondition for a healthy and successful economy.
Financial Policy Committee The Financial Policy Committee was established in 2013 as part of the new system of regulation brought in to improve financial stability after the financial crisis. It identifies, monitors and takes action to remove or reduce systemic risks with a view to protecting and enhancing the resilience of the UK financial system.
ICO The Information Commissioner’s Office (ICO) upholds information rights in the public interest, promoting openness by public bodies and data privacy for individuals. The ICO is the official governance body for the General Data Protection Regulation, which came into effect on 25 May 2018.
FSCS FSCS protects consumers when financial services firms fail. It’s the compensation scheme for customers of firms authorised by the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA). Since 2001 they have helped millions of people and paid out billions of pounds. The FSCS can compensate customers if a firm has stopped trading or does not have enough assets to pay claims made against it.
FOS The Financial Ombudsman Service is an ombudsman in the United Kingdom. It was established in 2000, and given statutory powers in 2001 by the Financial Services and Markets Act 2000, to help settle disputes between consumers and UK-based businesses providing financial services, such as banks, building societies, insurance companies, investment firms, financial advisers and finance companies. The Financial Ombudsman Service can deal with complaints from consumers about most financial matters including, for example: banking, insurance, mortgages, pensions, savings and investments, credit cards and store cards, loans and credit, hire purchase and pawnbroking, financial advice, stocks, shares, unit trusts and bonds. From November 2009 money-transfer operators also came under the ombudsman’s remit. Before the ombudsman can step in, the consumer must first give the business they are unhappy with the opportunity to look into the complaint itself - before the ombudsman service can make a decision on the dispute. The business has a maximum of 8 weeks to resolve the complaint. If they do not resolve it within 8 weeks or the consumer is not happy with the response then they can refer the complaint to the ombudsman service. The ombudsman has the authority to request or require a company to offer financial compensation, correct a consumer’s credit file, or offer an apology, as a means of dispute resolution.
EIOPA The European Insurance and Occupational Pensions Authority (EIOPA) was established in consequence of the reforms to the structure of supervision of the financial sector in the European Union. Before and during the financial crisis in 2007 and 2008, the European Parliament has called for a move towards more integrated European supervision in order to ensure a true level playing field for all actors at the level of the European Union and to reflect the increasing integration of financial markets in the Union. As a result, the supervisory framework was strengthened to reduce risk and severity of future financial crises.
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Chapter 2 Competency Test Question
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1
Who is First Title Insurance plc regulated by?
2
What was the name of the FCA’s predecessor?
3
Which Regulator has the duty to ‘secure an appropriate degree of protection for insurance policyholders’?
4
Does the FCA have a right to ban financial products?
5
What is the name of the third regulatory body (other than the FCA and the PRA) that replaced the FSA?
6
What is the name of the body that is responsible for upholding information rights?
7
Would a customer of a foreign authorised bank be able to claim compensation under the FSCS?
8
What is the maximum amount of time firms have to investigate a complaint before the customer can refer t to the FOS?
9
What does EIOPA stand for?
10
Which authority has the power to regulate conduct related to the marketing of financial products?
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Answer
Chapter 3 THE GENERAL DATA PROTECTION REGULATION (GDPR) Overview: The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a Regulation by which the European Commission intends to strengthen and unify data protection for individuals within the European Union (EU). It also addresses export of personal data outside the EU. The regulation supersedes the Data Protection Act 1998. GDPR introduces tougher fines for noncompliance and breaches, and gives people more say over what companies can do with their data. It also makes data protection rules more or less identical throughout the EU.
Personal data means any information relating to a living, identifiable person who can be directly or indirectly identified in particular by reference to an identifier. This definition provides for a wide range of personal identifiers to constitute personal data, including name, identification number, IP address, reflecting changes in technology and the way organisations collect information about people. The General Data Protection Regulation (GDPR) addresses additional data protection needs required as a result of rapid technical development and improvements in digital technology
POSITION BEFORE GDPR
POSITION UNDER GDPR
No general reporting obligation to ICO
Serious data breach reporting to ICO will be an obligation
No obligation to notify data subjects
Notifying data subjects will be required under certain circumstances
Compensation
Compensation
FINES UNDER GDPR
FOR THE OFFENCES BELOW
Up to €20 million or 4% of annual g lobal turnover
Breaches of (for example) the principles of processing and data subjects’ rights
Up to €10 million or 2% of annual global turnover
Breaches of obligations including maintaining written records, implementing technical and organisational measures and in relation to the appointment of Data Protection Officers
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New Fines under the GDPR The General Data Protection Regulation (GDPR) includes a list of factors which will need to be taken into account when determining whether to impose an administrative fine and the amount to be imposed. The factors to be considered are by reference to each individual case and will take account of (amongst other things) the nature, gravity and duration of the infringement, any mitigating actions taken and whether there is any history of previous infringements.
Recent Breach Example Telecoms Company, TalkTalk has been issued with a record £400,000 fine by the ICO in 2016 for security failings that allowed a cyber attacker to access customer data “with ease”. The ICO’s in-depth investigation found that an attack on the company in October 2015 could have been prevented if TalkTalk had taken basic steps to protect customers’ information. ICO investigators found that the cyber attack between 15 and 21 October 2015 took advantage of technical weaknesses in TalkTalk’s systems. The attacker accessed the personal data of 156,959 customers including their names, addresses, dates of birth, phone numbers and email addresses. In 15,656 cases, the attacker also had access to bank account details and sort codes. Under the new regulation, this fine would have been considerably higher in all likelihood.
Aim of the GDPR:
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•
The GDPR gives individuals certain rights regarding information held about them. It places obligations on those who process information (data controllers and data processors) while giving rights to those who are the subject of that data (data subjects).
The GDPR introduces the concept of Privacy by Design, which means organisations need to consider privacy at the initial design stages and throughout the complete development process of new products, processes or services that involve processing personal data.b
Different types of data: Generic Data means data not specific to an individual.
Examples of generic data include: • The fact that we offer legal indemnity policies • Generic names of the company’s insurance policies • The fact that enact acts on re-mortgage business
Requirements for Processing The disclosure of generic data is allowed under the General Data Protection Regulation (GDPR) and so generic data can be released to anyone that requests it. Personal Data means any information relating to a living, identifiable person who can be directly or indirectly identified in particular by reference to an identifier. This definition provides for a wide range of personal identifiers to constitute personal data, including name, identification number, location data or online identifier, reflecting changes in technology and the way organisations collect information about people.
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To protect the customer.
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To ensure that only information that is actually needed is used.
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To ensure that the data is only used for the purpose that it was given to the company.
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To protect the privacy of the individual.
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To regulate the use of personal data.
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To protect individuals from the risk of prosecution.
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To enable the individual to update / erase data in certain circumstances.
• Name details
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The GDPR relates only to personal data, but covers both facts and opinions about the individual.
• Date of Birth
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The GDPR seeks to strike a balance between the rights of individuals and the sometimes competing interests of those with legitimate reasons for using personal information.
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Examples of personal data include: • Any personal account information • Address details
• Mortgage Account numbers
• IP Address • Any other personal data
Requirements for Processing
Information Commissioner (IC)
Unless a relevant exemption applies, at least one of six specific conditions for ‘fair processing’ must be met whenever you process personal data.
The Information Commissioner is the person (and their office) who has the power of enforcement under the GDPR. The Commissioner has the power to close a business over breaches.
Sensitive Personal Data is used to refer to a specific category of Personal Data as detailed below. • Racial and ethnic origins
Examples of sensitive personal data includes: • Political opinions, religios or other beliefs • Membership with trade unions • Phisical or mental help • Sexual orientation • Commision or alleged commission of any criminal offence
Requirements for Processing
The Commissioner may serve an information notice on the controller requiring certain information if requested by an individual who believes the data controller is not processing his or her personal data in accordance with the principles; the Commissioner may also serve an information notice of his own volition. If the Commissioner finds that the data controller has contravened or is contravening a data protection principle, the Commissioner may serve an enforcement notice requiring that controller to remedy the breach or take certain steps (including erasing data etc.).
In addition to meeting the specific requirements for processing personal data, at least one of several additional conditions must be met before processing sensitive personal data.
Principles
Defined Roles
Article 5 of the GDPR requires that personal data shall be:
Data Controllers must comply with six enforceable principles of good information handling practice.
1.
Data Controller Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing of personal data.
Data Processor Data Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. Under the previous data protection regime, (prior to 25 May 2018) only the data controller was held liable for data protection compliance, not the data processor. GDPR changed this, and the data processor is now liable for fines for non-compliance. In order to ensure compliance, the data controller now has to have a Data Processing Agreement in place with all its data processors and sub processors.
Data Subject Data Subject means someone on whom data is stored somewhere outside their direct control. Any data subject has the right (subject to restrictions and exemptions) to be provided with details of such personal data by any data controller, and the information which constitutes that data.
Processed lawfully, fairly and in a transparent manner in relation to individuals;
2. Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes; 3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed; 4. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay; 5. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
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6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
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The individual has deliberately made the information public.
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The processing is necessary in relation to legal proceedings; for obtaining legal advice; or otherwise for establishing, exercising or defending legal rights.
Lawful Bases of Processing
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The processing is necessary for administering justice, or for exercising statutory or governmental functions.
Personal Data
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The processing is necessary for medical purposes, and is undertaken by a health professional or by someone who is subject to an equivalent duty of confidentiality.
•
The processing is necessary for monitoring equality of opportunity, and is carried out with appropriate safeguards for the rights of individuals.
The processing of personal data can only be permitted if one of the following six lawful bases applies: •
The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
•
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
•
Processing is necessary for compliance with a legal obligation to which the controller is subject.
•
Processing is necessary in order to protect the vital interests of the data subject or of another natural person.
•
•
Rights of the Data Subject A Data Subject has eight rights under the General Data Protection Regulation (GDPR): •
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
The right to be informed: The right to be informed encompasses your obligation to provide ‘fair processing information’, typically through a privacy notice. It emphasises the need for transparency over how you use personal data.
•
Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
The right of access: Individuals have the right to access their personal data and supplementary information. The right of access allows individuals to be aware of and verify the lawfulness of the processing
•
The right to rectification: The GDPR gives individuals the right to have personal data rectified. Personal data can be rectified if it is inaccurate or incomplete.
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The right to erasure: The right to erasure is also known as ‘the right to be forgotten’. The broad principle underpinning this right is to enable an individual to request the deletion or removal of personal data where there is no compelling reason for its continued processing.
•
The right to object: Individuals have the right to object to:
Processing shall be lawful only if and to the extent that at least one of the conditions above applies.
Sensitive Personal Data If an entity proposes to process sensitive personal data, one of the following additional conditions also must be met: •
The individual whom the sensitive personal data is about has given explicit consent to the processing.
•
The processing is necessary so that you can comply with employment law.
•
The processing is necessary to protect the vital interests of the data subject or of another natural person.
•
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The processing is carried out by a not-for-profit organisation and does not involve disclosing personal data to a third party, unless the individual consents. Extra limitations apply to this condition.
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- processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); - direct marketing (including profiling); and - processing for purposes of scientific/ historical research and statistics. •
Rights in relation to automated decision making and profiling: Individuals have the right not to be subject to a decision based solely on automated processing (making a decision
solely by automated means without any human involvement); and profiling (automated processing of personal data to evaluate certain things about an individual). •
The right to restrict processing: Individuals have a right to ‘block’ or suppress processing of personal data. When processing is restricted, you are permitted to store the personal data, but not further process it. You can retain just enough information about the individual to ensure that the restriction is respected in future.
•
The right to data portability: The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services. It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.
Scope The General Data Protection Regulation (GDPR) does not restrict the transfer of data from the UK to an EEA country. Data can be transferred to countries outside of the EEA if that country’s Data Protection regulations can be deemed “adequate” by the European Commission. These may be subject to conditions and must be checked prior to the transfer of any data, all such transfers need to be referred to Compliance and Legal.
Marketing Under the Data Protection Act, an entity could market to other entities or individuals as long as they did not opt out of receiving such material. Under the General Data Protection Regulation (GDPR), however, companies need to rely on one of the six lawful bases if they want to continue marketing. The most common basis for this purpose would be consent.
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Chapter 3 Competency Test Question
1
What is the maximum penalty a company can incur for data processing breach under the GDPR?
2
When did the GDPR come into force?
3
What type of data would a customer’s DOB be classed?
4
Name two examples of Sensitive Personal Data.
5
The following is the description of which role: ‘A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.’?
6
How many enforceable principles are there under the GDPR?
7
Name two rights of the Data Subject under the GDPR.
8
Does the GDPR restrict data transfer within the EU?
Is this True or False? 9
10
14
‘Generic Data can be disclosed to any third party.’ What is the name of the entity that has the power of enforcement un the UK under the GDPR?
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Answer
Data Controller
Data Subject
Data Processor
COMPETENCY TEST ANSWERS Chapter 1
Chapter 2 Answer
1
Answer
Minimum 15 hours training annually. 1
First Title is Dual Regulated by the FCA and the PRA.
2
Insurance Product Information Document.
3
IMD - Insurance Mediation Directive.
2
FSA - Financial Services Authority.
4
Conclude / administering.
3
PRA.
4
Yes.
5
False, the description covers: those who sell, advise on, or conclude insurance contracts, and those who assist in administering or performing them.
5
Financial Policy Committee.
6
ICO.
6
No - just the nature and basis of the remuneration received.
7
No, only customers of UK authorised firms.
8
8 weeks.
7
The insurance market, applicable laws governing insurance distribution; claims handling, complaints handling, assessing customer needs, appropriate financial competency; and business ethics standards / conflict of interest management.
9
European Insurance and Occupational Pensions Authority.
10
FCA.
8
Yes, all general insurance policies are in scope.
9
10 October 2018.
10
Yes, the IDD applies to all EU countries.
Chapter 3 Answer 1
Up to â‚Ź20 million or 4% of annual global turnover.
2
25 May 2018.
3
Personal Data.
4
Two of the following: Racial and ethnic origins / Political opinions / religious or other beliefs / Membership with trade unions / Physical or mental help / Sexual orientation / Commission or alleged commission of any criminal offence.
5
Data processor.
6
6.
7
Two of the following: right to be informed, right of access, right to erasure, right to rectification, right to object, rights in relation to automated decision making and profiling , right to restrict processing and The right to data portability.
8
No.
9
True.
10
Information Commissioner.
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OUR OFFICES LONDON
SEVENOAKS
GLASGOW
First Title Insurance plc 81 Gracechurch Street London EC3V 0AU
First Title Insurance plc ECA Court 24-26 South Park Sevenoaks Kent TN13 1DU
First Title Insurance plc Suite 5.1 Turnberry House 175 West George Street Glasgow G2 2LB
Call: +44 (0)20 7160 8100
Call: +44 (0)20 7160 8100
Call: +44 (0)141 413 8800
Email: comms@firsttitle.eu
Email: info@firsttitle.eu
Email: scotinfo@firsttitle.eu DX:
512057 Glasgow Central
www.firsttitle.eu First Title Insurance plc is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. First Title Insurance plc is registered in England and Wales under company number 01112603. Registered office: First Title Insurance plc, ECA Court, 24-26 South Park, Sevenoaks, Kent TN13 1DU.
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