FSCO UBI Flashcards
List Benefits from Usage Based Insurance(UBI) program
- Savings for drivers
- Fewer accidents (promoting safety)
- Less congested roads (by encouraging safer and less frequent driving)
List Things that the insurers need to inform consumers prior to enrollment
- What personal info is being collected
- Who may use or have access to the info
- How the info is being used
- Under what circumstances the info will or could be disclosed to other parties
- What their rights are with respect to the info
List Limitations on collection and use of UBIP data for insurance purposes
UBIP should:
• Collect and use data solely for discount-setting purposes
• Not be used to decline, cancel or refuse to renew risks
• Not be used to confirm rating criteria currently used (ex.: distance driven)
• Inappropriate for insurers to use UBIP data for claims-related purposes
List Data consideration regarding UBIP data
- Data Accuracy
- Data Security
- Data Storage
- Termination of Participation or Policy
List Roles and responsibilities of insurers and 3rd party providers
FSCO expects that insurers will have written contracts with each 3rd party provider to confirm:
• Provider’s ability and commitment to ensure a level of personal info protection >= expected of the insurer, and to comply with all applicable laws and regulations
• Service provider has the required service capability
• Succession issues are addressed to ensure a smooth transition when ending or varying an agreement with a provider
Explain FSCO position regarding personal information and privacy requirements regarding UBI data
• Data collected may be assumed to be about individual. Results in personal info as defined in PIPEDA
• Even if driver not identifiable (family car), FSCO consider it as personal info and should be handle appropriately
• Insurer responsibilities
i. Consent documentation and associated collection
ii. Use/disclosure of personal info by insurer (3rd party)
iii. Meet requirements in privacy legislations
iv. Consider privacy-by-design principles
Discuss data consideration: Data Accuracy
Insurers:
• Reasonable efforts to ensure that the data is accurate
• Ensure compliance with the approved UBIP discount
• Ensure that action is taken to fix any data that can be shown to be materially inaccurate within a timely manner
• Have processes to resolve any inquiry that a consumer may have about the accuracy of the data used for rating
• Be prepared to deal with selective or inaccurate data reporting: Unplug device at certain times
Discuss data consideration: Data Security
Insurer:
• Ensure that the data capture, transmission and analysis are all done within a secure environment
• Responsible for ensuring that it, and any 3rd party provider, maintains effective security standards for personal info
Discuss data consideration: Data Storage
Important that personal info/data is not kept for longer than is necessary
• Must demonstrate that it has a procedure for appropriately managing any personal info
• Personal info should be deleted or anonymized once there is no clear business need to retain the data
Discuss data consideration: Termination of Participation or Policy
Insurers must ensure that no further data is received or accessed after a consumer terminates participation in a UBI program or terminates the policy
Discuss UBI Program Costs and the impact on Insurers Expenses
- Should cover all costs or enrolling in a UBI program, including the cost of any device installation and any ongoing costs of operation or maintenance
- Must include this info in a filing regardless of whether the insurer has factored this cost into the rate determination assumptions
- Over time, the on-going operational costs will be taken into account in determining the discount
Discuss UBI Program Filing
- Recognized that there may be no Ontario-specific data
- Must submit annual reports to supt about annual changes in UBIP discount (and average rate level)
Filings must indicate:
• Which consumer behaviours are being measured (acceleration rates, speed, distance)
• How this data is measured (Frequency, occurrence, relevant thresholds)
• How this data is normalized and categorized for rating purposes (Total occurrences, averaged)
• All relevant claim/loss data that supports the risk rating
