The CII Claims Faculty New Generation group is calling for
organisations to adopt a new Best Practice Guide relating to
requests made under Section 29(3) of the Data Protection Act. The
guidance has been launched after two years of work behind the
scenes with support from the Insurance Fraud Bureau (IFB).
The new guide aims to improve the quality of data sharing under
Section 29(3), which allows organisations to share data with a
third party in order to prevent and detect crime. It is aimed at
requests made in respect of claims, underwriting or financial crime
within the insurance profession.
The move follows original work from the 2013 New
Generation group that highlighted a series of issues with Section
29(3); namely that marked requests were in unmanageably high
volumes, often "non-compliant" and "added little to counter fraud
Organisations that agree to embrace this model
are obliged to:
- ensure their employees make requests only where it is
appropriate and necessary
- ensure that due consideration is given to requests received by
- provide a detailed reason to the requester in the event that
they are unwilling to disclose personal data
- ensure their staff are appropriately trained in the use of
- ensure their SPOC details are kept fully up to date with the
- ensure a representative attends and fully participates in the
IFB's regular forums.
Nigel Fryer, member of the Claims group said: "We embarked
on this project to try and make a difference in the profession.
Through the support and collaboration of insurers, solicitors and
other organisations we have produced this guidance which we are
sure will improve the way data is shared. With the IFB's support we
hope a number of the collaborators will sign up and help improve
our ability as a sector to detect and prevent fraud."
Ant Gould, director of faculties at the CII said: "The annual
new generation group programme was created to provide insurance
professionals with the opportunity to further their personal
development. As part of the programme, each group is asked to work
on a project of their own choosing that could make a real
difference to the sector and customer outcomes. After two years of
hard work I am delighted that the 2013 Claims Faculty New
Generation Group members' vision for change will finally be
delivered, with the support of the IFB, and they should be
commended on their dedication to improving standards - all outside
of their day jobs."
Stephen Dalton, IFB head of intelligence, said: "The IFB will
manage the administration of this CII initiative designed to ensure
consistent high standards across the industry. As well as holding
regular forums where adopters of the initiative can discuss and
resolve any issues, we will also be responsible for ensuring that
the guidance remains compliant with any changes made to the Data
The DPA 29(3) Best practice IFB website is available
Georgina Gold, public relations executive
Office: 020 7417 4447
Mobile: 079 1873 5107
Notes to Editors:
The CII is the world's leading professional organisation for
insurance and financial services. Its more than 100,000 members are
committed to maintaining the highest standards of technical
competence and ethical conduct.
A robust framework of learning and development solutions enables
the CII to support corporate partners and individuals across the
industry. It ensures that all members comply with minimum standards
and inspires many more to achieve advanced levels of technical and
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New Generation Group
The CII New Generation programme aids the development of future
business leaders giving participants further experience of market
issues. The programme takes on 40 candidates with five to ten years
experience from claims, London Market insurance, broking and
underwriting. Candidates receive training in leadership, political
lobbying, regulation and dealing with the media. Each group is then
asked also to identify and complete a project or initiative that it
believes could make a difference to the insurance profession.
The S.P.A.R.C. Methodology should be used to assist those
making a request and/or responding to a request under Section 29(3)
of the DPA to ascertain whether that request is compliant, by
- TheSubjectmatterof the data request and whether this has been
clearly set out in the Section 29(3) request.
- TheProportionality of the information requested in relation to
the investigation requirements of the requester.
- Whether there has been a clearArticulation of concerns by the
requester and how the requested data are relevant to one or more of
the Purposes, (i.e. the commission or threatened commission of a
particular crime, the apprehension or prosecution of particular
offenders and/or the assessment or collection of any particular
tax, duty or imposition of a similar nature).
- Consideration should be given to whether the data requested
areRelevant to the crime or taxation Purposes being
- The requestor should be able to clearly state whatCrime or
taxation Purpose they are investigating.
The IFB is a not for profit organisation funded by the
insurance industry, specifically focussed on detecting and
preventing organised and cross industry insurance fraud.
The members of the New Generation Claims Faculty group are
ACE European Group
Crawford Specialist Liability Services