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Chartered Insurance Institute
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CII New Generation Group Launch Best Practice Guide

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 investigations".

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 them
  • 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 Section 29(3)
  • ensure their SPOC details are kept fully up to date with the IFB; and
  • 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 Protection Act."

 The DPA 29(3) Best practice IFB website is available here.



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 professional competence.

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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.

SPARC Methodology:

 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 considering:

  • 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 investigated.
  • 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 as follows:          

Graham Stait


Jenny Neale


David Clements


Nigel Fryer

NFU Mutual

Martin Kilshaw


Helen Yates

ACE European Group

William Talbot

Crawford Specialist Liability Services

Ryan Spies

Direct Line

Neiha Chohan

Atrium Underwriters