GFIA Shares Tips On Dos And Don'ts For Open Insurance

Purpose-driven data-sharing

Do have a clearly defined and

predetermined purpose or goal to data sharing. Possible goals could be to enable the

insurance sector to develop new and innovative products.

Don’t impose (mandatory) data sharing in areas where there is no clear issue that needs to be addressed. New data-sharing or open- data initiatives should not impede existing data-sharing initiatives and open-data ecosystems.

The data owner in control

Do give data owners the ultimate control over who is allowed to access their data and under which conditions. A definition of who the

data owner is in an open-insurance

framework, should be determined at the level of each jurisdiction in which such a framework exists. Furthermore, a workable consent

mechanism should exist.

Don’t let data-sharing or open-insurance initiatives interfere with existing privacy and data protection laws.

Setting the appropriate scope

Do clearly define which data sets would be subject to data sharing. Data usage, access and sharing should also be considered in the

broader context of cross-sectoral data sharing.

Don’t oblige insurers to share their

intellectual property, business-sensitive information or proprietary data that they have generated and that is the outcome of their own work.

An appropriate framework for insurance

Do carefully consider the lessons learned from possible previous open data-sharing initiatives in the banking and payments sectors. These lessons can be applied to the

specific context of the insurance sector to avoid repeating mistakes.

Don’t simply copy and paste open-banking or open-payment schemes and apply them to the insurance sector and insurance data. There are likely to be unintended consequences and they may not yield the desired results.

Level playing field

Do ensure a level playing field for the different parties involved in data sharing. The principle of same activities, same risks and same rules should apply. It is crucial to ensure

that consumers can count on the same level of protection, regardless of who serves them, bringing all involved parties within the scope of

the existing rules.

Don’t allow unregulated or unsupervised third parties to access insurance data. Furthermore, non-reciprocity of data sharing

must be avoided by ensuring the progressive openness of common data spaces in other economic sectors. Also don’t exclude any current third-party players, (such as

intermediaries) from the insurance sector value chain from gaining access to an open insurance framework.

Data security

Do require high levels of security to be in place to ensure the protection of data and clarify where liability lies in the event of a breach.

Don’t allow access to insurance data for third parties that do not demonstrate that they meet the same high level of data security as the financial sector.