General Insurance Code: making information publicly available

The General Insurance Code Governance Committee has published a report of its review of General Insurance Code subscribers’ implementation of the obligation to make certain information available.

Amongst other things, the 2020 General Insurance Code required subscribers to:

  • have a publicly available policy on their website on their approach to the development and distribution of their products for appropriate target markets;
  • provide applicants for or renewal of a home building insurance product, but not a strata insurance product, with access to a calculator that is periodically reviewed and updated to enable them to estimate their sum insured;
  • have information about applying for Financial Hardship support on their website. The information will set out the types of support options that may be available, and how Financial Hardship support can be accessed;
  • make readily available information about insured’s right to make a Complaint, their internal processes for dealing with Complaints and their external dispute resolution provider, to be published on their website, other digital platforms and in their relevant written communications; and
  • provide information about the Code and the Code Governance Committee on their websites, in their product information and in other places they consider it appropriate to do so.

The report says that four out of the 14 Code subscribers (29%) complied with all five public-facing

The requirement for subscribers to have a publicly available policy on their approach to the development and distribution of their products for appropriate target market on their website) was the most accessible public-facing obligation.

By contrast, the requirement to publish a sum insured calculator was the least accessible public-facing obligation – the calculators of five of nine Code subscribers who made their calculators available on their
websites by the due date were accessible via three or four clicks from the website homepage.

The Report recommends a model for making information publicly available, regardless of an organisation’s size and resources.

The report says that digital accessibility is important in an era where consumers are increasingly using
technology to access information. Given that the information that is the subject of these obligations is intended to provide assistance and support to consumers, it is important that they are visible and within easy reach on websites.

Based on the analysis of Code subscribers’ implementation of the public-facing obligations, the Committee has five recommendations for improvement.

1. Code subscribers should have robust and well-structured implementation programs to ensure they meet the implementation timeframes for the General Insurance Code of Practice.
2. Code subscribers are encouraged to broadly interpret and apply the scope of the public-facing obligations contained in the Code to maximise transparency for consumers.
3. Code subscribers should ensure the webpages containing information and/or policies for the public-facing obligations contained in the Code are easy to find to maximise accessibility.
4. Code subscribers should not confuse the implementation timeframes of their Code obligations with their statutory obligations.
5. Code subscribers are encouraged to complete post-implementation reviews to identify areas for improvement, including the use of website analytics to track and improve accessibility.

The Committee noted that information can also be inadvertently omitted when systems changes occur.

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David Jacobson

Author: David Jacobson
Principal, Bright Corporate Law
About David Jacobson
The information contained in this article is not legal advice. It is not to be relied upon as a full statement of the law. You should seek professional advice for your specific needs and circumstances before acting or relying on any of the content.

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