About dealing with us
We are a West Midlands based independent insurance intermediary. We have been doing this since 1995 and specialise in providing telematics policies. In this section we set out information we believe to be of commercial value to you. If you would like further information you can e-mail firstname.lastname@example.org or write to our Wholesale Manager, My Policy Limited, Prospect House, Halesowen. B62 8DU.
Law and Language
Our service including any agreement with you shall be subject to English Law and the jurisdiction of the English Courts. We will use the English language for all communications, including all contractual terms and conditions, and any information we are required to supply to you, a customer, or any other parties connected to an arrangement with us.
We will provide to you a separate agreement ‘wholesale agreement’ setting out our professional relationship, obligations of both parties, and general details about the services we will provide to you. We will do this as part of your registration and application process.
Method of Communication
Whilst your customers must be given a choice in the way you communicate with them, we will principally communicate with you using electronic means (usually this will be e-mail or some other means to enable you to access information electronically). During the process of dealing with us a customer must be given an option to receive information in this way, however if a customer requests information in a paper format you will need to agree this method with us.
Our Regulator and Insurance Distribution
The Financial Conduct Authority (FCA) is an independent watchdog that regulates financial services. We are a general insurance distributor and (other than Insurance Based Investment and Long-Term Insurance Contracts) are authorised (including products we co-manufacture) for advising, arranging, dealing, and assisting with the performance and administration of General Insurance contracts. We also distribute our products to other FCA authorised insurance intermediaries and insurance brokers and are also an authorised Credit Broker which allows us to undertake Credit Broking Activities. Our firm reference number is 307350 and you can check our status and permissions at www.fca.org.uk/register or by contacting the FCA on 0800 111 6768.
The General Data Protection Regulations (GDPR) and Data Protection Act (2018)
My Policy shall process data responsibly, fairly and in strict accordance with The Data Protection Act (DPA) 2018. The General Data Protection Regulations (GDPR) effective 25th May 2018 supersedes the Data Protection Act 1998 modernising data protection law and requiring enhanced disclosures about what we do with data including (but not limited to):
- Our lawful bases of processing;
- The information we collect, including GPRS data, and how we use and share that information;
- How long we keep information, including the purposes;
- The technical and organisational measures we have in place to safeguard your information;
- A customer’s individual rights; and
- Our approach to marketing
Precise details relating to Data Processing including Data Breach notification form part a separate agreement ‘wholesale agreement’ setting out our professional relationship, obligations of both parties, and general details about the services we will provide to you. We will do this as part of your registration and application process.
It is important to take time to read the Data Processing and Data Breach notification clauses carefully. These clauses set out more fully the basis on which we will process (i.e. collect, use, share, and or transfer) and store a Customer’s information. It is your obligation to ensure you provide a copy of our customer privacy notice to all parties related to any insurance arrangement under any agreement with us. If you have given us information about someone other than a policyholder or potential customer, you are deemed to have their permission to do so.
Should you have any questions, including obtaining a copy of our customer privacy notice, or any further information about our approach to the DPA/GDPR you can e-mail email@example.com or write to our Data Protection Officer, My Policy Limited, Prospect House, Halesowen. B62 8DU.
Compliance with a Customers Best Interests
Our primary aim is to ensure, for any customer (or potential customer) to act honestly, fairly and professionally and in the customers best interest including giving customers information they might need to understand the relevance of any information we provide as well as objectively giving that information when it is most useful to a customer to enable informed decision making. If at any time during your agreement with us you require additional information from us in the context of our approach to compliance with a Customers best interests you can e-mail firstname.lastname@example.org or write to our Chief Executive Officer, My Policy Limited, Prospect House, Halesowen. B62 8DU.
We act in the capacity of agents for designated product providers (i.e. we specifically select insurance companies we do business with). We are required to have in place appropriate governance controls to help us satisfy the terms of agreements we have in place with such designate product providers and meet our regulatory objectives. In addition, we have in place effective organisational controls, including appropriate supervision to ensure we manage conflicts of interests which may arise or may be identified from time to time, including gifts and benefits granted and accepted, which may damage the interests of our relationship with either our distributors, you, or one or more customers.
When such conflicts do arise, which constitute or give rise to conflict which may entail the risk of damage to a distributor or a customer and we are unable to manage a such conflict effectively we will always take steps to inform you and all effected parties including a customer, outlining the action we have taken and reasons why. Where relevant we will usually set out any relevant options to enable the conflict to be mitigated.
In providing an insurance quotation or accepting to enter into a contract of insurance for a customer you consent to us, and any third-party companies including insurance companies, to conduct a credit search to verify a customer’s identity and assess a customer’s credit worthiness. These checks may also include information held on claims and anti-fraud registers, in the interests of preventing fraud. The credit check procedure records a 'soft' check that is still visible on a customer’s credit report, but these do not affect a customer’s rating. When potential lenders check a customer’s credit report, they will not see the soft inquiries. It is your responsibility to ensure customers are informed of our credit checking procedure.
We are remunerated in a number of ways for the distribution services we provide (including the contract of insurance we provide to you for your customer). This renumeration ranges from the fees a customer might pay us (i.e. policy arrangement fee), the commission that providers of insurance (i.e. the insurance companies we deal with) pay to us. From time to time we may also receive renumeration for passing introductions to other professional firms.
We do not have any arrangements whereby we share in the profit from a particular deal with a particular provider and we do not and shall always seek to carefully assess any remuneration scheme (i.e. bonus payments) we make to our staff based on performance to ensure that this does not conflict with our approach to compliance with the best interests of one or more customers or potential customers.
Insurance Companies we deal with
We offer products from a limited range of product providers (i.e. designate insurance companies). The processes we have in place mean that the products of these providers take account of our target market (i.e. a customer seeking a telematics or similar modern contract of insurance) and are designed with such characteristics. Our products providers include: Markerstudy Insurance Company Limited; AVIVA Insurance Company Plc; and AXA Insurance (UK) plc.
Product Oversight and Governance
The products we offer are underwritten by our designate product providers; however, because of the nature of telematics policies and our group company’s actuarial activities (My Policy Services Limited) we elect to involve ourselves as a co-manufacture of the telematics products we offer.
Our product design processes aim to ensure our products take account of the typical objective, interests and characteristics of our target customers, and do not adversely affect our target customers and prevents or mitigates any customer detriment we might identify.
This role requires us to have in place written processes which we follow stringently. This allows us to ensure our distributors (including our employees) have the necessary knowledge, experience and competence to understand the product and ensure it is consistent with a customer (or potential customers) demands and needs; even where our distribution chain is long, we aim to ensure this goal is met.
We regularly assess the financial strength of the Insurance Companies that we deal with. The process usually involves general observation of the financial ratings applied by independent rating agencies such as Standard & Poor's and A M Best published with other readily available information within industry guides, newsletters and press releases. Whilst we take care to deal with companies that maintain reasonable solvency margins, we cannot guarantee their financial ability to pay claims.
Our aim is to provide you with an acceptable level of service at all times; however, we are aware that, occasionally, it is possible that we may fail to meet your expectations. If for any reason we have not met your expectations, let us know as soon as possible, you can e-mail email@example.com or write to our Wholesale Manager, My Policy Limited, Prospect House, Halesowen. B62 8DU.
Financial Services Compensation Scheme (FSCS)
If we are unable to meet our obligations, customers may be entitled to compensation from the FSCS. Where insurance is arranged will be covered for 90% of a claim, without any upper limit, however claims under compulsory insurance, such as our own professional indemnity insurance and certain claims for injury, sickness or infirmity of the policyholder are protected at 100%. Further information is available from the FSCS helpline on 0800 678 1100 or 020 7741 4100 and www.fscs.org.uk.
The FSCS is the UK’s statutory fund of last resort for customers of authorised financial services firms. Compensation is usually payable if an authorised firm is unable or unlikely to pay claims usually because it has ceased trading or become insolvent.
Demands and Needs - duty to customers
It is your duty to give us and or collect a customer’s information when applying for or amending a customer’s insurance policy, we and or the insurer will ask several questions to assess the risk prior to agreeing cover. It is your duty to ensure that you collect answers to all questions raised by insurers or us honestly and reasonably. These questions are designed to enable us or the insurer to obtain a comprehensive picture of the nature of the risk to be insured, and only by asking such questions and receiving answers which are given honestly and with reasonable care, can we or the insurer be able to offer terms which are designed to meet a customer’s demands and needs.
The reason why this is vital and extremely important is that if you fail to tell us or the insurer something when asked or act deliberately or recklessly in making misrepresentations when answering questions, may leave a customer with no insurance protection; insurers may not pay a part or all of a customer’s claim and insurers may cancel that particular customer’s policy. A customer may subsequently find it difficult to re-arrange cover because information was not disclosed to an insurer when asked.