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The Article 29 Working Party guidance suggests that when a policyholder wants to switch insurance companies, the portable data and new data processing should be limited to the data required for the new product. This interpretation would be mutually beneficial for consumers and insurance companies:
Consumers would have more control over their data, as they are aware of which data is necessary for the insurance product they are interested in purchasing.
It would enable insurance companies to fulfil their obligations as data controllers without disclosing confidential business information, such as their underwriting criteria, their risk and pricing tools and structures to their competitors.
However, Insurance Europe pointed out that, in the insurance context, there may be different types of data that are relevant and not excessive for the different products, which may be challenging for the insurance company receiving the portable data.
Insurance Europe welcomed the timely launch of the Working Party’s consultation. It pointed out that it is crucial to ensure that stakeholders have sufficient time to provide input and that the industry has sufficient time to prepare for implementation. Consultation periods of at least three months and ongoing opportunities to contribute to the process will help to ensure that European insurers and consumers fully benefit from a high-quality new data protection framework.