FSCO UBI

• Savings for drivers: control over own rates, based on usage patterns and driving behaviour
• Reduce hazards for everyone: fewer accidents and less congested roads from safer and less frequent driving

1. Personal info and Privacy req'ts
2. Personal Telematics Data: Insurer Transparency and Consumer Consent
3. Complaints, Inquiries and Customer Support
4. Driver Education and Transparency in Rating and Risk Classification Systems
5. Changes in Rating
6. Limitations on Collection and Use of UBIP Data for Insurance Purposes
7. General Rate-Filing info
8. UBIP Program Costs and the Impact on Insurer Expenses
9. Reasonability of UBIP assumptions and the provision of adequate support
10. Compliance with the Unfair or Deceptive Acts or Practices (UDAP) regulation
11. General Data Considerations: accuracy, security, storage, at termination
12. Roles and Responsibilities: Insurers and Third Party Providers

Treat telematics data as personal info and comply with privacy legislation (PIPEDA). Insurers:

• incl consent doc'tn
• ensure collection and use of personal info meets privacy req'ts
• seek legal advice on privacy req'ts if needed
• privacy-by-design for UBIP

• voluntary
• informed consent incl'd in enrollment
• able to enroll without sharing info for non-UBIP purposes.
• able to opt-in to use of personal info for non-UBIP purposes (rather than opt-out)
• insurers should facilitate use of personal UBIP data to transfer to another insurer’s UBIP.
• driver and insurer obligations (consent form); driver = install and use device; Insurer = use info only to calc discount
• promotional materials clear, fair and not misleading

• available in all territories
• make ware lowest and another is offering
• facilitate entering into another insurer's program
• UBIP start‐up costs as R&D

• What personal info is collected,
• How is info used,
• Who may have access,
• When could info be disclosed to others
• Customer rights wrt. info

Provide forums for p.h.'s to question and challenge any issue or disagreement with data collected

Rating models clearly communicated to consumer at all times

1. discount
   • how to qualify
   • max / min
   • period used to calc
   • regular feedback on driving habits.
2. consumers have access data and can correct inaccuracies

solely for discount, not to:

• decline, cancel or refuse to renew or
• confirm current rating variables (location of garage)

• if enrollment discount is only offered one term, or
• if actual discount is expected to differ materially from enrollment discount
• report changes in avg UBIP discount and resulting changes in avg rate at enrollment and each renewal

• To encourage participation, insurers should cover all enrollment costs incl
  • device installation
  • ongoing operation / maintenance
• May treat start-up as part of R&D and not allocate, but over time ongoing op costs will need to be allocated to p.h.

• Which consumer behaviours are measured (acceleration),
• How is this data measured (frequency) and normalized (averaged)
• Loss data that supports rating.

• UBIP be available in all of its territories
• make consumer aware of lowest rate among affiliated insurers
• insurers not offering UBIP need to make consumer aware of potential discount from affiliated insurer that offers UBIP

1. Data Accuracy
   • fix data inaccuracy in a timely manner
   • process to resolve inquiry about data accuracy
   • prepared to deal with selective data reporting
2. Data Security
   • data capture, transmission in a secure environment.
   • high security standards
3. Data Storage: delete once no need to retain
4. Termination: no further data is received or accessed

• Insurers:
  • accountable for collection, use or disclosure of personal info
  • ensure similar level of protection from TP
  • info collected by TP free of manipulation, and consent is collected
• Contracts with each TP to confirm:
  • TP ability and commitment to ensure level of protection >= insurer, and to comply with laws
  • service capability
  • smooth transition when ending agreement with a TP