Dáil Éireann Debate, Tuesday - 25 July 2023
313. Deputy Róisín Shortall asked the Minister for Finance if his attention has been drawn to concerns such as those raised in correspondence (details supplied) regarding the acquisition of insurance cover; whether there exists standardised guidelines for insurance companies in terms of dealing with customers who do not have email addresses; and if he will make a statement on the matter. [36170/23]
Amharc ar fhreagraI note that the question relates to a specific case involving an insurer requiring a customer to have an email address to engage with its services. As the Deputy will appreciate, I am unable to comment on individual cases.
However, in order to be as helpful as possible, my officials contacted Insurance Ireland, and the Central Bank of Ireland, in relation to this query. On a general level, Insurance Ireland has advised that there are no standardised guidelines for consumers who do not have email addresses. However, Insurance Ireland stated that all of the primary insurers in the Irish market have call centres or utilise a network of brokers enabling consumers to transact business either over the phone or in person. I understand that some insurers for niche products may only offer cover directly via electronic means.
However, due to the limited details supplied, it was not possible to provide a comprehensive response. Notwithstanding this, Insurance Ireland operates an Insurance Information Service for members of the public who have queries, complaints or difficulties in relation to obtaining insurance, which may be of assistance. This can be accessed by calling 01-676-1820 or emailing feedback@insuranceireland.eu.
It should also be noted that technology-driven risks was one of the key drivers of consumer risk identified in the Central Bank of Ireland’s Consumer Protection Outlook Report 2023. The Central Bank expects that “as firms move from traditional delivery channels toward increasing reliance on digital interaction with consumers, they must manage this transition respecting the legitimate expectations of consumers”. Additionally, “adequate consideration must be given to consumers who rely on traditional means of interacting with firms, including the opportunity to have human interactions where necessary”.
Firms must also comply with the Central Bank’s Consumer Protection Code 2012. This includes a requirement that where a regulated entity has identified that a personal consumer is a vulnerable consumer, it must ensure that they are provided with such reasonable arrangements and/or assistance that may be necessary to facilitate them in their dealings with the regulated entity.
Finally, it may interest the Deputy to know that digitalisation has been identified as one of the key themes of the ongoing review of the Consumer Protection Code. The Discussion Paper published by the Central Bank as part of this review (October 2022), notes “the use of technology by consumers should serve their interests and not be viewed as an opportunity to take advantage of their behavioural vulnerabilities, or to increase information asymmetries between consumers and firms”. I understand that a Consultation Paper from the Central Bank, setting out specific proposals on how the Code should be updated and improved, is expected to be published in Q4 2023.
