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Insurance Digital Onboarding > Protection of policyholders’ interests

Insurance Digital Onboarding

Protection of policyholders’ interests

When authorized insurers conduct insurance business over the Internet, they must comply with the Insurance Ordinance (Cap. 41) and other applicable regulatory guidelines and industry rules, including the Guideline on the Use of Internet for Insurance Activities (GL 8) and Guideline on Cybersecurity (GL 20), issued by the Insurance Authority (IA) to protect existing and potential policyholders.

If an insurer wants to provide sales via video conference, it is required to submit an application through the IA's Insurtech Sandbox and must obtain the approval of the IA before officially launching the service on a pilot basis to protect the interests of policyholders. The relevant application must comply with the following requirements of the IA:

  • Adequate control and monitoring measures must be introduced to ensure that policyholders are not adversely affected by the use of video conferencing, based on the principle of fair treatment of customers;
  • Adequate control and monitoring measures must be put into place to ensure that the intermediary provides all the required documents to the policyholder, and the information transmitted during the sales process must be clear, correct, complete and legible;
  • End-to-end video or audio recording of the entire video conference session must be carried out by the intermediary. If the policyholder opts out the video or audio recording, the intermediary must first record the policyholder’s wish to opt out via video or audio recording;
  • All video and audio recordings must be logged and identified with an audit trail to comply with relevant laws and regulations;
  • The insurer must conduct an ongoing assessment of the security of the video conference facility, including data protection and privacy, to ensure emerging risks and vulnerabilities are identified, mitigated and monitored in a timely manner, and that the control measures in place remain effective and comply with all relevant laws and regulatory requirements at all times; and
  • Appropriate training should be provided to intermediaries before they are allowed to conduct sales through non-face-to-face meetings using video conferences with clients, and the video conference facilities used must be provided by the insurer.