How to realize the IDD-compliant provision of information in the online sales process
As a basic principle all mandatory information, in our case the IDD-compliant provision of information shall be provided to the client on paper, on the website or on a durable data carrier (paperless). Hence the information shall be provided:
- in a clear an accurate manner, comprehensible to the customer
- in an official language of the Member State or in any other language agreed upon the parties
- free of charge
Especially the digital (paperless) submission of the relevant information and documents is attractive to the client. Travel documents such as the boarding pass and vouchers are often stored in a special App, e.g. the wallet. Consequently, a costumer who concludes an online insurance contract expects a quick and paperless submission of the relevant documents in order to save them easily on the computer.
Is a Durable Data Carrier Mandatory?
The provision of the relevant information on a durable medium shall be permitted only, if it is appropriate and the customer has been given the option to receive the information on paper or on a durable medium and has chosen the latter medium. Hence the customer must have the opportunity to actively agree to receive the information either on paper or digital. This may be visualized in the customer journey as follows: The costumer shall give its consent by accepting / clicking a checkbox. We recommend obtaining the consent right at the start of the customer journey, e.g. together with the acceptance of cookies.
It should be noted, that a costumer is entitled to receive the information also on paper. Assuming that the submission of information/documents on paper is not provided for at all, the respective consent shall be obtained from the customer.
Provision of Information via a Website
The relevant information can also be provided via a website:
- if the access to the website is personalized or the information is appropriate,
- and if the customer has given its prior consent to the provision of the information via the website
- and the customer is informed via electronic message on which website and where exactly on this website the information can be accessed
- and if it is guaranteed, that the information is accessible as long as necessary
According to Art 5 para 1 of the Austrian general good rules for insurance intermediaries the relevant information shall be provided to the customer in German language. Consequently, the customer has to give his/her explicit consent in order to receive the information in any other than the German language. If you want to provide the information only in English, we recommend obtaining the respective consent from the customer right at the start of the customer journey.
In a nutshell, the design of the customer journey with regard to the mandatory consent requirements (exclusive use of the English language, exclusive digital provision of the relevant information) might look like as follows:
If the client does not give his/her consent by clicking the provided button the customer journey cannot be entered.
In principle, the IDD gives the opportunity to distribute insurance products entirely digital. Ensure your compliance.
Find all related IDD-articles here.