The Insurance Group Ltd
Terms of Business for Clients
Definition – ”We/Us/Our” means The Insurance Group Limited, Falcon House, Eagle Road, Langage, Plymouth, PL7 5JY; Tel 01752 345333; [email protected]
The Regulator –The Financial Conduct Authority (FCA) is an independent watchdog that regulates financial services.
Our Financial Services Register number is 301133 and you can check our status and permissions at https://register.fca.org.uk/ or by contacting the FCA on 0800 111 6768.
Our Activities – The Insurance Group is a trading name of The Insurance Group Ltd and we are independent insurance intermediaries who arrange insurance solutions chosen from a wide range of insurance providers on behalf of our clients. We also assist with any claims that you may need to make. The FCA has authorised us to advise, arrange, deal in and assist with the placing and administration of all types of General Insurance policies.
We are also authorised to undertake Credit Broking (where we act as a credit broker)
Our Service – We can act both as agent of insurer, and on behalf of you, the customer. We have in place management controls to deal with any conflicts of interest that might arise. Unless we advise you otherwise, we are acting on your behalf.
We also act on behalf of insurers when collecting premiums under risk transfer (See “Money” section).
We will ask questions to enable us to assess reasonably your insurance requirements, this may include checking information that we already hold about you and your existing insurance arrangements with us and other parties.
We will provide you with advice and guidance, after assessing what you want and need and recommend a suitable policy based on our experience of dealing with similar risks.
If we use the services of another intermediary to place your insurance we will advise you of the name of the intermediary we use and the name of the insurer.
Our Product Selection – We offer products from a wide range of insurance companies. Our selection usually involves presenting to a reasonable number of insurance companies that will insure for the risk at hand, and this is called a fair and personal analysis of the market.
Sometimes we may only approach a specified number of insurers and this is a Panel, or in some cases, we may only approach one insurer in either case, we will tell you the basis as part of our selling process. We can also provide a list of the companies that form the Panel we have approached at quotation stage.
Duty of Disclosure – It is important that you understand that any information, statements or answers made by you to your insurers or us are your responsibility and must be correct. Your attention is particularly drawn to the importance of the declaration and signature on any insurers’ proposal forms, as failure to disclose facts material to the insurance or any inaccuracies in your answers may invalidate your insurance cover and claims may not be met. The disclosure of information not only applies at commencement and renewal of your policy, but also at any time during the period of insurance. Facts material to the insurance, are matters of information which may influence your insurer as to the acceptability or otherwise of your Proposal or Renewal and must be disclosed immediately. You are advised to keep copies of documentation sent to or received from us for your own protection. Please do consult us if you are in doubt on any aspect.
Where the terms of your insurance require you to notify your insurers of any increase or alteration in the nature of the risk, it is your obligation to provide such information to us so that insurers can be notified in accordance with the requirements of your insurance. All answers or statement on a proposal or claim form or other material document are your responsibility and you should always check the accuracy of the information you provide to us, even where we assist in the completion of any aforementioned document. Some insurers will wish to conduct a credit check on policyholders and prospective policyholders and this will likely be recorded on your credit record. You need to contact us if you do NOT consent to such a check being undertaken, however this may affect the ability of an insurer to offer its best rates and payment by instalments.
Quotations – Unless otherwise agreed Quotations will be valid for a period of thirty (30) days from the date the quotation is produced.
Awareness of Policy Terms and Claims Notification Procedure – When a policy is issued you are strongly advised to read it carefully, as it is that document, the schedule and any certificate of insurance that is the basis of the insurance contract you have purchased. If you are in doubt over any of the policy terms or conditions, please seek our advice promptly.
Please pay particular attention to the claims reporting procedure set out in the documentation and adhere to the guidelines. You should not admit liability nor agree to any course of action, other than emergency measures carried out to minimize the loss, until you have agreement from your insurers.
Should you have occasion to claim on your policy you must also notify us at the earliest opportunity in order that we can provide you with our full support.
Documentation – We reserve the right to retain certificates at this office until all payments due under the policy have been made.
You must not assume that ANY cover is in force until such time as you have received written confirmation that cover has been arranged.
Money – We will hold money that you pay to us in accordance with the regulators rules or under a risk transfer agreement with insurers. This will include holding your money in the following way.
A non-statutory trust client bank account that allows us to use the money held in trust on behalf of one customer to pay another customers premium before we receive it from that customer and to pay premium refunds or claims before we receive payment from Insurance Companies. This is a standard practice within the Insurance Industry and we cannot use your money for any other purpose. We do not pay any interest on premiums held by us in the course of arranging and administering your insurance. Unless you tell us otherwise, you are consenting to us holding your money in this way.
By holding your money in this way, it means that in the event that this firm becomes insolvent your money remains protected.
In arranging your insurance we may employ the services of other intermediaries who are regulated by the FCA and your premium may be passed to these intermediaries for payment to insurers. These firms are also required to hold clients’ money in a separate trust account. We will also inform you if at any time we are required to pass your premium to firms that operate outside the UK where the protection may be different. Should you not wish us to pass premiums to a firm outside of the UK please inform us.
Risk Transfer – If the insurance undertaking accepts Risk Transfer then the premium you have paid to us is deemed to be insurer money and is banked in our non-statutory trust bank account. This means that if our firm fails financially the insurer suffers the bad debt and not you.
If the insurance undertaking does not accept Risk Transfer then we hold the premium on your behalf in a non-statutory trust bank account. If our firm fails financially before we have paid the premium to the insurer then any bad debt would be your responsibility. Due to the nature of the non-statutory trust and exchange of letters between us and our bankers, no other creditors have any lien whatsoever on the account.
We can confirm whether or not the insurance undertaking we recommend accepts Risk Transfer on demand.
Our Remuneration – We usually receive a commission from the insurance provider with whom we place your business, and this is expressed as a percentage of the premium you pay and in such a case, the commission will be paid to us either when we are in receipt of cleared funds from you (or the premium finance company, if one has been used) or, when the insurer has received cleared funds from us in respect of the premium due under your policy. With certain insurers we may receive an additional bonus if they reach a profit target. The individual agreements we have with each insurer will determine which of the two methods above is used to make this transfer of commission. We also receive commission for arranging finance agreements for the payment of insurance premiums and this is usually expressed as a percentage of the individual loan and is paid to us directly by the premium finance provider. We may also receive a commission or fee for passing introductions to other professional firms.
Charges – We reserve the right to make charges for the arranging, amending, renewal and cancellation of any general insurance. These charges will always be advised to you before you purchase the insurance or before they are incurred and are as follows:-
New Annual Policies – Nil
Renewal of Annual Policies – Nil
Obtaining Duplicate Documents – £20.00
Any Mid Term Policy Alteration – £20.00
Instalment re-collections – £25.00
Payments not honoured by Bank – £25.00
Policy Cancellation with no return premium – £25.00
Policy Cancellation with a return premium – £25.00 plus commission (this amount to be deducted from the refund received from insurer)
All policies where the annual premium is less than £150.00 – £20.00
The above Charges may increase as administration costs rise.
For policies arranged with non-commission paying offices/syndicates or where the commission is inadequate to cover the cost of our service to you we will charge an additional administration fee which will be disclosed prior to inception of cover.
You are entitled at any time to request information regarding any commission which we may have received as a result of placing your insurance business.
Payment Options – You must be aware that cover is only in place where the premium has been paid in full or a credit agreement has been entered into for the collection of the premium. Where a premium has not been received within five working days of effecting cover, or an agreed instalment payment is not honoured your policy may automatically be cancelled or lapsed.
We will provide you with full details of all the payment options available to you when we provide you with your insurance premium.
If you choose to enter into a finance arrangement, your details will be passed to a third party (insurer or lender) to enable them to contact you and you should contact us at the address given in this document if you do not want your details passed to that party. This finance arrangement will be subject to interest charges that we will confirm to you when providing the full details. Importantly, the arrangement you will enter into will be with the finance company not us. It is an entirely separate contract irrespective of the insurance contract. In the event of your failure to meet with the contractual obligations regarding payment the finance provider could approach the insurer to seek a termination of the insurance contract to recoup their outstanding finance arrears. You will be liable to pay their costs and charges if you do not keep up your repayments and cover is cancelled under your policy. This is because the agreement is between you, the policyholder and the finance company direct, not us or the insurer.
It is important that you read the finance agreement that is sent to you before you agree to enter into such an agreement.
We do not charge any fees to you for introducing you to a credit provider
If you are a consumer as defined under the Consumer Credit Act, you will have the benefit of a 14 day cooling off period.
Please Note: Your policy cover will cease if you fail to keep up payments on an instalment agreement or premium finance facility related to it.
Your Right to Cancel the Insurance Policy – Please contact us if you wish to cancel any policy that we have arranged for you. Customers acting outside their trade or profession (Consumers) will usually have a legal right to cancel policies for any reason, subject to no claims having occurred, within 14 days of receiving the full terms & conditions. A charge may apply for the period of cover provided and, in addition, an administration charge will apply as shown in the charges section above, cancellation under this right must be in writing, prior to expiry of the cancellation period, to our usual office address.
Your Right to Cancel the Mediation Contract – The Mediation Contract is the agreement between you and us for the insurance mediation services that we provide to you in respect of your insurance requirements. This contract commences from the date you receive our initial disclosure document and terms of business. You are entitled to a period of reflection during which you may decide to proceed or cancel and this period is 14 days. If you decide to cancel the mediation contract with us at any time we will retain in full any fees that you have paid.
Confidentiality & Security – We will observe the provisions of the applicable UK, EU or other data protection laws including the General Data Protection Regulation (GDPR).
All information provided by you is treated as confidential and only disclosed in the normal course of arranging and handling your insurance requirements. In order to provide our services we may need to disclose personal data to third parties including insurance companies, surveyors, adjusters, premium finance providers and other relevant parties who may require the information for the purposes set out in our privacy notice.
We may also need to transfer data to countries outside the UK and the European Economic Area that have alternative data protection laws, however this will be done with the appropriate safeguards.
To make sure you get the best possible price offer from our insurers, now or at any time and to protect their customers from fraud and verify your identity, the insurers may use publicly available data which they obtain from a variety of sources, including a credit reference agency and other external organisations. Insurance companies may use a credit check to ascertain the most appropriate payment option for you. Any credit check will appear on your credit report whether or not a policy is actually incepted with us.
Insurance Companies exchange information with other Insurers and the police through various databases in order to check information to prevent fraudulent claims, detect people who break the law by not taking out insurance and enable insurers to pursue claims following accidents. Full details will be sent with your policy.
We maintain data security procedures to protect against the loss and protect personal data. We will not cause or permit any unauthorised disclosure of such information of which we shall become possessed. These confidentiality provisions shall not apply to any information:
- Which, at the time it is provided to us, is already in the public domain.
- Which is disclosed to us or by a third party not subject to similar duties of confidentiality.
- Which enters the public domain through no fault or breach by us of our obligations under this provision.
- Which is required to be disclosed by us pursuant to a legal obligation or to enable the Financial Conduct Authority to fulfil its regulatory function.
On occasion we may need to collect and use special categories of personal data such as health information and/or information regarding criminal convictions and offences in order to provide you with our services as an insurance intermediary and you consent to such processing. You may withdraw your consent at any time however if you do so we may not be able to continue providing you with our services if the information is integral to the cover.
Further information concerning our privacy notice please request a copy by contacting us on 01752345333 or emailing [email protected].
Where you have consented or we are legally permitted to do so we may send you information concerning products and services offered by The Insurance Group by post, telephone or email. If you would like us not to send you this type of information please contact us at the address above, by telephone 01752345333 or by email to [email protected]
Call recording – All calls, incoming and outgoing are recorded to evidence transactions and improve processes and quality.
Complaints – It is always our intention to act in the best interests of our customers, however we are aware that occasionally it is possible that we may fail to meet your expectations. If for any reason we have not met your expectations, let us know as soon as possible, by calling us on 01752 345333 or write to Laurie de Mel, The Insurance Group, Falcon House, Eagle Road, Langage, PL7 5JY or email us at [email protected].
If we are unable to resolve the issue to your satisfaction by the end of the third business day following receipt, we will formally investigate the matter. You will receive an acknowledgement of the matter together with a copy of our complaints process promptly and certainly within 5 working days. We will then aim to investigate and provide a resolution as quickly as possible, informing you of a final response no later than 8 weeks.
If you are not happy with our response, or the position after a period of 8 weeks, you may be eligible to refer your complaint to the Financial Ombudsman Service (FOS) for an independent assessment and opinion.
The FOS Consumer Helpline is on 0800 023 4567 (free for people phoning from a ‘fixed line’ (for example a landline at home) or 0300 123 9123 (free for mobile-phone users paying monthly charge for calls to No’s starting 01 or 02). Alternatively you can contact them at Financial Ombudsman Service, Exchange Tower, Harbour Exchange Square, London, E14 9SR. www.financial-ombudsman.org.uk.
Your Insurers also maintain a complaints procedure, details of which are contained in your policy.
Financial Services Compensation Scheme (FSCS) – If we are unable to meet our obligations, you may be entitled to compensation from the FSCS depending on the type of product and/or the circumstances of the claim. Further information is available from the FSCS helpline on 0800 678 110 or 020 7741 4100 and www.fscs.org.uk.