WMP 05/12/2023
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From: WMP
To:
Sent: 05 December 2023 10:50
Subject: Insurance ABl MOU requests
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Hi everyone,
Sorry if you’re not the right person to send this to — I’ve tried to take out the names of people I know ren’t involved in these requests but please pass onto the relevant people.
WMP have noticed a significant increase in requests from insurance companies since the new MoU came into play last year. | was doing some data analysis for our team over the last few financial years and have got these figures:
Financial year Incoming requests
2021/22 1519
2022/23 1612
2023/24 1729
The 2023/24 figure is only from April until the end of November — so we’ve had more requests in the last 8 months than we did for the whole previous 12 months. Breaking it down on a monthly average on what we’ve received so far in 2023/23, we’’re looking at an additional 80 requests per month which is a 60% increase in the work.
The reason that | think we’re seeing this increase is the new MoU (attached for ease of reference), specifically changing the legal basis from consent to legitimate interest; I think that it’s taken away the blockage that was getting consent, and now there’s really nothing in their way to send requests to police.
I’ve looked through the MoU and can’t really see anything specific about where we’re able to challenge why the insurance company are submitting the request. As long as they submit the appendix D form, and pay the fee, it doesn’t seem like there are restrictions (unless the case is on-going or would impact other policing work) and in fact, the MoU acknowledges fees can be applied because we can’t be sure a crime has been committed. I don’t want to be a barrier for data sharing, but insurance companies were making decisions before the legitimate interest basis and I don’t understand why they now need 60% more information from WMP than they did before the updated MoU.
There are costs associated with these disclosures which could be seen as income generating for the force, but I wonder where these additional costs are being offset. Are the insurance companies saving money, because they are now able to challenge more claims based on police information and therefore refuse pay outs? Or are the additional costs of obtaining these reports being passed onto the consumers by increasing insurance prices…
[redacted] said she’ll take this to national tomorrow but I wanted to share with the region too — this
probably falls more into the arena of “additional disclosure” that [redacted] proposing setting up, but could we add it to the agenda for our next regional as an exception until that meeting gets up and running?
Maybe we could look at the increase that all forces have received, and use this data to review the MoU. We’re after the 6 month implementation of the process now, as I think this fits into the “emerging issue” criteria in the review section.
If we can add it to the agenda for regional we can save discussion until then, but if not, I’m happy
to set a one-off meeting up for the new year.
Thanks
[redacted] Civil Disclosure Unit Manager
Civil Disclosure Unit (CDU) | Information Management
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