Remediation steps and formal warning
After identifying the issue, the insurer carried out an internal review to determine the cause, scope, and duration of the breach and apologised to affected customers. It introduced additional training and guidance for underwriting teams, implemented system changes to automate consent processes, and adjusted quality assurance and monitoring procedures to help detect similar issues. In deciding on a sanction, the Life CCC considered the length of time over which the breach occurred, the number of customers affected, the fact that a customer complaint rather than internal monitoring led to discovery, and the remediation and longer-term rectification measures taken by the insurer.