Ms MaryRose McGovern:

I might come in here. We are very conscious of the work the Central Bank is doing on differential pricing. It is doing a deep dive into the processes within organisations and the reasons behind that. We have made a number of submissions to the Central Bank in the context of its work to review the consumer protection code in order to share our perspective on certain aspects. Within those communications, we have suggested that the use of data analytics to calculate a premium is something that should be regulated. It is obviously a matter for the Central Bank, as the regulator, to determine whether such a practice should be prohibited or whether it is permitted. Similarly, if a loyalty penalty percentage is in place for customers who want to stay with a certain insurance provider, then perhaps there should be a limit on what that percentage should be and that should be communicated in a way that is clear in order that people can make an informed decision.

Going to back to the Chairman's question, we are very conscious when we see a complaint about premium rates that there are certain limits. On the whole issue of commercial discretion and the European regulations regarding the calculation of premiums, there is a limit to what this organisation can do. Nevertheless, when we see a complaint of that nature, we look to the detail that a complainant can make available to us in order to examine whether there are aspects of differential pricing behind the complaint about a premium increase or whether it is simply that the customer in question had an accident and his or her premium went up. One of the key pieces of information is that every complaint is individual and will turn on its own set of circumstances.

If the Chairman would like details of the numbers of complaints received relating to premium increases, the best we could do would be to confirm that in writing. We could provide numbers for the past couple of years and that would give the Chair more specific information.