Policyholder Protection Rule 13: Member data to be provided to Sanlam

Complete and accurate member data enables members to seamlessly claim their benefits and have access to material insurance information and value adding services.

The amended Policyholder Protection Rules (PPR) under the Insurance Act 18 of 2017 requires that insurers have up to date, accurate and complete member identity numbers and member contact data at all times.  Insurers collect this data from policyholders (employers or retirement funds) on an ongoing basis, with the progress closely monitored by the Financial Sector Conduct Authority (FSCA).

Policyholder requirements to ensure compliance (existing policyholders):

Monthly bordereaux schedules are required to be submitted by the policyholder to the insurer.

In addition to relevant data, such as contributions for each insured member, the PPR’s require that at a minimum the data collected by the insurer should include:

  • Member full name;
  • Member identity number;
  • Member mobile number and/or Member email address.

Implications of not providing member contact details to Sanlam:

Sanlam Group Risk (hereafter referred to as Sanlam) is required to report the status of the member contact details to the FSCA on an ongoing basis to enable them to track the progress against their target and deadline. 

Failure to reach this target will have serious implications, and as a result, Sanlam will have no option but to initiate termination proceedings against a policy should the member data remain outstanding.

Should it be the case that the required member contact details for a minimum of 95% of members cannot be provided, a formal letter, signed by an authorised individual within the organisation, must be sent to Sanlam specifying the reasons for failure to provide member contact details and stating actions taken to source and provide the outstanding data.

Member data at inception (new policyholders):

Sanlam will by no means be able to confirm risk and/or the inception date of a scheme without the required member data imposed by the Policyholder Protection Rules legislation.  The member data at inception date should contain at a minimum full names and surnames, ID numbers, salary and cell phone/mobile numbers and email addresses.