The beneficiaries of a master/group policy must belong to a clearly identifiable and genuine group, for example by virtue of common employment, association, occupation or activity and that connection must exist other than by reason of having the benefit of the master/group policy.
Customers whose only connection is that they purchased the same product or service from a vendor will not satisfy this requirement unless there is a genuine ongoing customer relationship (through the continuing provision of a non-insurance service) which gives rise to a clearly defined group. The continuing service provision should be indefinite or at least very long term and not limited by, for example, a 12 or 24 month contract.
Examples which would be considered a group:
- an employer holding a master/group policy to provide coverage for its employees;
- a sports club or other social club where members come together for an activity unrelated to insurance (e.g. rugby clubs, horse riding association);
- a bank or other investment service with an ongoing, long term relationship with its Customers for the provision of a service other than insurance e.g. a bank account, an investment product;
- a professional association which predominantly provides services to its members (such as training, publications, events) which are not related to insurance e.g. an association for local architects;
- a union which represents its members in the workplace; or
- a university or student accommodation holding a master/group policy to provide coverage for enrolled students.
Examples which would not be considered a group:
- individuals who have booked a holiday through the same travel agent;
- an association that exists only to provide special offers and insurance products to Customers (e.g. a supermarket association) where the members do not otherwise have a common interest and common reason for membership;
- individuals who have purchased a product or service from the same company where there is no ongoing relationship (e.g. extended warranty sold by a household appliance retailer, personal accident cover sold alongside the purchase of a concert ticket);
- an airline or hotel loyalty scheme;
- a mobile phone service provider;
- storage and removal firms (see ‘Thematic Review: Distribution of Storage and Removal Products 2018’ for further guidance);
- customers of estate agents or property managers; or
- an association where the predominant purpose or activity is to provide access to insurance products and other services are ancillary.