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PII - The Aftermath
 We have finally put to bed our firm's PII renewal. Every year, the process commences in mid-November and usually lasts until early January. Each year, we have pre-emptively put in a great deal of work refining our systems to deliver the data the Underwriter requires, and each year their questions get more detailed and wider-ranging, so all that careful preparation proves inadequate. Each year, there are Member firms that we have to keep chasing right until the final, final deadline.
It's all nail-biting stuff. It may not be apparent from my photograph, but actually I'm only 27. That's the effect of prolonged exposure to PII renewals. I am thinking of updating my Linked-In profile with an image of an Egyptian Mummy, and leaving it at that.
We've always worked hard with the PII, primarily out of the conviction that this is a really important bit of insurance, and it's better for all concerned if we handle renewals as effectively and responsibly as possible. To hear the complaints from one or two firms, you'd think that we were asking them to supply 100% of the information required by the Underwriter, instead of the (nearer) 1% that we have managed to knock it down to, thanks to our systems development. Of course, we accept that there's no grounds for complacency here, and we have an ongoing project to maximise the effectiveness of our practice-management systems, so that our Members are to the greatest extent protected from the practical impact of this kind of reporting procedure. The same goes for the RMAR.
Each year, when we approach our Members for supplementary data, it's difficult to know just how draconian one needs to be when it comes to issuing warnings about the effect of non-disclosure. Sometimes, when one looks at the responses on a data-capture form, one wonders if the respondent has even considered the implications of what he or she is saying - it is as if, because the form asks for an answer, then something - anything - is entered into the blank space, in order to keep ValidPath happy, as if this were simply a way of keeping our technical staff busy, to give themselves something to do.
In fact, we only tend to ask questions in relation to the data that we do not have immediate access to elsewhere. And, more importantly, we only ask for data which the PII Underwriter has requested - on the not unreasonable assumption that, if the information is required, then it must have something to do with (a) the risks being underwritten and (b) the premium we need to pay for our insurance. When a Member Firm either casually, or wilfully, chooses not to disclose its exposure to something critical, then that is bound to have some kind of knock-on effect at some stage: actions have consequences. And so, frequently, do inactions.
So, the PII renewal process does actually have some value, despite pushing me close to the brink of sanity. It forces us to think about our business, about the things we do which contribute to elevated risks, or potential liabilities. It requires us to move beyond a "it's just data" attitude when completing forms, to thinking about the value and importance of openness, transparency, and retaining good records. And it makes us think again about the real value of the advice we provide, and the difference it makes to our clients.
P.S. We deal with a really excellent PII specialist. You can find out more by clicking here.
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Kevin Moss, 06/01/2012 |
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