The general insurance industry provides insurance cover for consumers in relation to their homes, home contents and motor vehicles, and for other visible and invisible assets. Insurers require the provision of a considerable amount of personal data in advance of issuing a quotation, and require that information to be comprehensive and accurate. They may decline claims if they later discover material inaccuracies in the information the consumer provided.

Consumers have an interest in disclosing sufficient and accurate information, in order to gain cover, and to ensure their claims are paid out. They also have an interest in the protection of data about themselves, and in fair dealing by the insurer.

The Financial Rights Legal Centre (Financial Rights) represents the interests of consumers across the financial services sectors, including in general insurance.

The Australian Government announced in November 2017 its intention to introduce a Consumer Data Right (CDR). It is being rolled out sector by sector. The stated objective of the CDR is to increase the flow of personal data within sectors. This the government anticipates will generate greater competition among providers, reduce costs and lead to better service to consumers.

The CDR has been first applied with the intention of achieving “open banking”, but progress has been slow. The scheme is being extended to the energy and telecommunications sectors. The government is also now working toward what it calls “open finance”, including general insurance.

In preparation for the expansion of the CDR to 'open insurance', Financial Rights commissioned a study of consumer privacy in the general insurance industry.

The study comprised three linked segments.

• The first segment was an examination of the general insurance industry, with an emphasis on the current data practices and privacy safeguards of key players in the industry.
• The second segment complemented the desk analysis with field research, whereby the access rights of individuals were exercised to ascertain and access data held about them by their insurer. The purpose of this was to document the quality of the data held by insurers, and the practicality of the processes by which that data is accessed.
• The third segment of the study considered how the implementation of CDR might affect both data quality and services to consumers. The CDR's ongoing fluidity meant it was not possible to refer to established laws and procedures. Hence it was necessary to track changes, interpret intent, and then consider how the practices might be implemented in general insurance.

A number of privacy issues of considerable concern were discovered as a result of this analysis.