Project Overview
A UK FCA-authorised personal lines insurer with 280,000 motor policies and an existing black box telematics pr...
Technology Stack
Compliance & Standards
The Challenge
A UK FCA-authorised personal lines insurer with 280,000 motor policies and an existing black box telematics programme (2G device — being decommissioned by MNOs) needed to build a next-generation smartphone telematics platform — replacing the physical black box with a mobile SDK, providing drivers with real-time feedback, and enabling usage-based insurance (UBI) with live pricing adjustments. FCA ICOBS (personal lines motor insurance), FCA Consumer Duty PS22/9, UK GDPR (telematics location data is personal data), ICO guidance on telematics and employment monitoring, PCI-DSS (premium payment), and App Store / Play Store data privacy requirements were mandatory. Budget: £150,000.
Our Approach
Mobile SDK Telematics Data Collection
React Native SDK (iOS + Android): trip detection (accelerometer + GPS — detects journey start/end automatically), driving behaviour scoring (harsh braking via accelerometer, cornering via gyroscope, speed via GPS vs HERE Maps speed limit data, phone handling via motion sensor).
Privacy by design
precise GPS coordinates anonymised at collection (stored as speed + road segment, not precise location), trip data stored on device for 30 minutes then uploaded to server (device-side anonymisation).
ICO telematics guidance
- location data is personal data under UK GDPR — privacy notice explicitly describes telematics data collection, frequency, and purpose.
- Real-
Driving score
- composite score (harsh braking 30%, cornering 20%, speed 30%, phone handling 20%) calculated per trip and aggregated monthly.
- Real-time feedback: post-trip notification (overall score, worst event during trip with advice — "You braked sharply twice — try to increase following distance").
Gamification
weekly leaderboard (anonymous — drivers opt in), monthly rewards for high scorers (premium discount or voucher).
FCA Consumer Duty
driving feedback must be fair, clear, and not misleading — score criteria disclosed in app.
Vulnerable customers
- drivers who flag anxiety around driving performance excluded from leaderboard and comparative features.
- Usage-
UBI pricing
base premium + driving score adjustment (±20% of base premium based on monthly driving score) + mileage adjustment (annual mileage estimate refined by actual GPS mileage).
FCA ICOBS
UBI pricing must be transparent — driver can see exactly how their score affects their premium (itemised premium statement).
FCA Consumer Duty value assessment
is UBI fair value for low-mileage, high-scoring drivers?
Annual value assessment
compare UBI premium vs equivalent non-telematics premium for all customer segments.
Underwriting
- telematics data shared with reinsurer (in anonymised aggregate) — individual-level data not shared without explicit consent.
- App Store Compliance —
Apple ATT and Google Data Safety
Apple App Tracking Transparency (ATT): telematics app uses location in background (continuous GPS) — iOS requires permission prompt explaining location use.
App Privacy Label
location data (precise GPS — collected), driving behaviour (collected), device identifiers (not collected).
Google Play Data Safety
location data (precise, approximate — purpose: telematics scoring and UBI pricing), app activity (trip data — collected).
ICO UK GDPR
App Store privacy labels must be accurate and match actual data collection — ICO enforces UK GDPR compliance for mobile apps.
The Results
FCA ICOBS compliance confirmed.
App live at 20 weeks, £138,000 — under budget.
App Store launch: 4.2 stars iOS, 4.1 stars Android.
Active telematics users: 84,000 (30% of 280,000 policy base) in first 6 months.
Average driving score: 74/100.
Claims frequency for telematics customers: 18% lower than non-telematics equivalent (underwriting benefit — telematics selects better drivers).
FCA Consumer Duty review: confirmed compliant.
Customer average UBI premium saving: £84/year.
ICO telematics assessment: zero findings.
“84,000 telematics customers in 6 months — 30% of our policy base. Claims frequency 18% lower for telematics customers. Average saving £84 per year. FCA Consumer Duty confirmed compliant. ICO zero findings. The privacy by design work — device-side GPS anonymisation — was the critical technical decision. Not storing precise GPS coordinates means we never hold location data that could reveal where someone lives or works." — CEO, UK Motor Insurer (name withheld)”
Project Details
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