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Bollington Motortrade - The Motor Insurance Database (MID)
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The UK has one of the worst records in Western Europe for uninsured drivers with an estimated one in every twenty cars on the road being driven without proper insurance cover. This results in every honest motorist in the UK paying £15 - £30 of their insurance premium to compensate the innocent victims of these cheats... and the problem is growing at a dramatic rate.
The Motor Insurance Database (MID) was set up by the insurance industry to help combat this crime, and is now helping the UK comply with the 4th EU Motor Insurance Directive, which requires that insurance details of all vehicles in member states, can be easily accessed by a national information centre. In the UK, this role is carried out by the MIIC (Motor Insurers' Information Centre).
In theory every vehicle registered for road use in this country, which is driven in a public place will have to be notified to the MID. For vehicles insured on "Private Car" type policies this is already being done by Insurers as they hold records of registration numbers of vehicles covered on their policies.
Phase 2 of the implementation of the directive is a little more involved as it involves incorporation into the MID of all vehicles on "Unspecified" policies i.e. Blanket fleet policies and Motor Trade Policies
The regulations will require the following:
- Registration numbers for vehicles owned by the client and those specified covered on their Motor Trade/Fleet policy.
- Courtesy/Loan/Demonstrator vehicle registration numbers owned by the client for the purposes of customer use.
- Trade Plates (if applicable).
What about Temporary Vehicles?
The Department of Transport has now indicated that the rules for Fleet and Motor Trade policyholders will be identical. We understand the deadline for notification will be 14 calendar days. This means that vehicles held between 1 and 14 days will be excluded under the de minimis exception, but that all vehicles held longer than this, and covered by the policy, will need to be notified. Such vehicles would include
- Temporary hired vehicles (on fleet)
- Vehicles held for sale (stock vehicles) that are not used on the public highway and are disposed of within 14 days
- Customers Vehicles in for servicing and repairs
- Find out how you can submit your data (this will depend on who your insurer is)
- Prepare your data for provision to insurers. We can advise you of the best way to do this
- Submit your data as advised
- Update the data whenever there is a change to the relevant vehicles covered by your policy
- Congratulate yourself for being in compliance with the 4th EU Motor Insurance Directive
What is the Fourth Directive anyway?
The Directive is aimed at improving the settlement of cross-border motor claims amongst EU citizens. A full guide can be found on the MIIC website. The MIIC Database programme will implement only that element of the Directive, which relates to tracing insurers from registration numbers.
When will we see the legislation ?
While we await sight of the official legislation (expected at the beginning of December) the Government has confirmed there will be a legal obligation on policyholders to supply data within a specified period (14 calendar days of the vehicle going on cover).
Will we have to record every single vehicle?
Other than as indicated below, yes.
My fleets include unregistered vehicles not designed for road use - do i have to include them?
The Fourth Directive only relates to registered vehicles, so there is no requirement for such vehicles to appear on the MID. Some insurers will, however, insist on these vehicles being notified. Policyholders should be aware that it is not possible to enter these vehicles on to the MID via the MID Update web site because they do not use standard registration format, but many insurers will accept this information via their own websites.
Do Motor Traders have to submit all the vehicles passing through their hands ?
The DofT has now indicated quite clearly that the obligation on Motor Traders will be identical to fleet policyholders for taxed vehicles which will be driven on the road. We understand the deadline for notification will be 14 calendar days. This means that vehicles held between 1 and 14 days will be excluded under the de minimis exception, but that all vehicles held longer than this, and covered by the Motor Trader's policy, will need to be notified. In the case of untaxed vehicles, the number to be supplied by the user will be the trade plate.
What about stock vehicles which are never driven on the road ?
If a vehicle is never driven in a public place it does not need to be notified.
Does this mean that we can't have unspecified certifications any more ?
The MID does not change the law on liability or coverage. Blanket fleet policies - or policies with some vehicles identified separately, or for certain drivers only - are still permitted and there is no obligation to issue specified certificates.
Will my insurer refuse to pay claims if vehicles aren't on the MID?
The MID does not change the law on liability or coverage, or the terms of the policy. Third party claims will always have to be paid. Insurers are likely to make vehicle notification a condition of the policy, and hence potentially not pay own damage claims if this is not done, or seek to recover third party damages from you. Another reason why you MUST comply with the legislation.
When must I supply my data?
If your insurer has notified you that you should provide data to the MID website, then they will send you a User ID, password and pass-phrase to allow you access. Once you have received these, and your insurer has told you that your policy is available for population, you can enter your vehicle data. You should do this as soon as possible, and then keep it up to date thereafter. The law will require you to update the MID with changes to your vehicles within 14 calendar days. If your insurer has notified you of another supply method, or not told you anything yet then we will advise you of the alternatives available to you. All data needs to be in place by 20 January 2003 to comply with the law.
Who will give me access to the MID?
Ultimately it is for insurers to authorise access to policies - neither TBG or the MIIC have the ability do this. The Insurer will issue the appropriate security access requirements needed by individuals granted access to the MID.
Can I Search for vehicles on MID?
Only insurers dealing with claims, and the Police are currently permitted access to the MID.
I don't have internet access What should I do?
Not all insurers are requiring data via the Internet. TBG can assist by advising you of the different methods of notifying vehicles and provide forms and fax numbers on which you can do this.
What will the penalties be for non-compliance?
The penalties for not submitting data must, in the terms of the Directive, be "dissuasive". Exactly what the penalties will be is not yet known, but they will be set out in the implementing Regulations - non-compliance will be a criminal offence. We will publish full details as soon as they are made available by the Government.
Can I get some one else to submit the data for me?
There is nothing to stop you using an agent, such as a broker, to fulfil your legal responsibilities to send data to their insurer or the MID direct. It is a matter for policyholders to nominate people to do this for them. TBG will gladly assist if nominated.
Is this compatible with the Data Protection Act?
The MID can only be used for very limited purposes, and its operation is compliant with the data protection legislation. No-one but MIIC, the Police, the relevant insurer and the policyholder can access the data on the MID, and then only in strictly controlled circumstances. To ensure fair processing of data under the Data Protection Act 1998, living individuals should be informed that their personal details are being held on the MID, that these may be searched by insurers, the Police and the MIIC, and the purposes for which these searches will be made. Since named drivers may be recorded on the MID MIIC has recommended a wording to address this be incorporated into policies (or notified by separate notice) before the MID goes live. Fleet owners should make sure that their named drivers are aware of this.
Which websites do I use ?
We appreciate that this may be a little confusing - there are actually several different websites involved The first is an information website : www.miic.org.uk This provides details about data submission, MIIC in general, and various other issues. The second is the MID update website, which is: www.midupdate.co.uk This is where clients (or their nominated third parties) will be able to input details of your vehicles (if your insurer is offering you this option of data submission). However, to do this, you will need to obtain a username and password from your insurer. They should be contacting clients soon with this information, or informing them of alternative ways that they can submit data.
Download MID Excel Sheet
Download MID PDF
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