Insurance Europe has responded to a consultation by the EC on its proposal for a European digital identity.
Digital identities are an essential component of the digital single market and of national and European economies. The insurance industry therefore welcomes the EC’s initiative in this area and foresees a lot of potential in the insurance context.
In the area of distribution, insurers could imagine the following use cases:
- The clear and easy identification of potential customers, in particular in the fulfilment of “Know Your Customer” obligations for online distribution channels or compliance with anti-money laundering requirements.
- In facilitating the possibility to register and access insurers' online services and enabling easy identification for single sign-on.
- In ensuring that prospective customers are of legal age and therefore have full legal capacity to enter into a contract.
- In the context of the professional training and qualification requirements of employees, to demonstrate that relevant legal obligations have been fulfilled. The Digital Identity Wallet could provide a means of demonstrating to relevant supervisory authorities that continuing professional development requirements have been met by the employee.
Regarding the technical implementation of a European digital identity, the following aspects should be considered:
- There is currently no uniform IT architecture, nor test catalogue for SSI-architecture. However, interoperability of Digital Identity Wallets, particularly with regard to their level of assurance, should be guaranteed.
- Digital Identity Wallet solutions should also be user-friendly, while maintaining a high level of security and trustworthiness to improve users’ acceptance.
- In terms of interoperability, user-friendliness and users' acceptance, users should not be forced to use different wallets depending on their respective scope.
- There should be no technical restrictions on the use of wallets on mobile devices – wallet solutions should work smoothly across all mobile devices, regardless of their operating system or age.
Furthermore, digital identities could also help to simplify the fulfilment of data protection rights and make them more secure. However, when deciding on a specific technology for the implementation of Digital Identity Wallets, care must also be taken to ensure conformity with data protection legislation (eg data protection by design) and to choose future-proof solutions.