7.9.2021

Fennia – Acquisition of Integrated Insurance System

We assisted Fennia in the acquisition of an integrated insurance system from Salesforce and Accenture. Our Data & Technology service was closely involved in drafting the documentation and negotiating the agreements with Salesforce and Accenture.

The new integrated system will include customer relationship management and insurance systems and will enable Fennia to reorganise its insurance business operations. This will make it possible to refocus the entire insurance process on the customer.

‘We have a huge job ahead of us to reorganise our business models, clarify our products and streamline our processes. This new integrated system will be built from scratch. Our choice of system is more flexible and adaptable than traditional insurance systems, which will give us the best foundation to create the best customer experience in our business’, says Fennia’s Chief Development Officer Patrik Serén.

In practice, Fennia is building a new insurance business alongside its current business rather than developing its current one.  This is the first reorganisation of this scale to be carried out in Finland.

Latest references

We successfully represented insurance companies LähiTapiola and OP Henkivakuutus in two cases concerning an important point of principle: the right of insurance companies to process health data as part of the insurance application process. The Supreme Administrative Court handed down twin decisions ( one published as precedent ) addressing the matter in light of contrary DPA decisions. Under the Finnish Data Protection Act, insurance companies may, to simplify, process health data concerning “insured persons” (vakuutettu, försäkrad) to determine liability under the insurance. This rule constitutes an exception to Article 9 GDPR. At issue was whether the term “insured person” also covers people in the process of obtaining insurance coverage or only people who are already covered. In more practical terms: can an insurance company rely on the rule when considering whether/how to grant the insurance in the first place? The SAC answered in the affirmative and thus upheld the traditional industry approach over the DPA’s contrary view. The SAC noted that the Data Protection Act did not define the term “insured person” and thus looked at insurance legislation for guidance. As argued by the insurance companies, that legislation also uses the term in the context of describing the insured person’s pre-contractual informational obligations. Thus, and in view of the underlying purpose of the rule at issue, the SAC found that an “insured person” could be someone in the process of obtaining coverage, not just a person already covered. The outcome clarifies the scope of the local rule at the insurance application stage for the Finnish insurance industry.
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We assisted Oomi Oy in its expansion into the mobile telecommunications market with the launch of Oomi Mobiili, a new MVNO brand. Our work covered the preceding due diligence process as well as structuring and negotiating key partner agreements, laying a solid foundation for Oomi’s entry into the new market. Oomi Mobiili will operate as a virtual mobile network operator, offering customers the option to purchase a mobile subscription together with their electricity contract. The phased launch is set to begin in autumn 2025, with nationwide availability targeted for early 2026. 
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