Until the review and revision to Article 76 is completed we will not know how the current approach might change. This includes whether any form of sanctions may apply in the future.

Unfortunately using a link will not suffice. The Privacy Notice wording is mandatory wording for MID and/or MIAFTR subscribers under the Navigate Master Product Agreement (MPA) we will be entering into with you.

The Privacy Notice wording has been developed to ensure that MIB meets the requirements under Article 14 of the UK GDPR. We note that you will already have your own Privacy Notices, however we are requiring the inclusion of this mandatory wording to ensure that all subscribers provide consistent and sufficient information to ensure MIB meets its obligations under the UK GDPR, and that data subjects are provided with the information they are entitled to. 

We recognise that Members are concerned about the impact of some of the challenges associated with the roll out of Navigate may have on TTS obligations under Article 76.

Having reviewed the current position and the overriding principle outlined in section 2 of A76, we can confirm that there will be no sanctions applied to any Member as at the ‘review date’ of 31 July 2024.

This concession applies to data loaded to Navigate in May, June and July 2024. The next A76 review date will be 30 November, where we will review September, October and November data submissions to Navigate in the normal way.

We would like these changes incorporated by Go Live on 29 April 2024. But you can also use this wording now as it covers both pre and post Go Live periods.

A subset of insurers was consulted within a Legal & Contract workstream. This was to ensure the Navigage Master Product Agreement was fit for the future. MIB shared the draft MPA in July 2023 and made refinements based on industry feedback. The updated, final version and Navigate Terms & Conditions were shared in early December 2023. They are for review only at this stage by customers' own legal departments.

Subscribers who contribute data to the MID to include mandatory Privacy Notice wording stipulated by MIB in their own Privacy Notices to ensure MIB’s Article 14 GDPR obligations are being met. MIB shared the Privacy Notice in July 2023. 

Yes, users will have to agree to our new Navigate User Terms and Conditions.

The Navigate Master Product Agreement (MPA) will be accepted within Navigate as part of the registration process that opened in late February 2024 and closed on 28 March 2024.
Further information can be found here.