Official Information of 21 January 2014 on the Management and Control of Quality in an Insurance Company's Distribution Network

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 1 Sorting Code 2 0 2 1 4 5 8 0 OFFICIAL STATEMENT OF THE CZECH NATIONAL BANK dated 21 January 2014 on the management and control of the quality of an insurance company's distribution network activities
I. Scope and Purpose
Following insights gained during the supervision of the insurance sector, the Czech National Bank (hereinafter referred to as the "CNB") hereby issues this official statement setting out standards for the area of quality management of the distribution network and the effectiveness of control mechanisms in relation to the distribution network and the management of related risks. The details are provided in the Annex. The content of this official statement follows from the obligation of the insurance company to act with professional care and prudence1. The purpose of this official statement is to increase the quality of distribution activities in the insurance sector. This official statement applies to insurance companies.
II. Final Provisions
This official statement enters into force on the day of its publication in the Official Gazette of the CNB.
Vice-Governor
Prof. PhDr. Ing. Vladimír Tomšík, Ph.D. s. r.
Annex
Details on the management and control of the quality of an insurance company's distribution network activities Financial Market Supervision Department Responsible Employee:
Mgr. Zuzana Filipová
Tel.: 224 412 757, e-mail: zuzana.filipova@cnb.cz

1 Section 6(1) and Section 7 of Act No. 277/2009 Coll., on Insurance, as amended.

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 2
Annex
Details on the management and control of the quality of an insurance company's distribution network activities
I. Definition of Basic Terms

1. This official statement deals with the details of setting up the management and control system of an insurance company2 in relation to its own network and external distribution channels. The insurance company's own network includes employees offering insurance products, insurance intermediaries controlled by the insurance company, and insurance intermediaries conducting intermediary activities on behalf of and for the account of the insurance company, whereby the insurance company is liable for damage caused by the intermediary under Act No. 38/2004 Coll., on Insurance Intermediaries and Independent Claims Adjusters, as amended (hereinafter referred to as the "IIMA").
   Insurance intermediaries not included in the insurance company's own network constitute the insurance company's external distribution channels.
   3
2. For the purposes of this official statement, the distribution network is understood to mean the insurance company's own network and the insurance company's external distribution channels.
3. For the purposes of this official statement, a distributor is understood to mean an employee of the insurance company who offers its insurance products to prospective insured persons, and an insurance intermediary who conducts intermediary activities on behalf of and for the account of the insurance company, included in the insurance company's own network or in the insurance company's external distribution channels.
   II. General Approach and Expectations within CNB Supervision
4. The CNB assumes that the insurance company will establish appropriate internal control mechanisms for the purpose of managing the quality of the distribution network, as the distributor4 acts on behalf of and for the account of the insurance company, and poor quality, unethical, or even illegal activities of distributors, as well as potential failure to fulfill contractual obligations or actions contrary to the insurance company's internal regulations, may lead to significant financial losses for the insurance company and endanger, reduce, or destroy its reputation among its clients or prospective insured persons.
5. The insurance company should pay great attention to the wording of the contract concluded with the insurance intermediary. In particular, it is essential to focus on establishing the obligation of the given insurance intermediary to provide the insurance company with the necessary cooperation in carrying out quality controls of intermediary activities and in implementing remedial measures, including the obligation to provide required documents, information, and outputs from databases, as well as the obligation to tolerate inspections directly in the distributor's offices or the performance of undercover inspections ("mystery shopping"), and to establish the obligation to report all changes in information provided to the insurance company prior to the conclusion of the contract, particularly changes in the business model. The establishment of the intermediary's obligations in the contract should correspond to the specific control tools used by the insurance company in managing the quality of the distribution network and should be limited to the control of the quality of the distribution of the insurance company's insurance products.

2 Annex No. 1 to Decree No. 434/2009 Coll., implementing certain provisions of the Insurance Act (hereinafter referred to as the "Implementing Decree").
3 Detailed definition of these terms - see form DOPOS36 "Intermediary Activities for the Insurance Company" according to Decree No. 433/2009 Coll., on the method of submission, form, and content of reports of insurance and reinsurance companies, in its valid version. If the exclusive insurance agent falling under the insurance company's own network is a legal entity and is not a person controlled by the insurance company, the CNB assumes that the insurance company will proceed according to the part of this official statement concerning external distribution channels. 4 Employee, bound insurance intermediary, exclusive insurance agent, and insurance agent.

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 3
3. To prevent negative financial impacts from the potential termination of the contractual relationship with the insurance intermediary, the insurance company should clearly regulate what constitutes a breach of contract entitling the parties to withdraw from the contract within the meaning of Section 2001 of Act No. 89/2012 Coll., the Civil Code, (the list of such breaches should at least reflect the requirements for the quality of intermediary activities (regulated, for example, by an ethical code) and statutory obligations under the IIMA in its valid version, and Section 2758 et seq. of Act No. 89/2012 Coll., the Civil Code).
A breach of contract entitling the parties to withdraw from the contract should also include the failure to inform about changes in the business model or in the internally used documents of the insurance intermediary included in external distribution channels5, changes in statutory bodies, responsible representatives, and controlling persons, i.e., upon discovering a discrepancy between the factual state and the content of documentation submitted to the insurance company, or upon the non-cooperation of the insurance intermediary in control activities.
4. The CNB expects that, based on the content of this official statement, the insurance company will make maximum efforts to review already concluded contracts with insurance intermediaries. If the given insurance intermediary is not willing to accept the new contract terms and conclude an addendum to the existing contract, the insurance company should, depending on the severity of the refusal to cooperate, set up stricter control mechanisms6, and in more serious cases, consider terminating the contractual cooperation. The CNB assumes that the insurance company, to ensure an effective and functional management control system in relation to the distribution network, will regulate control mechanisms in internal regulations so that management and control activities can be monitored, objectively evaluated for quality and efficiency, and enforced if necessary. To this end, the specific obligations of the affected departments should be clearly defined and precisely delineated. The failure to establish control standards with the definition of specific control tools and the frequency of conducting controls in internal regulations may lead to controls not being conducted at all or only ad hoc based on the subjective approach of the persons involved in the control, which is insufficient from the perspective of setting up a management and control system. To ensure an effective and functional management control system, the execution of controls must be properly recorded. Since the insurance company's management and control system must allow for the retrospective retrieval of information about control activities, all outputs from controls, both from ongoing controls and from on-site controls in the offices of insurance intermediaries, must be archived, and the quality and efficiency of control activities must be retrospectively assessable.
5. The CNB assumes that, to ensure the quality of distribution activities, the insurance company will take into account, in addition to the volume of production, the quality of the distributor's activity when setting up contracts and subsequently remunerating the distributor. The evaluation of activity quality can be contractually linked to quantitative parameters, such as the volume of persistency7, results of customer satisfaction surveys regarding services, the number of justified complaints, etc. From the perspective of assessing the quality of distribution activities, it is desirable that the system be based on both positive and negative motivation. The CNB further expects that for long-term insurance products with an insurance period longer than 5 years (especially investment life insurance8) with high intermediary commissions paid mainly at the beginning of the insurance period, the insurance company should, to prevent financial losses and avoid fraud in contract conclusion9, prudently contractually spread the installments of such commission over an adequate time period depending on the result of a comprehensive evaluation of the distributor's riskiness10, or alternatively choose other methods of preventing financial losses, such as contractual agreement on the right to withhold part of the commissions to which the distributor has already acquired a right, so-called retention funds, etc. In the event of discovering deficiencies in activities consisting of violations of legal regulations, the insurance company's internal regulations, or contractual obligations, the insurance company should point out these deficiencies to the specific distributor, demand remediation, and subsequently verify it11. In repeated cases or in the event of a serious breach of obligation, the insurance company should then resort to adopting adequate measures in relation to such a distributor; in extreme cases, it should consider terminating the contractual relationship in accordance with the contract and valid legal regulations.
6. The CNB assumes that the insurance company will introduce, maintain, and apply an appropriate information flow system (internal reporting, etc.) for the management and control of the quality of distribution activities and the quality of subsequent client care.
7. The CNB assumes that the insurance company, within its obligation to act with professional care and prudence, will provide distributors with sufficient information about the offered products and thereby create appropriate prerequisites so that distribution networks, or individual distributors, offer products with professional care, provide objective, clear, and non-misleading information on behalf of the insurance company in accordance with Part I, Section 11 of Annex No. 1 of the Implementing Decree, or do not conceal information about the nature and characteristics of the services provided (see also CNB official statement of 2 May 2012 on certain information obligations during the conclusion and duration of life insurance). In light of the CNB's supervisory findings regarding the level of promotional materials for prospective insured persons and materials intended for distributors, particularly in the area of investment life insurance, it appears desirable that these documents be assessed by an independent internal control department of the insurance company. If an insurance intermediary uses its own promotional materials to promote the insurance company's insurance products, these should be submitted to the insurance company for assessment in advance (in the case of comprehensive materials promoting insurance products of multiple insurance companies, this would apply only to the part concerning exclusively the insurance products of the given insurance company).
8. The CNB assumes that insurance companies will pay increased attention to the content of complaints regarding the activities of insurance intermediaries. These client complaints are a significant source of client feedback and may reflect poor quality, unethical, or even illegal activities of the intermediary and lead to the timely detection of such activities. Therefore, the content of complaints should be centrally recorded and evaluated with the aim of capturing possible systemic errors12. Special emphasis should also be placed on client complaints regarding the insurance company's conduct during the debt collection process for overdue insurance premiums or during the settlement of an insurance event.
9. The CNB further assumes that, to prevent poor quality, unethical, or even illegal intermediary activities where objectively possible and not hindered by legal regulations, insurance companies will share (in addition to information shared for the prevention and detection of insurance fraud13) information about14 illegal or poor-quality activities of distributors.
A record of illegal or unethical conduct by a distributor should, depending on the severity of the conduct, be an obstacle to establishing a contractual relationship or an impulse to terminate the contractual relationship in accordance with the contract and legal regulations.
10. In view of the significant risks to prospective insured persons and to insurance companies, CNB supervision also focuses on the existence of illegal so-called pyramid structures15 within intermediary networks (see also CNB decision-making practice16). An illegal pyramid structure may be created, for example, to achieve stable income from commissions, where policyholders are obligated to pay insurance premiums under a contractual sanction in the form of a fine reaching the amount of the commission. A common phenomenon is also the situation where intermediaries are forced at the beginning of cooperation to arrange an insurance product17. This may lead to the creation of artificial demand for an insurance product that the client would not otherwise be interested in. Negative side effects include insufficient information about the nature and behavior of a specific insurance product and the client's lack of familiarity with the rights and obligations arising from the concluded contract.
11. The CNB assumes that any outsourcing of activities that insurance companies must perform within the framework of prudential rules and the control of the expenditure of professional care, particularly the control of premium payment and its subsequent collection, to their intermediaries, will be considered very carefully. Outsourcing certain activities of the insurance company to an insurance intermediary may lead to a situation where the insurance company is unable to timely detect an illegal pyramid structure and introduce adequate measures to mitigate damage on its side and on the side of clients who concluded the insurance product.
III. Own Distribution Network of the Insurance Company
a. Control mechanisms applied before concluding a contract with a new distributor falling under the own distribution network

1. The CNB assumes that insurance companies, for the purpose of managing the quality of their own distribution network, will establish internal standards for the selection of a distributor falling under the own distribution network, i.e., requirements for knowledge, experience in the financial market, etc., taking into account the branch of insurance that will be the subject of offering and intermediation, and the nature of specific insurance products. For example, prior to concluding a contract, it can be requested that the future distributor, if possible, submit their CV and documents proving their relevant practice, and, if possible, references from a previous contractual partner or from their previous employer, which should be given priority attention. The distributor's past engagements should be verified and assessed from the perspective of riskiness for the insurance company.
2. The CNB further assumes that the insurance company, for the purpose of proper management of the activities of its own distribution network, will include specific obligations of its employees in distribution activities in the insurance company's internal regulations, at a level comparable to the obligations of exclusive insurance intermediaries, which are applicable to employees18.
   b. Control mechanisms applied during the contractual relationship with a distributor falling under the insurance company's own network
3. The content and effectiveness of controls performed in the line of hierarchy and subordination, particularly in cases where superiors are partially financially motivated by the production volume of subordinates, should always be subject to independent assessment. Therefore, these controls should be appropriately supplemented by independent monitoring within the insurance company's internal management and control system. Controlling, risk management, compliance, and internal audit play a significant role here. Control units use information from the complaint register, client19 and intermediary20 sections for their activities, without direct access to these registers and sections, the control cannot be considered effective. The obligation of confidentiality and the requirements of the Personal Data Protection Act are not affected by this.
4. Tools for continuous monitoring of activity quality can include, for example:
   (i) participation of superiors or persons performing control activities independently of the line of hierarchy and subordination in meetings between the distributor and the prospective insured person, (ii) control calls, so-called welcome calls, for the purpose of monitoring client feedback and analyzing their results (within the limits of regulations on personal data protection), 21 internal and external surveys monitoring client satisfaction with products and services and analysis of their results, (iii) simulated interest in the intermediation of an insurance product in the form of an "undercover inspection" without the knowledge of the controlled distributor (so-called "mystery shopping"), (iv) control of the content of client files with a focus on controlling the quality of written records prepared pursuant to Section 21(8) of the IIMA.
5. Within the monitoring of distribution network activities, the insurance company should monitor and evaluate non-standard production indicators from the perspective of managing the quality of distribution network activities, for example:
   (i) non-standard values of insurance premiums or high riskiness of investment strategy in investment life insurance, where the risk bearer is the policyholder, considering the specific circumstances of contract conclusion. - e.g., the amount of the premium is in gross disproportion to the policyholder's income, or their expected income; the selected investment strategy contradicts the requirements and needs of the prospective insured person. The prospective insured person/policyholder should be contacted in case of doubts to determine whether the concluded insurance was concluded in accordance with their requirements and needs. In this regard, the CNB draws attention to the obligation of the insurance company arising from Section 2789 of Act No. 89/2012 Coll., the Civil Code. (ii) non-standard length of the validity period of the insurance contract considering the development of the policyholder's financial situation and the purpose of concluding the insurance - e.g., a person of pre-retirement age concludes an insurance contract for 30 years. The policyholder should be contacted to determine whether the concluded insurance was concluded in accordance with their requirements and needs and in accordance with the expected development of their income during the duration of the contract. In this regard, we draw attention to the obligation of the insurance company arising from Section 2789 of Act No. 89/2012 Coll., the Civil Code. (iii) collectively set identical conditions/parameters of insurance contracts concluded through the same distributor (e.g., identical amount of annual premium, identical amount of sum insured in case of death risk, selection of identical investment strategy in investment life insurance for a higher number of concluded insurance contracts). (iv) a phenomenon where, in a significant number of insurance contracts concluded through the same distributor, the person of the distributor is identical to the person of the policyholder or the insured person. The insurance company will set up adequate control mechanisms to capture this phenomenon. (v) development of the premium base and persistency - these indicators are also evaluated by the insurance company within the management of the quality of the distribution network; it is not sufficient to limit the evaluation of these parameters to commercial purposes - e.g., a sharp increase in the production of investment life insurance, a sharp increase in persistency, etc. (vi) payments of insurance premiums for multiple insurance contracts from one bank account, by one person, or from one address, if it may be clear from specific circumstances that this procedure is non-standard; identical contact address for a higher number of insurance contracts, insurance contracts concluded by one intermediary in different places on one day, if it may be clear from specific circumstances that they could not factually have been concluded by them on one day, failure to include a telephone contact for
   the policyholder in a higher number of contracts, and potentially other suspicious circumstances of contract creation.
6. The CNB assumes that the insurance company will create, maintain, and apply its internal regulations establishing methodological procedures for monitoring the quality of the distribution network, by regulating not only the substantive parameters of control establishing the method of evaluating the monitored items, their threshold values, and subsequent specific measures (at least considering the appropriate procedure and recording its reasons), but also establishing adequate procedural procedures with the definition of responsible departments and persons.
   IV. External Distribution Channels of the Insurance Company
   a. Control mechanisms applied before concluding a contract with a distributor falling under external distribution channels of the insurance company
7. The CNB assumes that the insurance company, prior to establishing a contractual relationship, i.e., prior to incurring an obligation, will at least:
   (i) request all documents of the intermediary that the intermediary intends to use when intermediating the insurance company's products to clients (beyond documents provided by the insurance company); (ii) have presented the method of recruiting future subordinate insurance intermediaries or other persons who will participate in the intermediation of insurance products; a representative of the insurance company will participate in the initial training intended for future subordinate insurance intermediaries; (iii) have presented the business model used by the intermediary, including its commission system, incentive system, and system of commission refunds from cancelled contracts; (iv) verify the possibility of the existence of a phenomenon where, in a significant number of insurance contracts concluded through the same distributor, the person of the distributor is identical to the person of the policyholder or the insured

5 Meaning documents related to the distribution activities of the insurance products of the given insurance company.
6 Particularly in the area of monitoring non-standard production indicators. Furthermore, for example, higher frequency and depth of controls using tools of continuous monitoring of their activities, which the specific contract concluded with the insurance intermediary allows.
7 Termination of the insurance contract before the expiration of the period for which it was concluded, by notice, withdrawal from the insurance contract, or agreement of the contracting parties.
8 Annex No. 1 to Act No. 277/2009 Coll., on Insurance, as amended, Part A, point III.
9 e.g., misuse of client identity.
10 especially the assessment of their asset situation, the functioning of the internal control system, and the business model.
11 e.g., by submitting a report on remediation, or on systemic measures.
12 Regarding the method of handling and evaluating complaints, see EIOPA General Guidelines on the handling of complaints by insurance companies (EIOPA-BoS-12/069 Cs).
13 Section 129(6) of Act No. 277/2009 Coll., on Insurance, as amended.
14 including activities that are not in accordance with the obligation of the insurance intermediary to act with professional care.
15 within the meaning of Section 26(2)(c) and (d) of Act No. 38/2004 Coll., on Insurance Intermediaries and Independent Claims Adjusters and on the Amendment of the Trade Licensing Act, as amended.
16 Compare, for example, CNB decision No. ref. 2012/2896/570 dated 3 April 2012 in the version of the CNB Board decision on the annulment No. ref. 2012/1774/110 dated 14 June 2012, file ref. Sp/2010/158/573 and CNB decision No. ref. 2011/14136/570 dated 14 December 2011 in the version of the CNB Board decision on the annulment No. ref. 2012/564/110 dated 23 February, file ref. Sp/2010/110/573 - www.cnb.cz. 17 except for compulsory liability insurance for damage caused by the performance of activities.

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 6 6 18 An employee, for example, will not provide the policyholder with information about the register in which they are recorded.
19 A compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 A compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 7 7 19 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 8 8 19 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 9 9 19 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 10 10 19 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 11 11 19 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 12 12 19 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 13 13 19 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 14 14 19 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 15 15 19 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 16 16 19 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 17 17 19 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 18 18 19 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 19 19 19 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).

Official Gazette of the CNB, Issue 2/2014 dated 23 January 2014 20 20 19 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with concluded private insurance.
20 Compilation of all documents, documents, communication records, and data contained in the insurance company's systems connected with the contractual relationship with the distributor and their distribution activities.
21 The insurance company will take into account in this regard, in particular, the provisions of Act No. 480/2004 Coll., on Certain Information Society Services and on the Amendment of Certain Laws (Act on Certain Information Society Services).