Memorandum submitted by Standard Life
Standard Life is the largest mutual insurance
company in Europe and is a leading provider of life insurance
products in the United Kingdom.
1.1 The Association of British Insurers
(ABI) has adopted a Code of Practice on genetic testing which
is followed by all its members.
Two principal elements of the ABI Code of Practice
insurance companies will not ask
applicants to undergo a genetic test result in order to obtain
where an applicant for insurance
has previously had a genetic test, insurers may only take the
result into account if it is a test that the ABI's Genetic Adviser
has decided is relevant, reliable and valid and that has been
approved by GAIC.
1.2 We support the principles of the ABI
Code of Practice but we have decided that for the foreseeable
future we will follow a policy that goes beyond the requirements
of the Code.
1.3 We do not require applicants to disclose
the results of any genetic tests they may have taken. If an applicant
does disclose the result of a genetic test we do not take it into
account in our assessment of the insurance risk, unless the result
1.4 The genetic tests that are likely to
be most relevant for life insurance are those for Huntingdon's
Disease and Hereditary Breast Cancer (BRCA 1 and 2).
1.5 Within the context of our overall business
the number of applications with a known family history of Huntingdon's
Disease are very few. Our approach to the assessment of risk for
such applications takes account of the family history, with allowance
for the probability that the applicant will be affected. We believe
that this gives a reliable assessment of overall risk. Taking
account of negative tests results does unbalance the overall risk
assessment against the insurer but in view of the numbers involved
we believe the effect to be insignificant. We monitor applications
received to ensure this continues to be the case.
1.6 The occurrence of a family history of
breast cancer at an early age is seen more frequently in an insurance
context than is a family history of Huntingdon's Disease. However,
only a small proportion of applicants with such a family history
will have either of the genes identified by the ABI's Genetic
Adviser as relevant.
1.7 We have therefore concluded that our
traditional approach of taking account of the family history and
generally ignoring genetic test results is sufficient. This allows
the cost of such risks to be spread as widely as possible. The
policy does rely on the presumption that we will not have significant
increases in the numbers of applicants with abnormal genetic tests.
2.1 The approach of the ABI to the use of
genetic test results in insurance follows the guidance given by
its Genetic Adviser. The advice is based on reviewed medical research
and tests approved for use in clinical practice.
2.2 In addition, there has been research
published on the impact of genetic disease, particularly for Huntingdon's
Disease, BRCA 1 and 2 and Alzheimer's Disease.
2.3 We believe the advice given by the ABI
for the use of genetic test results for these diseases to be fully
2.4 As indicated, however, we do not take
genetic tests results into account, unless negative.
3.1 We do not anticipate using any positive
genetic test results for Huntingdon's Disease in the foreseeable
future. Similarly, we will not wish to use the results of tests
for conditions that are not single gene defects or where there
are also non-genetic influences.
3.2 Our approach to risk assessment will
follow the conventional approach of taking account of clinical
factors, environmental aspects such as smoking and family history.
4.1 The present regulatory system is based
on the Code of Practice of the ABI. This requires an annual statement
of compliance by the Chief Executive of each insurance company.
The Code of Practice has provision for appeals and adjudication
of any alleged breach of the code by an insurer. We believe the
system to be effective.
19 January 2001