Scottish Widows Limited · DRN-6225773

The complaint Ms O is unhappy with the way Scottish Widows Limited’s handled her claim. What happened Ms O has critical illness cover with Scottish Widows. In August 2025, she was diagnosed with multiple sclerosis (MS) and made a claim under her policy. Ms O said Scottish Widows has delayed her claim unnecessarily and breached GDPR by sharing her personal information with an unauthorised party. Scottish Widows said it needed more information to validate her claim. It said Ms O underwent diagnostic treatment abroad and so it needed more information about that. It said once the information it asked for has been received, it’ll be able to move Ms O’s claim forward. Scottish Widows said Ms O agreed to its declaration which gave it the authority to contact the third-party treatment provider and so it didn’t uphold that part of her complaint. But it did, however, agree it’d caused a short delay of five days in sending a consultant’s report. It offered Ms O £150 compensation in recognition of that. Our investigator didn’t uphold this complaint. She said it was reasonable that Scottish Widows asked for additional information from the third-party as it’s relevant to her claim. She acknowledged this has caused some delay, but said this was outside of the insurer’s control. She thought the £150 compensation offered was fair for the distress and inconvenience for the delay in sending the consultant’s report. Ms O, unhappy with that, asked for an ombudsman to review her complaint. In summary, she said Scottish Widows didn’t contact the healthcare professional that completed her MRI scan, rather, it shared her personal information with an unconnected employee at the third- party healthcare provider. She also said local laws in that country prevent the third-party healthcare provider from sharing any information with Scottish Widows as it’s unable to verify the insurer. Ms O said the delays she’s experiencing are in contrast with industry rules. And so, it’s now for me to make a final decision. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. Having done so, I’ve decided not to uphold it and for reasons similar to those given by our investigator. I think Scottish Widows is entitled to validate Ms O’s claim before it determines whether to accept liability. Where the insurer identifies the need for further information from a third-party, it’s reasonable to allow it the opportunity to gather that evidence. Scottish Widows acknowledged it caused a short delay of five days in releasing a report and I think the £150 offered fairly compensates her for the distress and inconvenience that caused. I’ll explain why. The relevant rule that applies in this case comes from the Insurance Conduct of Business

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Sourcebook and says Scottish Widows must handle claims promptly and fairly and must not reject a claim unreasonably. I’ve considered the insurer’s obligations under this rule and other relevant industry guidance whilst assessing Ms O’s claim. I appreciate Ms O is still waiting for Scottish Widows to say whether it accepts her claim, but I must make clear I’m only considering the insurer’s actions up until it issued its final response on 23 December 2025. The issues she’s encountered since then are not part of this complaint and so I won’t be responding to any arguments she’s made that exceed that timeframe. The policy terms say: “12.3.2 Information Given To Us We may reasonably ask for information about you: a) during the application for the policy, b) during the making of a claim, or c) at any other relevant time while the policy is in force. All questions we ask must be answered honestly and in full.” And: “Subject to provision 12.3.2, we will only pay benefits if: a) you; b) the person making the claim; or c) anyone else connected with the policy or claim gives us such evidence as we may reasonably require of: … iv) such authorisations as we may require to obtain medical information about you, and v) other information that we may reasonably require to enable us to assess the claim” I’ve highlighted these terms because I think they clearly set out part of the insurer’s approach to validating claims brought to it. Scottish Widows has acted in line with the policy terms by reasonably requesting additional information from a third-party healthcare provider. I think it’s reasonable for the insurer to ask for this information because it relates directly to Ms O’s claim. The evidence shows she underwent an MRI scan abroad and given this is often used to help with a diagnosis of MS, I’m persuaded more information about that is relevant to Scottish Widows’ assessment of Ms O’s critical illness claim. Ms O said the third-party provider won’t engage with Scottish Widows as it’s unable to verify the insurer. She’s provided evidence of an email she received from the specialist she saw which supports what she said about that. I should say it’s not unusual for a UK insurer to request information from a foreign healthcare provider and so I find its position irregular in the circumstances. The policy terms say Scottish Widows may not pay any benefit unless it receives all the necessary information it’s asked for. So, because it hasn’t received the evidence it’s asked for, I don’t think its current position is unreasonable in the circumstances. Ms O said there’s nothing more the third-party healthcare provider can offer beyond what she’s already told it. Ms O said the scan wasn’t recommended by her treating specialist and that she arranged it herself and paid for it privately. I acknowledge her comments about that, but that still doesn’t mean it’s unreasonable for Scottish Widows to ask the third-party directly for more information as it’s entitled to validate the claim. Ms O said Scottish Widows breached GDPR because it shared her personal information with an employee at the third-party healthcare provider, instead of reaching out directly to the contact she’s now provided. Ms O has made a complaint to the relevant scheme about that and is aware I cannot consider whether GDPR has been breached. But I can consider whether Scottish Widows acted reasonably in its assessment of her claim. I thought the insurer acted reasonably by reaching out the third-party provider. Scottish Widows said the contact was listed on the company website as the appropriate person to answer information requests. I’ve considered the evidence it provided, and I thought it reasonable for it to reach out to that employee, as director of the clinic, for further

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information in the circumstances. I also note once Ms O provided the contact information for a different employee, Scottish Widows complied with her request and sent the same information request to her preferred contact, which I also thought was the fair thing to do. I should also highlight Ms O signed Scottish Widows medical consent form when she submitted her claim, which I’m satisfied gave it authority to contact the provider. Scottish Widows did what I’d expect in these circumstances by reviewing the company’s website to determine who to send its information request to and so I don’t uphold that part of her complaint either. I’m aware Ms O hasn’t accepted the £150 compensation offered by Scottish Widows as she didn’t think it fairly acknowledged the level of distress and inconvenience caused. But given I’ve decided not to uphold her complaint, I won’t be making any award to increase the compensation offered. Scottish Widows said Ms O should Ms O change her mind and accept the offer, it’s still available. But she’ll need to contact Scottish Widows directly to do that. My final decision For the reasons I’ve explained, I don’t uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Ms O to accept or reject my decision before 15 April 2026. Scott Slade Ombudsman

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