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The rules of insurance lead generation

News article

Publication date:

28 June 2021

Last updated:

28 June 2021


Alain Desmier, Managing Director, Contact State

Every day, thousands of consumers use lead generation websites in order to be introduced to insurance intermediaries of all shapes and sizes. From fully advised, whole of market conversations, through to more direct, non-advised or online price driven policy help; lead generation is the process of introducing a consumer to an individual or a company that can help provide a product.

The numerous ways that these websites market to consumers are restricted only by the imagination of the lead marketeers themselves. From straight forward search engine marketing to adverts that look like news articles through to videos endorsed by celebrities, the adverts are plentiful and endless. 

But what are the rules that insurance professionals should be aware of before engaging in lead generation? This article sets out the most important things an insurance firm should know before they set out on a lead generation campaign.


The three golden rules - Culpability, Compliance and Consent 

  1. Buyers of leads are as responsible for the lead generation process as the lead generator themselves. If you buy leads you must always sign off the adverts and landing pages that are being used, because any consumer complaint that is investigated and upheld will feature both the lead generator and the ‘advertiser’ (the buyer of the lead). The Advertising Standards Authority have produced a very handy guide here for buyers of leads which sets out where these responsibilities lie.
  2. Any adverts for an FCA regulated product like Life Insurance are themselves subject to FCA regulation and have to follow very clear rules which are set out here. If you buy leads it's your responsibility to understand how the lead generation process adheres to FCA regulation and in particular how the lead generator fulfills the rules set out by the sector regulator. In much the same way that a directly authorised firm must keep a log of the promotions they wish to use, a lead generator should do exactly the same.
  3. Before you speak to a consumer sent to you as a lead, you need to be clear that the lead generation partner has obtained the relevant level of consent to authorise the introduction. Of the three ‘rules’ highlighted in this article, this is potentially the most financially important given the significant fines that surround GDPR breaches of consent. To understand what is technically meant by consent, the ICO clearly spell out what a lead generation form should include to be deemed as valid here. 


Why do the rules matter? What are the consequences for insurance firms that ignore them?

Online advertising is fundamentally about first impressions; the internet is a crowded place and adverts for insurance compete for space and attention with all manner of other products. A consumer promised unrealistic pricing expectations of a life insurance product is likely to have a very different relationship and conversation with an insurance professional compared to say the expectation of a product provider. 

If the insurance sector wants to ensure that consumers have the relevant and necessary level of protection at the end of a sales process, then collectively as a sector, we need to make sure that consumers receive advertising that is fair and representative of the product they are likely to to be sold. 

Putting aside the regulatory censures and fines that a firm might receive for ignoring these rules, there's an increasing view within the protection sector that consumers that are incentivised by misleading price price based advertising are far more likely to cancel their policy. This should give buyers of leads pause for thought when comparing 'quick, easy and cheap leads’ to working with regulating marketing firms who are willing to share their marketing paths.


Good leads lead to good growth

Successful lead generation is the ‘secret of success’ for many successful insurance firms in the UK and lead generation is a powerful marketing tool. The ability to speak to consumers who themselves have self identified as needing insurance, allows insurance professionals to do what they do best, provide insurance. 

However all individuals and insurance firms that buy leads should take the relevant steps to protect themselves to ensure that they are a) making a profitable long term return from lead generation activity, and b) staying on the right side of the various regulators who police this area of advertising. 


Alain Desmier is co-founder and managing Director of Contact State, an advertising intelligence platform that helps insurance businesses manage compliant lead generation activity.

This document is believed to be accurate but is not intended as a basis of knowledge upon which advice can be given. Neither the author (personal or corporate), the CII group, local institute or Society, or any of the officers or employees of those organisations accept any responsibility for any loss occasioned to any person acting or refraining from action as a result of the data or opinions included in this material. Opinions expressed are those of the author or authors and not necessarily those of the CII group, local institutes, or Societies.