Rock Insurance Services Limited · DRN-6116542

The complaint Mr E complains that Rock Insurance Services Limited didn’t give him clear information when he bought a travel insurance policy. Any reference to Rock includes its agents. What happened Mr E booked a trip abroad in September 2024, and he bought a travel insurance policy in October 2024 to cover the trip. The trip dates were between 7 and 14 December 2024. Rock was responsible for the sale and administration of the policy, which I’ve considered under this complaint. Any reference to the insurer is simply to set out the background, and I make no finding against the insurer in this decision. Mr E had to seek medical treatment during the trip, and he made a claim to the insurer. The insurer first declined the claim because Mr E hadn’t declared a pre-existing medical condition. But following our involvement, it agreed to settle the claim proportionately. This was because had Mr E declared the medical condition, the insurer would have charged a higher premium for the policy. Mr E complained to Rock that it wasn’t made clear that he had to declare his pre-existing medical condition when he bought the travel insurance policy. However, Rock thought the information was clear during the online sales journey. It also said that it had sent Mr E an email on 5 December 2024 which reminded him about the need to declare pre-existing medical conditions. Mr E says he didn’t see this email before the trip as it went into his junk mail. And in any event, he doesn’t think an email about this matter just two days before the trip was reasonable. Rock accepted it incorrectly directed Mr E to the insurer when he first raised a complaint, as it didn’t think it was responsible for the sale. It offered to pay Mr E £100 in compensation for the distress and inconvenience caused. Unhappy with Rock’s overall response, Mr E brought a complaint to this service. One of our investigators reviewed the complaint. Having done so, she didn’t think the way Rock had set out the information about the need to declare pre-existing medical conditions was clear. To put things right, she said Rock should pay Mr E compensation to the equivalent remaining amount the insurer wouldn’t pay for costs otherwise covered by the policy. The investigator thought Rock should also add simple interest at 8% per annum from a month after Mr E made a claim to the insurer until settlement. And she said Rock should increase its offer of compensation to a total of £250 to reflect the unnecessary distress and inconvenience caused. Rock didn’t accept the investigator’s findings. It said it had shown that the information about the need to declare pre-existing medical conditions was clearly visible when Mr E bought the policy. It also didn’t think it was responsible for the email of 5 December 2024 being filtered into Mr E’s junk mail.

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As no agreement was reached, the complaint has been passed to me to decide. 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. Mr E took out the policy online on a non-advised basis. This meant that Rock needed to give Mr E clear information so that he could make an informed decision about the policy he was buying. To expand on this, this was information that he needed, at the right time, and presented in a way that he could understand. I’ve considered the information Rock has provided about the online sale journey, including screenshots and a screen recording. On the page where Mr E could choose the policy he wanted to buy, it said the following: “Please see Policy Wording for a list of the excesses payable for each benefit of this policy. For further information relating to Pre-existing Medical Conditions, Cancellation Terms and How to make a claim, please see here.” I don’t think this made it clear that Mr E needed to declare any pre-existing medical conditions before taking out the policy, or that he needed to click the link and review the information shown there before doing so. And Rock hasn’t provided any evidence to show that Mr E clicked the link and reviewed the information on that page. So, I’m not satisfied that Mr E saw the information on the page where the link would have directed him to. So, this means that at the point of choosing the policy, I’m not satisfied that Rock had made it clear that Mr E needed to declare any pre-existing medical conditions before taking out the policy. Rock has also shown that before buying the policy, Mr E would have seen a pop-up showing the eligibility criteria for the policy, which explained the need to declare pre-existing medical conditions. And Mr E needed to confirm he understood and agreed before being able to proceed with the purchase. I accept that that’s what the eligibility criteria set out, but I don’t think the way this information was set out was clear. It was set out in one large block of text. The sentences are not separated on different lines of paragraphs, there are no headings or bullet points, and the mention of pre-existing medical conditions is in the middle of the text. I think a reasonable consumer would find this content difficult to read and understand due to how it’s formatted. So, I don’t think the way Rock set out the information in the eligibility criteria was clear that Mr E needed to declare any pre-existing medical conditions before taking out the policy. Rock has also said that the policy wording and Insurance Product Information Document (“IPID”) were available to review during the online sale. But simply having these documents available to review isn’t enough for me to say that Rock gave Mr E clear information about the need to declare pre-existing medical conditions before buying the policy. Given that the declaration of pre-existing medical conditions could affect the policyholder’s ability to make a successful claim, I’d expect this information to be sufficiently brought to their attention during the sale of this type of insurance policy.

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Lastly, I can see that Rock sent Mr E an email on 5 December 2024 which reminded him about the need to declare pre-existing medical conditions. But I don’t think an email over a month after the sale means that Rock acted fairly and reasonably in how it sold the policy. It had a responsibility to give Mr E clear information before he bought the policy, and it didn’t do so. So, this email doesn’t change my overall findings. Overall, I don’t think Rock gave Mr E clear information during the sale. So, it didn’t give him the information he needed, at the right time, or presented it in a way that he could understand. And therefore, Mr E wasn’t able to make an informed decision about the policy he was buying. I think Rock has caused Mr E a financial loss as a result. I’m satisfied that had Rock done everything right, Mr E would have declared his pre-existing medical condition. And had he done so, his insurer would have paid any claims covered by the policy terms in full. But it has only paid a portion, as it considered that Mr E had made a misrepresentation. To put things right, I think Rock needs to pay Mr E compensation equivalent to the amount not paid out on any successful claim under the policy by the insurer. Mr E should provide Rock with information about any successful claims made under the policy, and how much the insurer paid. It’s clear that Rock has caused Mr E unnecessary distress and inconvenience in how it sold the policy, and how it handled everything when Mr E raised a complaint about the issue. I agree with the investigator that Rock should pay him a total of £250 in compensation. My final decision My final decision is that I uphold this complaint and direct Rock Insurance Services Limited to take the following action: • pay Mr E compensation equivalent to the full amount of any successful claim under this policy, minus the proportionate settlement paid by the insurer (subject to receiving this information from Mr E), • add simple interest at 8% per annum on these amounts from a month after Mr E made a claim to the insurer until the date of settlement (subject to receiving this information from Mr E)*, and • pay Mr E £250 compensation for the distress and inconvenience caused**. *If Rock considers that it’s required by HM Revenue & Customs to take off income tax from the interest, it should tell Mr E how much it’s taken off. It should also give Mr E a certificate showing this if he asks for one, so he can reclaim the tax from HM Revenue & Customs if appropriate. **Rock must pay the compensation within 28 days of the date on which we tell it Mr E accepts my final decision. If it pays later than this, it must also pay interest on the compensation from the deadline date for settlement to the date of payment at 8% simple per annum. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr E to accept or reject my decision before 20 April 2026. Renja Anderson Ombudsman

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