ASR Vitality by ASR Insurance

#MiniDEC

ASR insurances: the Vitality program

1. The organization

ASR Insurances (https://www.asr.nl/vitality) provides diverse insurance products, including car insurance, health insurance, home insurance, life insurance, and pension schemes. Their goal is to provide customers with reliable insurance solutions and financial products that meet their needs and circumstances. As a company, ASR insurances: the Vitality program is also involved in socially responsible initiatives. They have focused on sustainability and responsible business practices, aiming to have a positive impact on society and the environment.

One of these programs is a program called “ASR Vitality”. ASR Vitality is a health and wellness program designed to encourage and reward policyholders for leading healthy lifestyles. It is typically offered alongside certain insurance policies, such as health and life insurance. The program is based on the concept of behavioral change, where participants are incentivized to adopt and maintain healthier habits through various activities and challenges.

The program includes activity tracking, health assessments, rewards and incentives, and coaching and support. The goal of ASR Vitality and similar vitality programs is to promote preventive health measures, improve overall well-being, and reduce the risk of chronic health conditions. By participating in the program and maintaining healthier lifestyles, policyholders may benefit from lower insurance premiums, cashback offers, or other incentives.

2. The AI technologies Employed

The website does not mention if and what kind of AI technology is used.
However, it is mentioned in the FAQ that automated decision making is done. A profile is created based on a lot of data which the user shares. Based on this profile, it is computed whether a user will earn points or not.

However, it is common for insurance companies and financial institutions to explore and implement various AI technologies to improve their services and operational efficiency. Some examples that could be used in the vitality program are:

3. Ethical concerns

Through initiatives like the ASR Vitality program, ASR demonstrates its awareness of the growing significance of health and wellness in insurance, encouraging customers to adopt healthier lifestyles and rewarding them for doing so. By integrating AI and digital tools, the company streamlines processes, provides prompt customer support, and stays ahead of industry trends.

transparency

The website of ASR does not mention any of the technologies used in their Vitality Program. They use automated decision making for scoring, which is only mentioned in the FAQ. It is not described if any type of machine learning is used, and therefore it is not clear whether the decisions that are made are explainable.

Taking a look at the new AI Act shows it has four categories. Systems that fall into category 1, unacceptable risk, are banned in the proposal because they are harmful and contrary to EU values. These are applications that most people think go too far. For example, the use of a social scoring system as used in China or real-time biometric systems for remote identification in public spaces. While this might not yet be the same, it is something to keep an eye on. I think using automated decision making in AI for scoring, needs to be at least transparent and explainable. This way the system will be more fair, since a transparent system shows potential biases and keeps humans in the loop.

Profiling and automatic decision-making

ASR creates profiles of their customers based on the data that is collected to analyze this information and gain insights into (future) actions and preferences. This allows them to tailor communications accordingly. For instance, they may send targeted advertisements or information to (potential) customers based on their browsing behavior tracked through tracking cookies.

Since they use a point system, they make these profiles to determine a customer’s Vitality Status and if a movement qualifies for points. To do this, they use automated decision-making. The consequence is that if a movement qualifies, it will be transmitted to ASR, and points will be earned, otherwise no points will be earned. If a customer does not wish to have their a.s.r. Vitality Status automatically determined, the customer cannot participate in the a.s.r. Vitality program.

Also, the a.s.r. Vitality Age provides an indication of how healthy the customer is, which is calculated based on more than 10 risk factors. The a.s.r. Vitality Age is automatically calculated using the a.s.r. Vitality Health Questions and the a.s.r. Vitality Health Check. This means automated decision-making based on profiling is involved.

privacy

ASR gathers a lot of information from users, which raises many concerns.

  1. In their privacy statement it is stated that the a.s.r. Vitality app and the processing of personal data in this app are commissioned by a.s.r. Vitality operated by the Discovery Group, which are processors for a.s.r. vitality, located in South-Africa, Frankfurt and the United States.

    Later, they point out that many suppliers of these apps or activity trackers are based outside the European Union and store data outside the European Union. As a result, other privacy legislation than the GDPR may apply. They recommend that users consult the privacy statement of these suppliers for more information about how they process the data and the user's rights.

  2. Next, ASR assesses all kinds of data such as:

    • (sports) activities
    • location data (when using the a.s.r. Vitality Bicycle app)
    • living habits
    • eating habits
    • blood pressure
    • heartbeat
    • cholesterol
    • BMI & Waist Size
    • whether or not you smoke and/or have smoked

    This is neccessary for the a.s.r. Vitality test and making a profile. As a user you have to agree with this to use the app. However, for a user it is not clearly mentioned what this is used for, except for creating a personal profile. While they also use it for marketing and can share data with a long list of people. (2)

  3. Data is in most cases directly obtained from the user. Besides the information the user provides, they may also receive and process data from third parties, such as their employer or other external parties, including other entities within ASR Netherlands.
    In the latter case, this involves linking their a.s.r. Vitality membership to an insurance policy they have with one of the other entities within ASR Nederland, so that they can, if applicable, pay a cashback on the premium you have paid for the insurance.

Is the goal ethical?

As an additional point, I would like to raise the question whether the goal of the app is ethical. The goal is to stimulate movement, however, this results in getting discount or a gift card for example. In my opinion, technology should be used for the social good, where every person has equal opportunity and is not mislead by the company. I think it should be more focused on creating a more healthy society, since these rewards are very individualistic. The people that are already healthy and can afford a smart watch will get even more. When people can not afford a smart watch or the app (which costs money), they do not get the opportunity to get discount on their insurance, while those are maybe the ones who need it the most. The goal of the app should be to stimulate movement and make people aware of the importance of movement, and not tempt them to buy unnecessary things.

4. Recommendations

  1. transparency and explainability:
    ASR should prioritize transparency and explainability in the implementation of AI technologies within the ASR Vitality program. They should clearly disclose the use of AI and machine learning algorithms and provide detailed explanations of how these technologies influence decisions, such as scoring and determining a.s.r. Vitality Status. This transparency will foster trust among participants and allow them to understand how their data is being used.

  2. privacy and Data Protection:
    ASR should provide comprehensive and easily accessible information about data collection, processing, and sharing practices. Users must be fully informed about how their data is being used, with clear explanations of the purposes and potential recipients of the data. ASR should also prioritize compliance with relevant privacy regulations, especially when dealing with data transferred outside the European Union. To ensure informed consent, ASR should implement clear and easy-to-understand opt-in mechanisms for users to agree to the processing of their personal data. This consent should be granular, allowing users to choose which data they are comfortable sharing and for what specific purposes.

  3. User Awareness and Education:
    ASR should invest in educational initiatives to enhance user awareness about the program's objectives, data usage, and potential benefits and risks. Providing resources and information on the importance of health and wellness could help participants make more informed decisions about their engagement with the ASR Vitality program.

  4. Ethical Considerations:
    While the ASR Vitality program aims to promote health and wellness, the company should carefully evaluate the ethical implications of using financial incentives to drive behavior change. ASR should consider adopting a more inclusive approach that focuses on creating a healthier society without exacerbating inequalities. Encouraging healthy behaviors should not be contingent on owning expensive devices or paying for the app, as it might exclude those who cannot afford these resources.

  5. Regular Ethical Assessments:
    ASR should conduct periodic ethical assessments of the ASR Vitality program, considering the impact of AI technologies and data usage on participants' privacy, fairness, and well-being. This assessment should involve input from diverse stakeholders, including customers, privacy experts, and ethical advisors.

Resources

  1. "a.s.r. Vitality is er voor jou!" https://www.asr.nl/vitality/
  2. "Met wie delen we jouw gegevens?" https://www.asr.nl/vitality/privacy