Supporting Compliance through Better Customer Status Intelligence
A year after first exploring the topic, we revisit why mortality and goneaway data has moved beyond operational housekeeping to become an important part of better governance, customer outcomes and risk management across regulated markets.
When we first wrote about mortality and goneaway data as a compliance concern in early 2025, the case was largely forward-looking.
Consumer Duty was still bedding in. Organisations across regulated sectors were reviewing how they managed customer vulnerability, data quality and governance. For many, mortality and goneaway data were still viewed primarily as operational tools - helping improve efficiency, reduce waste or support fraud prevention.
Over a year later, the conversation has evolved.
Rather than being driven by a single piece of legislation, organisations are responding to a broader shift in regulatory expectations. Across financial services, insurance, utilities and telecommunications, firms are expected to demonstrate that they understand their customers, maintain accurate records and deliver fair outcomes throughout the customer relationship - not simply at the point of onboarding.
In that context, customer status data has become more than a housekeeping exercise. Knowing whether someone has moved address or passed away can play an important role in helping organisations make better-informed decisions, reduce risk and support compliance with existing regulatory obligations.
The regulatory landscape
There has been no single regulatory change that specifically requires organisations to monitor mortality or goneaway data.
However, a number of established regulatory frameworks place clear responsibilities on organisations to maintain accurate customer information, manage risk appropriately and treat customers fairly. These include the UK Money Laundering Regulations, FCA Consumer Duty, UK GDPR and sector-specific expectations across insurance, utilities and telecommunications.
Taken together, they point towards a broader expectation: customer information should remain accurate, relevant and appropriate throughout the customer relationship, not simply at the point it was first collected.
For many organisations, this means reviewing how customer records are maintained over time and considering whether important life events are being identified before key business decisions are made.
Where this matters in practice
Financial services
Banks, lenders and other financial institutions are required to carry out ongoing customer due diligence under the UK Money Laundering Regulations, while Consumer Duty places greater emphasis on delivering good customer outcomes throughout the customer relationship.
Mortality and goneaway intelligence can support these objectives by helping organisations maintain accurate customer records, reduce the risk of fraud, prevent communications being sent to the wrong individual or address, and identify circumstances where additional review may be appropriate.
Ultimately, accurate customer status information is about more than operational efficiency. It helps organisations reduce avoidable customer harm while supporting stronger governance, more informed decision-making and greater confidence in customer data.
Insurance
Insurers depend on accurate customer data throughout the policy lifecycle, from underwriting through to claims management and customer communications.
Current mortality and customer status data can support fraud prevention, claims validation, policy administration and customer servicing, while accurate address information helps ensure important communications reach the intended recipient.
Case study: During a recent proof of concept with a UK insurer, MiExact reviewed customers who had previously been identified as deceased by an incumbent data supplier. More than two-thirds were subsequently confirmed to be alive, highlighting the importance of data quality when customer status is used to inform business decisions. Beyond the commercial impact, inaccurate mortality data also has the potential to affect customer experience, trust and customer outcomes.
Utilities and telecommunications
Utility providers and telecommunications organisations manage large customer populations, ongoing billing relationships and collections activity.
Maintaining accurate customer records can help reduce the likelihood of correspondence being sent to former addresses or to the families of deceased customers. Alongside broader customer service processes, mortality and goneaway data can support fair customer treatment while helping reduce avoidable complaints, customer harm and operational costs.
Regulated organisations handling personal data
Under the UK GDPR, organisations are required to ensure that personal data is accurate and, where necessary, kept up to date.
While no organisation can eliminate every inaccuracy immediately, having appropriate processes in place to identify significant changes in customer status can form part of a wider data quality strategy and help demonstrate good information governance.
The risks organisations are managing
Many organisations initially invest in mortality and goneaway data to improve operational efficiency or reduce fraud risk. Those benefits remain important.
However, more organisations are recognising the wider impact that inaccurate customer records can have across compliance, customer experience and operational resilience.
Poor-quality customer data can contribute to:
- Communications being sent to incorrect or outdated addresses.
- Unnecessary distress for bereaved families.
- Increased exposure to identity fraud where organisations are unaware of a customer's death.
- Avoidable complaints and remediation activity.
- Additional operational effort spent correcting downstream data issues.
- Reduced confidence in customer records across multiple systems.
Viewed individually, these issues may appear operational. Collectively, they can affect an organisation's ability to demonstrate effective governance, reduce customer harm and deliver fair customer outcomes.
From point-in-time verification to better ongoing awareness
Perhaps the biggest shift over the past year has not been the regulations themselves, but how organisations are responding to them.
Identity verification at onboarding remains essential. However, many organisations are reviewing whether important customer status checks should also take place before key events such as issuing a policy, processing a claim, making a lending decision, commencing collections activity or sending significant customer communications.
Rather than relying solely on information captured months or years earlier, organisations are looking to ensure that important decisions are informed by customer information that is as accurate and current as reasonably possible.
This reflects a broader move towards treating customer data as something that should be actively maintained throughout the relationship, rather than simply captured once and assumed to remain accurate.
At MiExact, we describe this broader approach as Life Events Intelligence: recognising significant customer life events to help organisations make better-informed decisions, reduce risk, strengthen governance and improve customer outcomes.
Supporting better decisions with trusted data
MiExact provides verified mortality and goneaway intelligence that helps organisations improve customer data quality, reduce risk and strengthen decision-making across regulated markets.
Whether you're reviewing compliance processes, strengthening data governance or looking to reduce customer harm caused by inaccurate records, having access to timely, reliable customer status information can support better outcomes for your organisation and the people you serve.
If you'd like to understand how your current customer records compare, get in touch to discuss a complimentary MiExact data audit.
Sources and further reading
- UK General Data Protection Regulation (UK GDPR) – Accuracy Principle and ICO guidance.
- FCA Consumer Duty (FG22/5).
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended).
- Ofgem guidance on supporting customers in vulnerable situations.
- Ofcom guidance on treating vulnerable customers fairly.