Scottish Widows Limited · DRN-6252589

The complaint Ms F complains that Scottish Widows Limited (Scottish Widows) treated her unfairly when she says it incorrectly cancelled her Income Protection Policy. What happened The events which led up to this complaint are well known to both parties, so I’ll give just a broad overview here. In 2000, Ms F took out two policies with Scottish Widows, one was an Income Protection Policy, and the other was a Level Term Assurance Policy with reviewable critical illness cover (Critical Life Policy). In 2011, Ms F has said that she cancelled her Critical Life Policy when she undertook a review of her policies during a visit she made to a bank branch. Following this, Scottish Widows wrote to Ms F in 2011 twice. First to confirm it was actioning her request relating to her Income Protection Policy and then, secondly, to confirm her Income Protection Policy had been cancelled with effect from 4 May 2011. Scottish Widows next sent Ms F correspondence on her Critical Life Policy in the form of a policy statement in September 2022. On 15 September 2023, Ms F contacted Scottish Widows to confirm what policy she held with it as she was unsure. She also said she’d changed address. Scottish Widows responded on 20 September 2023 by sending Ms F the policy information to her new address. On 4 September 2024, Scottish Widows sent a further policy statement to Ms F. On 25 April 2025, Ms F contacted Scottish Widows and asked it to send her information about her policy. On 6 May 2025, Ms F contacted Scottish Widows as she hadn’t received the information. Scottish Widows confirmed that the information had been sent a few days previously and she should receive it shortly. During this telephone call, Ms F asked for confirmation of what policy she held as she was unsure. Scottish Widows confirmed to Ms F that her policy was a Critical Life Policy and that she had cancelled her Income Protection Policy in 2011. Ms F complained. She said Scottish Widows had cancelled the wrong policy. It should have cancelled her Critical Life Policy, and her Income Protection Policy should still be active. Ms F further complained that she had not received relevant correspondence regarding her policies and wanted her Income Protection Policy to be reinstated. Scottish Widows responded by saying it had sent all required and relevant correspondence to Ms F which included the letters sent in 2011 which told her it had cancelled her Income

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Protection policy following her request. Scottish Widows didn’t think it had done anything wrong so didn’t agree to reinstate the policy. Ms F wasn’t happy with this response so brought her complaint to this Service. Our Investigator considered the evidence available and thought Ms F had brought her complaint about the cancellation of her Income Protection Policy outside of the required time limits, so thought it wasn’t a complaint we could consider. But, from the evidence that had been made available to her, she thought Scottish Widows had made errors in the way it dealt with Ms F’s concerns and enquiries and thought that it should pay her £150 in compensation for the distress and inconvenience this will have caused. Following this initial opinion, Ms F said that Scottish Widows hadn’t answered her concerns that it hadn’t provided the required reviews of her Critical Life Policy. And that our Investigator hadn’t covered this in her opinion of the complaint. In response, our Investigator issued a second view and said that Ms F’s concerns about the management of her Critical Life Policy hadn’t been part of the original complaint brought to this Service. She said Ms F should address these points to Scottish Widows and, if not satisfied with its response, then was free to bring this back to this Service as a new complaint. Our Investigator made no other changes to the opinion she’d previously issued. In response to this second opinion, Scottish Widows provided evidence of its communication with Ms F and didn’t agree it had made any errors which would warrant a compensation payment of £150. As both Scottish Widows and Ms F were not satisfied with our Investigator’s opinion the complaint has been brought to me for a 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 looked at the evidence available I came to a different conclusion to our Investigator and issued a Provisional Decision. My Provisional Decision I’ve first considered if Ms F’s complaint that Scottish Widows incorrectly cancelled her Income Protection Policy is one that I can consider. I can’t look at all complaints referred to me. The rules applying to this Service say that, where a business doesn’t agree, I can’t look at a complaint made more than six years after the event being complained about – or (if later) more than three years after the complainant was aware, or should reasonably have been aware, of cause for complaint. Our Investigator thought that Ms F’s complaint had been brought out of time and when she asked Scottish Widows if it gave permission for this Service to consider the merits of Ms F’s complaint it refused.

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But on review, I can see Scottish Widows had, in fact, given its consent for us to consider the merits when it provided its original file on the complaint. And when a business gives its consent for us to consider the merits of a complaint it can’t then withdraw it. This is under DISP 2.8.2A, which is part of the rules in the Financial Conduct Authority’s handbook that govern what this Service can consider. So, given this, I am able to consider the merits of Ms F’s complaint that Scottish Widows cancelled her Income Protection in error. Ms F says she visited a bank branch in 2011 to review the two policies she’d taken out in 2000. During this face-to-face review meeting, Ms F says she cancelled her Critical Life Policy because she’d heard of someone having a poor experience when trying to claim on a similar policy so had lost faith in its suitability. But she still wished to keep her Income Protection Policy. Ms F says she received no follow up communication or any other correspondence on her policy and as her direct debit showing the premium payment on her bank statement was referenced “Scottish Widows” had no reason to think the wrong policy had been cancelled. In its response to this complaint, Scottish Widows provided evidence that it had sent Ms F two letters following her review meeting at the bank branch in 2011. The first was sent on 18 April 2011 which said: “Thank you for your recent request in connection with your INCOME PROTECTION PLAN. I am writing to let you know that we are dealing with your request and will get in touch again as soon as possible” This letter was then followed by a second letter sent on 5 May 2011 which said: “I am writing with regards to your INCOME PROTECTION PLAN. The policy does not have a value and has been cancelled from 04/05/2011” There is no suggestion that these letters were sent to the wrong address but Ms F says she didn’t receive them so was unaware that an error had been made and, as she received no further statements or correspondence on any policy she had with Scottish Widows until she contacted it in 2023, was unaware of the error she felt had been made. In complaints such as this one, where I can’t know for certain what did, or didn’t happen, especially given the passage of time since the event, I need to weigh up the evidence available and make a decision on the balance of probabilities. In other words, if I think Scottish Widows sent the Income Protection Policy cancellation notices to Ms F which explained it had been cancelled and these had been received by Ms F. I know Ms F says she never received these letters, but I’ve not seen any evidence that there was a specific issue with Ms F’s postal delivery service. And, although I accept that, again, given the passage of time this might be difficult to recall, I’ve no reason to think that the letters Scottish Widows sent her weren’t received which explained to Ms F her Income Protection Policy had been cancelled. In summary, from the evidence available, I think it more likely than not that Ms F cancelled her Income Protection Policy at this time when she visited her bank branch to review her policies in 2011. I’ve seen evidence that Scottish Widows sent two separate letters to Ms F notifying her of this cancellation and these were sent to the correct address. And, as I’ve seen no evidence of a specific issue with Ms F’s postal delivery at that time, I think, on the

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balance of probabilities, that these letters were delivered which would have allowed Ms F to take corrective action if she still wished to continue her Income Protection Plan. So, given this, I don’t think I can reasonably say Scottish Widows did anything wrong when it cancelled Ms F’s Income Protection Policy. And because of this I don’t think it needs to re-instate the Income Protection Policy. Ms F has also complained that she received no statements or correspondence about her policy until she contacted Scottish Widows in 2023. And this would have alerted her sooner that the Income Protection Policy had been cancelled. Firstly, given that the Income Protection Policy was cancelled in 2011, it follows Scottish Widows won’t have sent any correspondence relating to it after it sent the cancellation notice on 5 May 2011 as it had no reason to. So, Ms F’s concerns about the lack of correspondence relate to the Critical Life Policy that Ms F says should have been cancelled in 2011. At this point I think it’s important to say that the complaint that has been brought to this Service, and detailed in the complaint form this Service received from Ms F, specifically concerns the cancellation of her Income Protection Policy and the challenges Ms F felt she faced when trying to get copies from Scottish Widows of relevant correspondence and to get clarity on what policy she held. So, these are the specific complaint points that I have dealt with in this decision. That said, I can understand that Ms F feels that some of her concerns have not been addressed. In its final response of 17 June 2025, Scottish Widows gave four complaint points Ms F had raised with it. These were: • Scottish Widows have not provided correspondence about the Critical Life Policy since the early 2000’s • Ms F believed the Critical Life Policy was cancelled at a …bank branch in person and the Income Protection Plan was kept in 2011 • No annual statements have been sent and there have been no options to update or amend any policy • Ms F requested a copy of all correspondence sent to her to be produced for the past 25 years, and for the income protection policy to be reinstated In this response, Scottish Widows said it had been sending correspondence over the years and that it had sent Ms F everything it had on file on 16 June 2025. From the evidence I’ve seen, Scottish Widows did start to send annual statements on her Critical Life Policy in 2022 following new compliance regulations, but I’ve seen no correspondence prior to this. Ms F says she should have had been given the opportunity to have reviews and make amendments to this policy and Scottish Widows have never provided her with this opportunity. And she says the policy isn’t fit for purpose as it doesn’t consider advances in medical practises. I can’t see from the evidence that these complaint points about the management or suitability of Ms F’s Critical Life Policy have been fully addressed by Scottish Widows. I accept that Ms F has raised aspects of these as part of her core complaint that Scottish

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Widows incorrectly cancelled her Income Protection Policy but, given the confusion between the two issues, I also think that Scottish Widows should be given an opportunity to respond to Ms F separately and in detail before this Service makes any judgement. If Ms F isn’t happy with Scottish Widows response to her concerns about the management and/or suitability of her Critical Life Policy then she is, of course, able to bring this to our Service as a separate complaint. But while I make no judgement on Scottish Widows management or suitability of Ms F’s Critical Life Policy, there is one aspect that I think is relevant to her complaint about the incorrect cancellation of her Income Protection Policy. I’ve seen a copy of the terms and conditions of the Critical Life Policy, and it states that if the policy includes critical illness cover (which Ms F’s policy does) then it would be reviewed on the fifth anniversary following inception and then every fifth anniversary following that. The review appears to relate solely to premiums and states Ms F would be notified if, as a result of these reviews, there was a change in her premium payments. I’ve seen no evidence that Ms F’s premium did or didn’t change as a result of these reviews and so I can’t say if Scottish Widows should or shouldn’t have written to Ms F to let her know. And I make no judgement on this in this decision. But if Scottish Widows had been obliged to notify Ms F of a change in her premium payments, following the bank branch visit in 2011, following the review frequency this would have taken place in 2015. If this had happened this would have alerted her that the policy she thought was cancelled was still active and would have allowed Ms F to make her complaint earlier. But even if this had happened the core evidence and circumstances would still have been the same and, for the same reasons I’ve already detailed above, the evidence would still lead me to conclude Scottish Widows hadn’t done anything wrong when it cancelled Ms F’s Income Protection Policy. And this is despite whatever errors Scottish Widows may or may not have made regarding its management of Ms F’s Critical Life Policy. The final aspect of this complaint is the poor customer service Ms F says she received when trying to establish what policy she had and then get all the information she needed to understand the full circumstances of what she felt was the incorrect cancellation of her Income Protection Policy. Ms F says she had to make numerous telephone calls to Scottish Widows, and each time received conflicting advice. She says her queries weren’t answered which led her to making formal complaints, the responses to which she felt were incomplete and vague. And Ms F says she had to ask both verbally and in writing for copies of correspondence some of which wasn’t sent to her. Our Investigator considered this evidence and, as she’d received only limited counter evidence from Scottish Widows, thought it should pay Ms F £150 for the distress and inconvenience this poor service will have caused her. Following the second opinion our Investigator issued, Scottish Widows finally produced counter evidence of its communication with Ms F. From the evidence, Scottish Widows introduced annual statements in 2022 following new regulatory guidelines. The first statement it sent was to Ms F’s old address as it had not been informed, she had moved. In September 2023, it changed Ms F’s address when she contacted it and sent her annual statement the same month to this new address. It sent a further annual statement in 2024 to this address.

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Scottish Widows said it had no further contact with Ms F until 25 April 2025 when she contacted it to ask what type of policy she had. Ms F followed up this telephone call on 6 May 2025 and was told the policy detail had been sent and would be with her shortly. Scottish Widows then also clarified what her policy was and that her Income Protection Policy had been cancelled. Scottish Widows have said that it was at this May 2025 telephone call that the Income Protection Policy had first been mentioned and that all previous communication had dealt with Ms F’s active policy, the Critical Life Policy. In response to Ms F’s subsequent complaint, it provided her with her request for all the relevant correspondence by 18 June 2025. And it said that while this was slightly longer than usual this was because it was reviewing correspondence over a twenty-five-year period. Having considered this evidence of specific communication detail and timescales, and while I think it’s disappointing that it didn’t provide this earlier in the process when originally asked, I think this shows Scottish Widows provided Ms F with all the information I think it was obliged to in a timely manner, relating specifically to her complaint that it had incorrectly cancelled her Income Protection Policy. So, given this, I don’t think I can reasonably say it did anything wrong. If Ms F has evidence that contradicts what Scottish Widows has provided, then I invite her to send it to me before I make my final decision. For clarity, I make no judgement here on any communications relating to Ms F’s concerns that her Critical Life Policy was managed incorrectly or fit for purpose and how Scottish Widows have responded to any points Ms F has made to it regarding these. I’ve said above that I think Scottish Widows should respond in full to any complaint Ms F has regarding this and then bring a separate complaint back to this Service if she remains dissatisfied. In summary, I know Ms F feels strongly about this issue and I know she’ll be disappointed by this provisional decision. Having read all the evidence available, I can understand this because of her personal circumstances, and I do have a lot of sympathy for her. But my role here is to impartially decide if Scottish Widows did anything wrong when it cancelled Ms F’s Income Protection Policy and then when it dealt with Ms F’s enquires relating to the matter. And having carefully considered all the evidence I don’t think I can reasonably say it did. My provisional decision For the reasons detailed above I don’t intend to uphold this complaint. The Responses to my Provisional Decision Scottish Widows didn’t respond to my Provisional Decision, but Ms F made a number of points for me to further consider. Ms F has said: • She received no correspondence from Scottish Widows between 2011 and 2022. Therefore, there was no way she could be reasonably aware of any changes and complain in time for the merits of her complaint to be considered. • When she first contacted Scottish Widows in 2022, she immediately complained about the cancellation of the wrong policy. • Scottish Widows did not send her copies of any correspondence that had been sent to her between 2011 and 2022.

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• She received no reviews relating to her Critical Life Policy which she says is further evidence of Scottish Widows lack of communication. • Regarding poor communication when she telephoned Scottish Widows to ascertain what sort of policy she had, Ms F says she received only vague information which didn’t resolve her queries. And she says the fact that she was only informed in 2025 about the policy waiver is evidence of this poor communication as she’d asked about this on several previous telephone calls. Ms F goes on to say she had to be very persistent before she received her policy document. In summary, Ms F feels that Scottish Widow’s delays in providing clear information amounts to incompetent practise. What I’ve decided – and why I’ve first considered Ms F’s comments that she received no correspondence from Scottish Widows between 2011 when it sent her the cancellation letters (which she disputes she ever received) and 2022 and that this meant she wasn’t aware she had cause to complain about what she says was the incorrect cancelation of her Income Protection policy. Ms F also says she contacted Scottish Widows in 2022 and immediately complained that the wrong policy had been cancelled. In making these points I think Ms F is suggesting that the merits of her complaint should be considered. To be clear, I have fully considered the merits of Ms F’s complaint about the cancellation of her Income Protection Policy, which is the complaint she brought to this Service. This differs from the conclusion our Investigator came to, and one of the reasons I issued a Provisional Decision, but as I have considered the merits, I make no further comment regarding this point. In my Provisional Decision I noted that Scottish Widows had said it had been sending correspondence to Ms F over the years and that it had sent her everything it had on file by 16 June 2025. In her responses, Ms F has strongly refuted this and says that no evidence has been provided to her that Scottish Widows corresponded with her between 2011 and 2022. As explained in my Provisional Decision, as the Income Protection Policy was cancelled in 2011, it follows that no further correspondence would have been generated on this policy following the notice of cancellation letter that Scottish Widows sent Ms F in 2011. But it is potentially possible that correspondence was, or should have been, sent on Ms F’s Critical Life Policy as a result of policy reviews and Ms F has said that this absence of a review is further evidence of Scottish Widow’s poor communication. I’ve covered this in my Provisional Decision. In this I’ve said that the terms and conditions say the premium level on the Critical Life Policy would be reviewed on five-yearly anniversaries of the policy inception – and – if a change in the premium level was deemed necessary then Scottish Widows would write and inform Ms F. But I’ve no evidence that any premium review had resulted in a change of monthly premium and so I can’t therefore conclude any correspondence should have been sent. And, importantly, I went on to say that, even if Ms F had been notified of a change in premiums, which would have alerted her earlier to the cancellation of her Income Protection Policy, I would still be minded, given the evidence, to conclude Scottish Widows hadn’t done anything wrong by cancelling the policy.

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In summary, having reviewed the evidence, I don’t think Scottish Widows did correspond with Ms F between 2011 and 2022 and I’ve no evidence to say that it should have. Given this, I can’t reasonably then say it hadn’t sent Ms F copies of all relevant correspondence by the stated date 16 June 2025. Ms F’s final comments relate to what she feels is very poor service she received from Scottish Widows when she was trying to establish what type of policy she had. Ms F said she made numerous telephone calls to Scottish Widows and was given conflicting advice on each occasion. I’ve looked at the evidence available and can see that in September 2023, Ms F contacted Scottish Widows to confirm what type of policy she had. Ms F emailed Scottish Widows on 15 September 2023 asking it to send her details of her policy. She had also provided her new correspondence address. On 20 September 2023, Scottish Widows responded by sending the policy details to Ms F’s new address. This detail states the policy is a Level Term Life Policy and not Income Protection. Having considered this, I think Scottish Widows provided clear information to Ms F, when she enquired about the type of policy she had, and within a reasonable timescale. Scottish Widows provided an annual statement in 2024 which, again, provided clear details of the type of policy Ms F had. I’ve also seen a transcript of the telephone call Ms F held with Scottish Widows on 6 May 2025. On this call, Ms F asks for clarification as to what type of policy she had and was told it was a Critical Life Policy and not Income Protection, so, again, from the evidence I don’t think I can reasonably say Scottish Widows did anything wrong when answering Ms F’s enquiries about the type of policy she had. I think it would be helpful at this point to be very clear that in this decision I’ve only dealt with Ms F’s complaint that Scottish Widows incorrectly cancelled her Income Protection Policy. I say this because, in her response to my Provisional Decision, Ms F has said that it wasn’t until 2025 that she was informed by Scottish Widows about the policy waiver on her Critical Life Policy. She says she’d asked about this on previous occasions and she was put to significant inconvenience before she was provided with the information she’d asked for. In my Provisional Decision I was clear that I think Scottish Widows should be given an opportunity to respond to Ms F’s concerns about the management, communication and suitability relating to her Critical Life Policy. And, if Ms F is unhappy with this response, then she can bring this separate complaint to this Service for consideration. But, for clarity, I make no comment or judgment in this decision on any aspect of Scottish Widows management of Ms F’s Critical Life Policy – or any communication requests Ms F gave to Scottish Widows about this policy once she was aware of what type of policy it was. In this decision I’ve only considered if I think Scottish Widows did anything wrong when it cancelled Ms F’s Income Protection Policy. In summary, I know Ms F will be disappointed by this decision. I can understand this because of her personal circumstances, and I do have a lot of sympathy for her. But my role here is to impartially decide if Scottish Widows did anything wrong when it cancelled Ms F’s Income Protection Policy and then when it dealt with Ms F’s enquires relating to this specific policy. And having carefully considered all the evidence I don’t think I can reasonably say it did.

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My final decision For the reasons stated above I don’t uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Ms F to accept or reject my decision before 27 April 2026. Ben Castell Ombudsman

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