This article provides guidance on writing your own GDPR/DPA18 Policy and utilises the requirements set out under the General Data Protection Regulation (GDPR) and Data Protection Act 2018 (DPA18). What is a Data Protection Policy? The GDPR advises that controllers must implement appropriate technical and organisational measures to comply with the GDPR; with those measures […]
What is Legitimate Interests? This article looks at how to carry out a Legitimate Interests Assessment (LIA) and gives guidance on the suggested stages. Legitimate Interests is one of the legal basis for processing personal data under the GDPR. Article 6(1)f of the Regulation states: – “Processing is necessary for the purposes of the legitimate […]
Under the Senior Managers Regime, SYSC 25.9.4 of the FCA Handbook advises that Enhanced firms must take reasonable steps to ensure that a person becoming or taking over a role of a Senior Management Function (SMF) Manager, must be provided with adequate information and materials to enable them to carry out the job and their […]
If you have obligations under The Money Laundering Regulations 2017 (MLR17), you will need to have compliant policies, measures and processes in place to meet those obligations. Whether your Supervisory Authority is the FCA, HMRC or Gambling Commission, many of the requirements set by these bodies come from the MLR17 and require firms to have […]
Certification Functions are those that cover specific functions that are not not specified as Senior Management Functions, but that can still have a significant impact on customers, the firm and/or market integrity. The FCA does not approve those individuals performing certification functions in the same way that they do Senior Managers. Instead, the firm itself […]
Whether you are starting from scratch, revising existing data protection policies or use templates from a professional provider; documenting your GDPR measures and controls is a labour-intensive task. Although the GDPR/DPA18 has been in place since May 2018, there are still thousands of firms who are only partially compliance with the mandatory data protection laws […]
In a speech delivered by Nausicaa Delfas (Executive Director of International) at the UK Financial Services Industry Beyond Brexit Summit in London, the FCA discussed their preparations for Brexit and beyond. Whilst it is still the case that nothing is set in stone with regards to the UK leaving the EU, the FCA were keen […]
The FCA are extending the Senior Managers and Certification Regime (SM&CR) to include solo-regulated firms from 9th December 2019. This extension aims to reduce harm to consumers and strengthen market integrity. There are 3 categories under the SM&CR: – Limited Scope: these firms will be exempt from some baseline requirements and will typically have fewer […]
If you are required to comply with the MLR17, we have developed a Anti Money Laundering Checklist that contains over 60 assessment questions and helps firms to assess their compliance with the money laundering and financial crime legislation and regulations. Covering areas such as policies and procedures, transactions, internal controls, training, risk assessment and due […]