Retail Financial Services Compliance

Our Data Protection Officer/Support service team, provided by an experienced and multiskilled personnel including a Certified Data Protection Officer and Industry Practitioners, are at your disposal when you are looking to address data protection risks and enhance your privacy mechanisms and internal framework. Our service entails assisting you to understand and work within the legislative complexities, which govern the processing of personal data, and at the same time consider your business needs with respect to Information Systems, data security and organizational processes across the full scale of your operations.

Our multi-faceted Data Protection Services are provided through our multiskilled team of legal, security and operational experts when you are looking to:

  • Implement essential elements of UK Data Protection Act 2018 (DPA) and the General Data Protection Regulation of the European Union EU2016/679 (GDPR), such as the principles of data processing, data subjects’ rights, data protection by design and by default, records of processing activities, security of processing, and notification and communication of data breaches.
  • Foster a data protection culture within your organisation and with your external stakeholders
  • Carry out DPIAs where needed and suggest the appropriate technical and organisational measures) to mitigate the identified risks
  • Support the management of Data Breaches with respect to response, notifications, communications, and advice on corrective actions necessary to prevent losses, regulatory complications and reputation impact.
  • Where necessary, provide a contact point for the Information Commissioner’s Office (ICO)
  • Provide solutions/answers to those data protection questions that puzzle your staff and help with decision making when a data protection issue arise in the context of your daily business.

The maintenance and sustainability of the data protection framework ensures any organisation continues to comply with the DPA and the GDPR. This is possible through planned checks, identification of threats, risks and opportunities for improvement initiatives and monitoring which are necessary to keep compliance regime in its best shape. These tasks must be coordinated and executed at least, on an annual basis.

In order to do that, an external support to the Data Protection Officer (DPO) service can be deployed in order to assist the company designated individual who will have the everyday responsibility of the data protection administration. Our service considers the business needs with respect to Information and Communication Technologies, data security and organizational processes across the operational departments of the organisation. The below table includes the scope of our full external service.

External Data Protection Officer (DPO) services

Privacy framework Maintenance tasks
  • Assistance to maintain a full and accurate Record of Processing Activities
  • One annual full in-depth Data Protection review based on specific criteria
  • Ongoing review of Data Sharing & Processing relationships
  • Review of the existing DPIA and the defined risk mitigation strategy
  • Data Breach Management & Incident logging support (technical analysis and cyber forensics are not included)
  • Records management support
  • Review of existing policies and procedures including the development of new/updated documents as required
  • Provide advice on legal bases, i.e. consent and framing the purpose, the means and the controls of a new personal data processing activity.
Internal &External Interfaces
  • Support when dealing with the ICO
  • Attendance at meetings, both internal and external, where required
  • Examination of data subject’s requests/complaints relating to their rights and advice on how to approach such requirements
Legal support
  • Legal assistance if necessary and approved by the Management of the Organisation
  • Legal support for Subject Access Request (SAR) management if necessary and approved by the Management of the Organisation
  • Legal advice on operational issues relating to personal data if necessary and approved by the Management of the Organisation
Awareness and training
  • Provide an induction awareness on data protection training to all new staff and further ongoing refresher training as required.

Legal support can be sourced in the UK, which will be costed and agreed with the client prior to the engagement of the legal firm.

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction; (GDPR, Art 4, 2)

Please contact us now to discuss our DPO Support as a Service and data protection advice & guidance

The retail financial services market is vast and diverse. From retail banks and high street financial advisors to consumer credit and pensions providers, each sector would have its own specific regulatory and compliance requirements. These requirements have been compounded by the continuing shift towards more digital lead services being offered to retail consumers.

Complyport has been servicing the retail financial services sector for over 20 years. We have advised retail banks on policies, assisted in consumer credit authorisations, reviewed DB Pension files across several firms in the market and continue to provide market leading compliance advise and support on current regulation as well as regulatory change.

At Complyport, can assist retail financial services firms with (but are not limited to) the following compliance support:

FCA Authorisations

  • Consumer Credit Authorisations
  • Claims Management Company Authorisations, and
  • Wealth Management and financial advisor authorisations.

File Reviews

  • Pension Switching and DB Pension Transfers reviews
  • Complaint reviews
  • Suitability reviews
  • AML File reviews, and
  • KYC File reviews,

Project work

  • Policy and documentation reviews
  • Vulnerable Customer process gap analysis
  • Review of TCF procedures
  • Review AML procedures
  • Review KYC procedures

Ongoing support

  • Regulatory and compliance advice
  • Regulatory horizon scanning
  • Outsourced compliance support and short & long term secondment
  • Assistance with complaints monitoring and handling
  • Assistance with compliance monitoring
  • Help with FCA reporting and capital adequacy checks
  • Review of financial promotions, and
  • Assistance when dealing with the Financial Ombudsman Service (“FOS”)

Highlight – Key services

FCA Authorisations

At Complyport, we are market leaders in assisting consumer credit firms with their FCA authorisations and have successfully assisted over 1000 financial services firms with their FCA authorisations. With colleagues who have joined us from the FCA’s authorisation department, we know how to structure an application pack and can help brokers and lenders get FCA authorised first time round.

As part of our FCA authorisation support, we will project manage your application, ensuring the required documents are prepared in order and on time.

We will make sure your firm has the correct documents and policies in place to ensure you are compliant from your first day as a FCA regulated consumer credit firm.

Once authorised, we can assist brokers and lenders with ongoing monitoring as well as the implementation of robust compliant, conduct risk and governance risk frameworks.

All the above is relevant to Claims Management Companies and high street advisors as well.

File Reviews

Within our core team, Complyport has over 70 years of combined experience in undertaking pre or post sale review of the advice given to a clients. Having reviewed in excess of 25,000 files, our team understand the nuances within each file and can provide real time telephone support as well as batch reviews. Each review will consider the suitability of the advice given and the completeness of the documentation.

We can also provide you with assurance over historical advice standards by undertaking a sample review of past business. This can help with any FCA requests or communications, PI insurance renewals or can simply provide comfort over potential liabilities that you have or may have inherited through acquisition.

Our business assurance service ensures a risk-based approach focussing on complex cases categorised as higher risk. We then combine our regulatory and industry expertise, the latter being QCF Level 4 and chartered status.

Our file review support service helps ensure that you reduce potential remedial action and complaints.

Vulnerable customers gap analysis

The topic of vulnerability and the identification & management of vulnerable customers is a persistent issue that gets additional regulator focus each year. The FCA defines a vulnerable consumer as ‘someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care’.

The difficulties for retail firms arise not only in the identification and management of vulnerable customers but how to discuss vulnerability with them in the first place. The FCA have made it clear that they are not looking for a tick box approach when it comes to dealing with vulnerable customers.

At Complyport, our experienced compliance consultants can help your company put in place the right policies and procedures to ensure you understand what a vulnerable customer look like as well as the practical steps that need to be taken once they are identified. We can review your staff’s skills and capabilities when it comes to vulnerable customers and highlight any knowledge or skill gaps. Our team can help implement a persistent monitoring and evaluation process to make sure you continue to meet & exceed the FCA’s expectations and vulnerable customers are not accidently caused harm.

Interested in learning more about our services?

Please fill our free consultation form and a member of our team will get in contact for a personalised quote: