Summary of changes

Delegation – Hide button

The review period option, present on draft delegations has been removed due to it being a non-functional field.     

Data purging

Purging can be enabled by selecting the 'Purging’ toggle within administration.

The ability to manage data purging is now available to Admin users provided they have the ‘Manage data purging’ option selected on their system area access.

They will be able to manage purging individuals and their related documentation, enable additional sign off by selected users and manage purging versions of the management responsibilities map.

In all instances the purging of an individual or management responsibilities map requires an authorised user to perform the purge as once an individual or management responsibilities map has been purged the data is removed from the system and is NOT recoverable. 

Navigating to data purging and home page overview

Purging is accessed by expanding the ‘Manage’ navigation menu on the main dashboard.

The purging overview page will display the overall view of individuals who have been deactivated and their expected purge date along with additional information. 

Selecting the manage data purging option will enable users to set up purging schedules, email recipients and sign offs.

Selecting the documentation archive option will allow users to set up which documents are purged with the individual (and which will be archived).

Manage data purging overview

From the manage data purging page the user will be able to set schedules to purge individuals and management responsibilities map versions.  Add recipients for email notifications when purging is due soon and due.  Enable sign offs and view audit history.

Creating purging schedules

To create an individual purging schedule, select the ‘Add individual purging schedule’ option.  A schedule can be created based on Firm(s), Position(s) and Regime(s).  The retention and notification periods must also be set to the required duration.

To add a management responsibilities map purging schedule, select the relevant option and complete the required fields.

Once a schedule is added the page will be refreshed and will return to the Manage data purging page where the newly created schedule will be displayed.  The schedule name, retention period and schedule type will be displayed.  The schedule can be updated or removed by the selecting the relevant icons on the right.

Add recipients

Select the ‘Update recipients’ option to add users who will be required to receive email notifications.  Only users with ‘Manage data purging’ access will appear in the list of available individuals.

The selected users will then be displayed on the manage data purging page and can be updated at any time.

Email notifications

If an individual or management responsibilities map schedule has been created, email notifications are automatically sent to all recipients when an individual or management responsibilities map is approaching or has reached its scheduled purge date.

A separate email is sent for individuals and management responsibilities maps when the purge date is due soon, and again on the day the purge is due.

Manage sign offs

Select the manage sign offs option if you require specific users or a selection of users to sign off purging.

The ‘Individual purging sign off enabled’ toggle will automatically be turned off. To enable sign off, toggle the option on. Select in the ‘Sign offs required’ field the number of users who are required to sign off before an individual/management responsibilities map can be purged, then add the required users.

The purging dashboard for individuals and Management responsibilities map will display an additional ‘sign offs’ column indicating how many of the required sign offs have been completed.

If a logged in user is authorised to sign off purging and they select the hamburger menu they can sign off by selecting the ‘Sign off’ option.

View audit history

To view the audit history of either the individual or management responsibilities map schedules or recipient, select the relevant audit history options on the manage data purging page.

Document archive overview

The document archive allows users to set up which documents will be automatically purged with the individual or merely archived.  By default the documents are set to be archived.

Select which documents are to be automatically purged or archived by selecting the toggle against the required area along with their retention and notification periods.

When an individual has been purged, but some or all of their documentation has been archived, the documentation can be downloaded by selecting the hamburger menu next to the relevant individual and selecting the ‘Download all’ option.

It is also possible to purge all the archived documents at any time by selecting the ‘Purge all’ option.

Purging home page overview

Individuals tab

When an individual has been deactivated they will appear on the ‘All individuals’ tab.  The date they were deactivated, the purging schedule they meet the criteria for (if any), sign offs (if activated) and their purge date will be displayed.

If the logged in user is authorised for sign offs they can sign off from this page or remove sign off if required. 

Due soon or overdue tab

This tab is identical to the all individuals tab and displays those individuals who are due to be purged soon or overdue.  

Where sign offs are enabled and completed prior to the purge date or sign off is completed on an overdue purging, the purging will be completed by the overnight service.

Where sign offs are not enabled an individual will be required to be manually purged by an authorised user via their individual summary page.

Never purge tab

Individuals set to never be purged will be displayed.  Should an individual no longer need to be excluded from purging, this can be managed via their individual summary page.

Signed off tab

Individuals who have a purge date and have been signed off will be displayed on this tab.  If the logged in user signed off the purge they will also have the option to remove their sign off.

Management responsibilities map tab

Versions of the management responsibilities map that are scheduled for purging are displayed.  If the logged in user is authorised for sign offs they can sign off from this page or remove sign off if required. 

Individual purging

When an individual has been deactivated an additional field of ‘Scheduled purge date’ will appear on their summary page and will show the scheduled purge date if they are covered by a purging schedule.  If they are not covered, the field will display ‘Not set’.

Purging can be managed directly on a deactivated individuals summary page via the hamburger menu.  They can be set to never be purged, reverse a 'never purge', purge immediately or the scheduled purge date changed if the individual meets a schedule criteria. 

If sign offs have not been enabled the option will say to ‘Purge individual’.

If sign offs have been enabled it will say ‘Sign off purging’.

An individual set to never be purged can be updated by selecting the ‘Mark to purge’ option and selecting the ‘Set to purge individual’ option in the overlay.

Additionally an individual who has set to be purged can be removed by selecting the ‘Remove individual from purge queue’ option.

If the individual falls under a purging schedule the scheduled purge date will be displayed otherwise the individual will remain deactivated until they are manually purged.

If the purge date for an individual needs to be extended, this can be done by selecting the ‘Change purge date’ option and completing the fields in the ‘Change purge date’ overlay.

Once completed the scheduled purge date on the individuals summary page will be updated and also display that it has been extended.

Management responsibilities map purging

The purging of an management responsibilities map can be managed directly from the Firm.  Selecting the hamburger menu next to a version will reveal an option to purge the version.

If a purging schedule is added, when viewing all the management responsibilities map versions and a version falls within the notification or expiry periods, the purge date along with an indicator showing the status will be displayed on the page.

Import – Additional import to work the same as the main import

The additional data import has been updated so that select records can be imported, rather than doing all records at once.

Like the ‘Import individuals’ tab, the ‘Import additional data’ tab now has a checkbox against each record.

Once the required records are selected, the ‘Import individuals’ button will change to ‘Import selected individuals’. A confirmation overlay will list the number of individuals selected.

Once confirmed, the selected records will be imported.

Reform Phase 1- reduce assignment of overlapping SHF's

An FCA consultation paper is proposing removing overlapping certification requirements in three specific situations where individuals hold multiple functions at the same firm:

·        FCA Material Risk Taker certification removed where the individual is already PRA-certified (as MRT, Significant Risk Taker, or Key Function Holder).

·        Significant Management Function certification removed where the individual is already an FCA Material Risk Taker.

·        Manager of certified employee's certification removed where the individual is already certified for another function.

Therefore, should the customer wish, a script will be run to make the following updates on an individuals’ certificate.

        I.          If an individual is in a dual‑regulated firm and is also certified by the PRA in one of its certification functions, SHF 9 - Significant risk taker or Material risk taker (PRA), SFH 10 - Key function holder (PRA) or SHF11 - Managing a material risk taker (PRA) at the same firm, then SHF 6 - FCA Material Risk Taker can be removed.

      II.          If an individual has SHF 3 - Significant management function and certified as an SHF 6 - FCA Material Risk Taker, then SHF 3 - Significant management function will be removed

     III.          If an individual has SFH 5 - Managers of certification employees and another SHF then SHF 5 will be removed.

Where a certificate is already in a draft state, the certificate will be updated.

Where a certificate is issued, a new draft certificate will be created.

Individuals who have either no certificate, an expired or revoked certificate will be ignored.

Addition/removal of people not clear

The ‘Individuals’ page, within the multiple assessment wizard has been updated so that the options previously only displayed within the hamburger menu are displayed directly on the page.

An individual is only required to be selected if they are either to be removed or if the template being used has cycles and the cycle needs to be changed.

All other functionality on this page remains unchanged.

Reform phase 1 - Reg referencing

The regulatory referencing feature will be turned on for all clients by default and will be displayed for System Admin users in the feature toggles section.  The option can be turned off if required.

Reform phase 1 - Reg referencing 2

Individuals who are either Senior Managers, Certified or Standard Non-executive Directors will now see on their Individual Summary a new ‘Regulatory referencing’ option.

Selecting the option will generate a PDF that will be automatically downloaded. 

The file will display, where appropriate, the following information for a period of up to 6 years:

Individual reference number

Forename and surname

Date created in Comply Accountability

Fit & proper assessment with valid from and to dates with assessment outcome

Firm name

Firm reference number

Firm type

Firm contact (name, position, email)

Regimes held with start and end dates

Positions held with start and end dates

Senior manager functions with start and end dates

Significant harm functions held with start and end dates

Key functions with start and end dates

If you have any questions or need some further information on the recent changes please get in touch: [email protected]