GDPR and financial advice: data accuracy
There is a very interesting article for Financial Advisers in Professional Adviser today. It looks at how to manage your data for GDPR compliance. A few key points;
What is deemed reasonable among advisers is that firms should look to make it easy for their clients to verify the data is correct even if they are not actively serviced clients.
The example of retail online banking portals was raised whereby clients are reminded to verify their personal details when they log in. Working group representatives agreed this would provide good evidence of compliance with the intent of this requirement.
This scenario works for the larger companies, however smaller businesses may benefit from a Consent System that can be included in any communication be that email/letter/newsletter. This system gives an easy way for the consumer to verify their details or for the Adviser to log responses.
The article carries on to say…
For Inactive clients where a transaction has been done in recent years and/or the investment is still under the firm's agency it is proposed a letter could be sent to the client advising the firm has previously transacted with them and/or was currently an agent for an investment of theirs and they would like them to get in contact so they can reconfirm the data they hold on them.
Of course, where the subject has moved house, this probably will not garner a response and the data will remain inaccurate. As such, a data-cleansing service could be used against this segment of client data to identify people who have moved house - from the ‘gone away' register. The firm would then send a letter to both addresses asking for them to get in contact.
Not only would this provide evidence the firm has looked to meet its obligations for ensuring data accuracy, this could also prove to be beneficial as regards re-engaging with clients for additional services or advice. If the client ignores requests to update their data, the firm can show reasonable efforts have been made to maintain accurate data on them.