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Compliance Bulletin 76
GDPR, Insurance Distribution and Transparency
Meanwhile, the line taken by the ICAEW to their members last week was that there is a risk in sending out seasonal greetings where the recipients have not agreed to be on a mailing list, but that your legitimate interests might justify it, and that either way the risks in sending out email cards is greater than in the post seems about right.
Insurance Distribution Directive
A reminder that the amendments made to the SRA Financial Services (Conduct of Business) Rules include the requirement that those who are involved in providing insurance distribution advice (and so most fee earners at least) should be trained so as to understand the requirements that they are under in this regard (Appendix 1, para 12(1)(a)).
As promised, Infolegal has now posted a training presentation and quiz on this topic which all relevant members of your firm will be able to access through the training section of the Infolegal Compliance Hub.
Remember also that if you want to be able to see who has undertaken the training and how well they did in the quiz, then you can register a training manager for your firm who will be able to access that information. For more details about this contact Duncan Finlyson (duncanfinlyson@infolegal.co.uk).
SRA Transparency Rules
Apart from the GDPR, the other major new compliance requirements this year have been those contained in the SRA Transparency Rules.
The emphasis has of course been on the information required in relation to fees and the personal details of the advisers where the firm provides any of the listed services, but there are requirements that apply across the board. The most obvious of these is the requirement for the firm to provide information about its complaints handling processes which should include the roles of the SRA and the Ombudsman.
In relation to these requirements we would suggest as a minimum wording along the following lines:
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