Leading Point and P9 Form Collaboration to Accelerate Trade and Transaction Reporting
Leading Point and P9 Form Collaboration to Accelerate Trade and Transaction Reporting
Leading Point and Point Nine (P9) will collaborate to streamline and accelerate the delivery of trade and transaction reporting. Together, they will streamline the delivery of trade and transaction reporting using P9’s scalable regulatory solution, and Leading Point's data management expertise. This new collaboration will help both firms better serve their clients and provide faster, more efficient reporting.
London, UK, July 22nd, 2022
P9’s in-house proprietary technology is a scalable regulatory solution. It provides best-in-class reporting solutions to both buy- and sell-side financial firms, service providers, and corporations, such as ED&F Man, FxPro and Schnigge. P9 helps them ensure high-quality and accurate trade/transaction reporting, and to remain compliant under the following regimes: EMIR, MiFIR, SFTR, FinfraG, ASIC, CFTC and Canadian.
Leading Point, a highly regarded digital transformation company headquartered in London, are specialists in intelligent data solutions. They serve a global client base of capital market institutions, market data providers and technology vendors.
Leading Point are data specialists, who have helped some of the Financial Services industry’s biggest players organise and link their data, as well as design and deliver data-led transformations in global front-to-back trading. Leading Point are experts in getting into the detail of what data is critical to businesses. They deliver automation and re-engineered processes at scale, leveraging their significant financial services domain expertise.
The collaboration will combine the power of P9's knowledge of regulatory reporting, and Leading Point’s expertise in data management and data optimisation. The integration of Leading Point’s services and P9's regulatory technology will enable clients to seamlessly integrate improved regulatory reporting and efficient business processes.
Leading Point will organise and optimise P9’s client’s data sets, making it feasible for P9's regulatory software to integrate with client regulatory workflows and reporting. In a statement made by Christina Barbash, Business Development Manager at Point Nine, she claims that, “creating a network of best-in-breed partners will enable Point Nine to better serve its existing and potential clients in the trade and transaction reporting market.”
Andreas Roussos, Partner at Point Nine adds:
“Partnering with Leading Point is a pivotal strategic move for our organization. Engaging with consulting firms will not only give us a unique position in the market, but also allow us to provide more comprehensive service to our clients, making it a game-changer for our organization, our clients, and the industry as a whole.”
Dishang Patel, COO and Founding Partner at Leading Point, speaks on the collaboration:
“We are thrilled to announce that we are collaborating with Point Nine. Their technology and knowledge of regulatory reporting can assist the wider European market. The new collaboration will unlock doors to entirely new transformation possibilities for organisations within the Financial Sector across EMEA.”
The collaboration reflects the growing complexity of financial trading and businesses’ need for more automation for compliance with regulations, whilst ensuring data management is front and centre of the approach for optimum client success. Considering this, the two firms have declared to support organisations to improve the quality and accuracy of their regulatory reporting for all regimes.
About Leading Point
Leading Point is a digital transformation company with offices in London and Dubai. They are revolutionising the way change is done through their blend of expert services and their proprietary technology, modellr™.
Find out more at: www.leadingpoint.io
Contact Dishang Patel, Founding Partner & COO at Leading Point - dishang@leadingpoint.io
About Point Nine
Point Nine (Limassol, Cyprus), is a dedicated regulatory reporting firm, focusing on the provision of trade and transaction reporting services to legal entities across the globe. Point Nine uses its in-house cutting-edge proprietary technology to provide a best-in-class solution to all customers and regulatory reporting requirements.
Find out more at: www.p9dt.com
Contact Head office, Point Nine Data Trust Limited - info@p9dt.com
Leading Point have joined the SME Climate Commitment
Leading Point have joined the SME Climate Commitment
What is The SME Climate Hub?
The SME Climate Hub is a global collection of SMEs (small-medium enterprises) that have commited to halve emissions by 2030 and become net-zero by 2050. Included in this commitment is to report on progress yearly.
The SME Climate Hub is a network that supports SMEs on this vital net-zero journey.
Why we joined:
Leading Point is pleased to announce that we have joined the UN-backed SME Climate Commitment and formally committed to being net-zero in carbon emissions by 2030 (in advance of the minimum target of 2050).
We have joined the community of UK businesses tackling climate change through the SME Climate Hub. With their support, we will understand, track, and make strategic, impactful emission reductions to achieve our target of being a net-zero business by 2030.
Leading Point is committed to having a responsible, sustainable, and transparent operating model. We are excited to collaborate with other businesses on this scheme, and implement a business climate strategy using the tools created by Normative, CDP, Business for Social Responsibility (BSR™), and the University of Cambridge Institute for Sustainability Leadership (CISL).
We are proud to be taking the lead on climate action with the SME Climate Hub community and will be fully transparent with our progress.
Words from our Founding Partner and Chief Sustainability Officer, Thushan Kumaraswamy:
“Committing to a net-zero target is the right thing to do for the planet. It is also a bold statement for a growing startup. I want Leading Point to be at the forefront for fintechs who are making a climate change difference. As we grow, our impact on the environment naturally increases. I am excited to find the best ways to mitigate those impacts and share those findings with our peers.”
Words from our ESG Associate, Maria King:
“Climate change presents both potential risks and potential opportunities for businesses. Small to medium-sized enterprises (SMEs) account for 90% of business worldwide. However, only a small portion of these report on their emissions due to costs and complexity.”
Who we are:
Leading Point is a fintech specialising in digital operating models. We are revolutionising the way operating models are created and managed through our proprietary technology, modeller™, and expert services delivered by our team of specialists.
Leading Point is Highly Commended in Harrington Starr's Top 1% Workplace Awards
Leading Point is Highly Commended in Harrington Starr's Top 1% Workplace Awards
This third edition of The Financial Technologist brings you Harrington Starr's The Top 1% Workplace Awards 2021. We are proud to announce we have been highly commended in the category, ‘The Best Workplace for Change and Transformation’.
About the award:
"As we approach the end of 2021, it's time to celebrate the greats of our industry! This edition of The Financial Technologist brings you The Top 1% Workplace Awards, showcasing the most innovative and groundbreaking firms that are disrupting the FinTech space. We recognise the entire spectrum of excellence that exists in our industry, and gain exclusive insights into the traits and practices that put them at the fore of the marketplace." - Harrington Starr.
Judges words:
“Leading Point are altering how change and transformation should be done, fostering a revolutionary approach to change management. Equipping their team with the best tools and encouraging unique approaches amongst their team, Leading Point should rightly be commended for their work in pioneering excellence in the change and transformation space."
Congratulations to all of the winners and highly commended, in particular OpenFin and Amphora. It is a pleasure to be a part of a community who excels in their policies and practices, leading the way for global transformation.
Please take some time to read our feature article in The Financial Technologist, written by Nadyah Ibrahim and Dishang Patel: The four ingredients of an outstanding workplace - page 37.
Click here to download your free copy of Issue 3, featuring Leading Point: The Financial Technologist: The Top 1% Workplace Awards
Who we are:
Leading Point is a fintech specialising in digital operating models. We are revolutionising the way operating models are created and managed through our proprietary technology, modellr™, and expert services delivered by our team of specialists.
Partnership News: Aurachain & Leading Point to Drive Business Transformation in FS
Partnership News: Aurachain & Leading Point to Drive Business Transformation in FS
Words from Leading Point:
Earlier this year Aurachain and Leading Point announced a partnership. The agreement will combine Aurachain’s low-code platform and Leading Point’s experience with digital operating models in the fintech sector, to introduce a brand-new set of strategic business transformation offerings to client organizations. As they scale, we will be working on client projects collaboratively.
Leading Point’s Founding Partner and Chief Solutions Officer, Thush Kumaraswamy comments on the partnership: “We are excited to work with Aurachain to improve the operating models of our financial services clients by delivering cutting-edge business process automation.”
— Originally published January 2021 at Aurachain.ch —
Aurachain and Leading Point will Drive Business Transformation in Financial Markets
Aurachain, provider of the leading low-code application development platform for automation of both digital process and blockchain applications, today announced a value-added partnership with the highly regarded UK digital op model company, Leading Point. The agreement will see Aurachain’s low-code platform combined with Leading Point’s pedigree as an operational change agent in the financial services sector, to introduce a brand-new set of strategic business transformation offerings to client organizations.
The new collaboration will drive further accelerated automation initiatives and unlock doors to entirely new transformation possibilities for organizations within the financial sector. The partnership will combine the power of Aurachain’s low-code platform, which has distributed ledger technology (DLT) capabilities built-in, with the strong business transformation and project management expertise of Leading Point that specializes in delivering accelerated business deliverables.
The Aurachain low-code platform will enable Leading Point customers to accelerate digital initiatives by delivering new digital process applications up to 80% faster than traditional development methods, with participation from Leading Point SMEs and delivery experts to ensure all target client architectures meet specific business requirements. Furthermore, the platform’s ability to build and deploy applications on Distributed Ledger Technology, will empower Leading Point customers to explore the potential of tokenization within their respective markets for increased liquidity of existing assets and entirely new revenue streams that can be unlocked.
About Aurachain
Aurachain is the provider of a leading low-code application development platform for automation of both digital process and blockchain applications. The platform lets you automate end-to-end processes connecting multiple systems, teams, and departments in a continuous flow optimised for efficiency.
Severine Raymond Soulier joins the Leading Point advisory board
Severine Raymond Soulier joins the Leading Point advisory board
Leading Point™ are thrilled to welcome Severine Raymond Soulier as the newest member of their advisory board. Severine joins Leading Point™ to expand the product portfolio and its reach across international markets.
Severine is the recently appointed Head of EMEA at Symphony.com – the secure, cloud-based, communication and content sharing platform. Severine has over a decade of experience within the Investment Banking sector and following 9 years with Thomson Reuters (now Refinitiv) where she was heading the Investment and Advisory division for EMEA leading a team of senior market development managers in charge of the Investing and Advisory revenue across the region. Severine Raymond brings a wealth of experience and expertise to Leading Point.
Severine Raymond Soulier says: “I am delighted to join the Leading Point team, I have been truly impressed by the talents within the team and by the transformation projects they have run with key financial players so far and look forward to bringing the company to the next level. I also fully embrace the diverse and inclusive culture of Rajen’s team and I will surely be enriched by the team and hope they can benefit from my leadership in return."
Rajen Madan, Founder & CEO of Leading Point says, "We are excited to have Severine join Leading Point. She brings expertise in strategy, go-to-market and team building for global established FS firms. She has driven high growth in her current role at Symphony. Severine’s rich experience will help us expand our product portfolio and reach across international markets. Severine is passionate about helping create future female leaders and will be a great role model and mentor to our wider team.”
Who we are:
Leading Point is a fintech specialising in digital operating models. We are revolutionising the way operating models are created and managed through our proprietary technology, modellr™, and expert services delivered by our team of specialists.
Contact: rajen@leadingpoint.io
John Macpherson Joins Leading Point's Advisory Board
John Macpherson Joins Leading Point's Advisory Board
Leading Point™ are thrilled to welcome John Macpherson as the newest member of their advisory board. John joins Leading Point to support their go-to-market services and product offerings.
John Macpherson was the former CEO of BMLL Technologies; and is a veteran of the city, holding held several MD roles at CITI, Nomura and Goldman Sachs. In recent years John has used his extensive expertise to advise start-ups and FinTech in challenges ranging from compliance to business growth strategy. John is Deputy Chair of the Investment Association Engine which is the trade body and industry voice for over 200+ UK investment managers and insurance companies.
John has extensive experience in change management and growth and has a high calibre record in delivery. John is joining Leading Point at a pivotal moment as they are focused on an intense growth phase across their services, products and ventures. The company may tap financing to accelerate its product trajectory in the coming quarters.
John Macpherson says “I am thrilled to be working with Rajen and the team at Leading Point. Leading Point’s focus on combining innovative technologies, alongside their expertise in financial services has allowed them to deliver change by putting data at the heart of their client’s businesses. Their ethos and values are evident at every step and closely aligned with my own.”
Leading Point is solutions and products company, dedicated to helping financial markets work better. Leading Point blends bespoke expert advisory with innovative technology solutions to reduce fundamental complexity and enable enterprises to deal with the new.
Rajen Madan, Founder & CEO of Leading Point says, "We are thrilled to have John join us at this pivotal moment, with his industry leadership spanning Fintech, established enterprises and trade bodies to help us accelerate our go-to-market and meet the demands of our growing client base.”
Who we are:
Leading Point is a fintech specialising in digital operating models. We are revolutionising the way operating models are created and managed through our proprietary technology, modellr™, and expert services delivered by our team of specialists.
Leading Point Listed as one of the Most Influential Fintech Companies of 2021
We are delighted to share we have been chosen as one of the Most Influential Financial Technology Companies of 2021 by Harrington Starr and the panel of equally influential judges.
The past year could not have been further from the norm, and we can see this being reflected in the companies we work for or with. With all the changes and adjustments that came with this frenzied year, to be chosen as one of the Most Influential, is an achievement we are over the moon with. Leading Point has been recognised by Harrington Starr’s magazine, The Financial Technologist, as one of the most exceptional companies set to dominate the headlines in the year ahead. We’re thrilled to be featured amongst the brightest and most dynamic companies in the industry.
The Harrington Starr Group explains:
“This listing is particularly poignant as we see and hear from companies that have not only survived the pandemic, but come through stronger, bigger and even better than they were before.”
Being recognised in this way is a huge testament to the ever-growing Leading Point family and our determination to help businesses work better. Our growth journey will never stop - as those in the Fintech sector will appreciate, learning and growing will, and can never cease, as it is the key to solutions and success. Our founding Partner & COO Dishang Patel gushes over our triumph, saying:
“I’m delighted to be recognised and it is humbling to be amongst such incredible names within the fintech ecosystem. This award is special to us as it’s allowed the Leading Point culture and successes to be recognised and discussed.”
After claiming a spot on this highly coveted list, Dishang then spoke on Harrington Starr’s podcast, Fintech Focus TV, discussing a range of intriguing topics, such as the values and practices that have really made Leading Point an exceptional place to work. He explores how we are continually attracting the best in the industry and how we have created a successful working environment that ensures we are building and retaining our relations and the best talent in the sector.
Check out Dishang on Fintech Focus TV: https://www.youtube.com/watch?v=mn12YAbTf6A
Click below to enjoy issue 1, free of charge, featuring Leading Point:
#mostinfluentialfinancialtechnologists2021
Who we are:
Leading Point is a digital transformation company, dedicated to helping business work better. We’re transformation specialists fluent in people, data and innovation. Our software products and bespoke consultancy services give you greater control and more peace of mind at every stage of your development. Helping you seamlessly progress from where you are today to where you need to be tomorrow.
GDFM & Leading Point Partnering for Smarter Regulatory Health Management
GDFM and Leading Point collaborate to deliver innovative and efficient regulatory risk management to our clients and through the SMART_Dash product; enabling consistent, centralised, accessible regulatory health data to assist responsible and accountable individuals with ensuring adequate transparency, for risk mitigation decision making and action taking. This is complemented by a SMART_Board suite for Board level leadership and a more detailed SMART_Support suite for regulatory reporting teams.
We are delighted that SMART_Dash has been shortlisted in 3 categories in this year's prestigious RegTech Insight Awards in Europe, which recognises both established solution providers and innovative newcomers, seeking to herald and highlight innovative RegTech solutions across the global financial services industry.
GD Financial Markets Head of Regulatory Compliance Practice and SMART_Dash Co-creator Sarah Peaston "Centralised, consolidated, consistent regulatory health transparency and tracking is key to identifying and managing regulatory and operating risk. I am delighted that SMART_Dash has been recognised as a new breed of solution that practically assists Managers, Senior Managers and Leadership with managing their regulatory health through the provision of the right information, at the right level to the right seniority”.
Leading Point CEO Rajen Madan "Our vision with SMART_Dash is to accelerate better regulatory risk management approaches and vastly more efficient RegOps. As financial services practitioners we are acutely aware of the time managers spend trying to make sense of their regulatory and operating risk areas from a multitude of inconsistent reports. SMART_Dash enables the shift to an enhanced way of risk management, which creates standardisation and makes reg data work for your business. We are very grateful to the COO, CRO and CFOs whom have contributed to its development and help the industry move forward”.
GDFM and Leading Point are rolling out the SMART_Dash suite to the first set of industry consortium partners progressively in H1 2021, and thereafter open to a wider set of institutions.
Leading Point FM featured in IFTA 2019 Trade Handbook
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Leading Point has been featured in the “India Fintech Awards - IFTA 2019” Trade Handbook highlighting 30 UK fintechs with a strong presence or interest in the Indian market. We are proud to be selected alongside Transferwise, Revolut, R5FX and Onfido. This demonstrates our ongoing partnerships with the East and sets us up for an exciting 2020!
Our team was part of the Fintech Trade Mission to India in May-June 2019 with the London Mayors Office and will be participating again in 2020.
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Leading Point FM CEO Rajen Madan on Fintech Focus TV
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Leading Point FM Founder & CEO Rajen Madan has been featured on Harrington Starr's Fintech Focus TV where he discussed the company's capabilities and solutions, the world of data, problems in the FS industry. He provides an overall picture of new technology and trends in the market with a growing focus on delivery and execution in companies!
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Leading Point FM successfully delivers ISO 27001 certification for Fintech client
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Leading Point led the certification process for external global accreditation ISO 27000 for one of their leading global Distributed Ledger Technology clients. ISO 27001 is an international Information Security Management System standard providing best practice in improving information security and also compliance with GDPR. The COO of Adjoint found Leading Point's steer in Stage 1 & 2 delivery and execution invaluable:
"We partnered with Leading Point Financial Markets to define and implement our ISMS. Adjoint selected to partner with Leading Point on this project because they have extensive experience within the FinTech industry, this coupled with the expertise and experience within the information security domain, Leading Point were the obvious choice for this project. What should not be overlooked is Leading Point's influence and recommendations in deciding the most appropriate certification to go for as well as guidance on what ongoing maintenance would be best suited for our needs and match with those of the global certification provider."
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About Leading Point Financial Markets:
Leading Point FM is a data-driven business solutions provider for transformative plays in Financial Services. It works with FinTech, RegTech, DataTech on the one hand and established Financial Institutions to deliver smoother, cost effective business operations. Global financial institutions use Leading Point FM for its Think Fast design, domain data assets and unique ability to deploy ML, AL and DLT in functions such as Client Lifecycle Management, Compliance, Legal, Risk and Data Analytics.
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About Adjoint:
Adjoint Treasury is a powerful platform that unifies your treasury workstation, accounting record, and bank systems to enable real-time payments & settlements, cash management & flexible intercompany loans. Gain visibility, increase control and allow for instantaneous transfers without cumbersome reconciliations.
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Leading Point FM forges strategic AI partnership for Anti-Financial Crime
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Specialist Data-Driven Business Solutions company Leading Point FM will apply and augment Daric’s Artificial Intelligence (AI) platform to provide lean, accelerated solutions for Anti-Financial Crime to serve both established Financial Institutions and challenger FinTechs.
Firms are facing huge pressures to improve their Anti-Financial Crime (AFC) capabilities in 2019. Large volumes of data, growing regulatory requirements, poor data quality, high compliance & operating costs and customer digital experience are the most common pain points that firms experience.
With Daric’s AI capabilities, Leading Point FM will enable firms to harness the power of ML and AI to identify customer risk, dynamically screen payments against transaction history, automate periodic reviews and enhanced due-diligence processes and embed risk intelligence. The combined approach will give financial institutions deeper understanding of their clients, reduce false positives, assure compliance for new regulations and improve business KPI’s.
The partnership comes ahead of the 5th EU Money Laundering Directive, and multiple, billion-dollar fines handed from U.S and UK authorities.
“By combining our expertise with Daric’s AI and expanding our practice in London with new industry hires, we are equipping our clients with an integrated approach to Anti-Financial Crime, one that is based on real process re-imagining, domain expertise, data assets and AI-powered customer insights rather than point solutions and remediation projects which don’t deliver any meaningful business results. There is a great opportunity for firms to address money laundering, fraud prevention and cyber risk requirements with a holistic approach on the underlying data – this is precisely what the Leading Point and Daric partnership make uniquely possible for firms with substantial savings.” said Rajen Madan during a high profile trade mission of leading UK fintech companies led by the Mayor of London’s International Business Programme, with other leading UK fintech companies to India to explore growth opportunities with investors, FinTechs and Industry Leaders at the Barclays Rise Accelerator in Mumbai.
Daric CTO & Co-Founder Vasant Ramachandran added:
“We are thrilled to be working with Leading Point FM to deliver this end-to-end value proposition and increase the impact of our technology for Anti Financial crime use-cases such as client intelligence, transaction monitoring and risk management. This will allow our clients to drive automation across their workflows and to adopt risk-augmented models based upon data intelligence. Technology and process re-imagining go hand in hand.”
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About Leading Point Financial Markets:
Leading Point FM is a data-driven business solutions provider for transformative plays in Financial Services. It works with FinTech, RegTech, DataTech on the one hand and established Financial Institutions to deliver smoother, cost effective business operations. Global financial institutions use Leading Point FM for its Think Fast design, domain data assets and unique ability to deploy ML, AL and DLT in functions such as Client Lifecycle Management, Compliance, Legal, Risk and Data Analytics.
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About Daric:
Daric uses Machine Learning and Artificial Intelligence to improve client digital journeys, real time transaction screening, fraud prevention and risk intelligence for banks and financial institutions. The company is based in Santa Clara, California. Their technology team includes veterans of Goldman Sachs, Palantir Technologies, Google, and LinkedIn, and their investors include industry leaders including Wells Fargo CEO Richard Kovacevich and Goldcrest Investments.
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Rules of Data
On 24 October, it was reported that the Financial Conduct Authority launched an investigation into the US credit checking company Equifax; almost 700,000 Britons had their personal data misappropriated between mid-May and July this year. The FCA gave evidence on this matter to the Treasury Select Committee on 31 October because of the significant public interest. The FCA has the power to fine Equifax, or strip it of its right to operate in the UK, if it is found to have been negligent with its customers’ data. With European Union governments formally stating that cyber-attacks can be an ‘act of war,’ data protection cannot be taken seriously enough. The Equifax data breach is by no means a solitary data breach – several large organisations such as Dun & Bradstreet, Verifone, Whole Foods, Deloitte, DocuSign, Yahoo! are already part of the mix.
The Government is aligning domestic data legislation with the European Union in an effort at continuity, despite our plans to leave the EU. The Data Protection Bill, is proof that the Government seeks to keep the UK au courant with the newest data law of EU provenance.
The number of internet users is now close to 4 billion. Businesses continue to move their products and services online in order to service their customers. Data continues to grow exponentially and will persist in its travel far and wide – enabled by technology proliferation. The EU’s General Data Protection Regulation (‘GDPR’) has been precipitated by acute necessity. Companies need to review and revise their approach to privacy, security and governance of their data. A holistic, data protection framework is needed that is centred on the customer and encompasses their interactions, experience, sentiment, along with those of advocacy groups, shareholders, and regulators. This is a non trivial exercise and requires interventions at the mindset, policy, information governance & security and process levels, along with enabling technology.
Businesses are heading in the right direction with GDPR, but there is still a long way to go. Implementing this change with the right spirit is fundamental to building trust with customers and partners. Leading Point’s experience helping organisations with these requirements suggests that while significant compliance hurdles exist, a risk-based approach that focuses on five core areas, will be instrumental to success.
1. Give your customers control over their data – a mindset change
Bearing in mind the territorial scope of the GDPR – across the current 28 EU member states, plus, anyone dealing with the EU, most teams within organisations will benefit from the ethos behind the Regulation. A mindset shift from owning your customers’ data to stewarding your customers’ data is required. Give your customers control over their data. Any legal or natural person processing data must believe in the spirit of this sea change – the need
to assume responsibility for stewarding your customers’ data and to provide them with confidence in your processes. GDPR expands on the list of ‘rights’ each data subject is afforded: the right to be informed, the right to
access data records, the right to data erasure, to name a few. Tone at the top matters immensely.
2. Achieve Data Protection by Design
Which department is leading your organisation’s GDPR compliance efforts? A cross-functional team will help in deploying a holistic data protection framework. To start with, the focus must be on classification of the data, its
supply chain and its governance. Therefore, leveraging existing data management initiatives to embed data privacy requirements can really help in ‘data protection by design’. In practical terms, companies need a clear picture on: ‘what types of data do they hold on their customers;’ ‘which types of data is sensitive and requires enhanced security levels;’ ‘who has access to customers’ sensitive data;’ ‘where is this data processed and distributed;’ ‘how does it flow;’ ‘what is its quality;’ and ‘are their checks and controls in place around its flow and access’? The rules are more stringent now, as companies establish the depth of customer data – their interactions, experiences, sentiments – what impressions are left in an organisation’s data stores. The definition of personal data and its inherent breadth has been redefined – ‘Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.’ And so the notion of data minimisation is born. We believe that while there are increasing numbers of quick-fix GDPR solutions in the market, achieving data protection goals is less about technology, and more about energising the organisation into becoming 100% data aware.
Building trust in your data will allow for effective process and controls for data protection, security and governance.
3. The Art of the Process
Focus must be on the ‘process’ exercise – visibility of customer journeys – which processes interact with customer data and the ensuing data lifecycle. Knowing which functions have client-facing processes and ensuring these are
adapted is called for. Threading through specific processes for data collection, data storage, data sharing, access requests and breaches is the focus. Having a command of what happens to personal data, who is involved in gathering it, and responding to Subject Access Requests is important, not least because you will have only a month to respond and cannot routinely charge the current £10. What steps to take in the event of a data breach, how to manage contracts which hold personal data: these are all explicit in the Regulation. For all data processors, we must double down on education and training – on policies, on data governance, on processes and new rules of data. This means highlighting a consistent approach to the different scenarios. Surely the best protection is a body of staff that is wholly informed?
4. Integrating data protection with a risk-based approach
By taking an inventory of obligations to customers via existing contracts and business agreements, organisations can start to manage their stated responsibilities linked to customer data and its management and use. This is a
quick-win.
Data classification and governance exercises will highlight the sensitivity, breadth and depth of data, the access and use of the data held. Data flow will highlight the data processors and third-parties and internal functions involved. Data quality will highlight where data management controls are required to be shored up. In turn, this will flag up priority remediation exercises on customer data.
The aforementioned ‘process’ exercise will highlight key customer-facing process changes, or a requirement to deploy specific data processes referenced by GDPR. Organisations can road-test these processes against the required process turn-around times. For example, data breaches must be reported within 72 hours, and as mentioned above, data subject access requests – one month. Involve your customer services team actively with data protection and security breach scenarios – this will build memory and promote mindset change.
The overarching governance in an organisation will be a key cog in the data protection ecosystem; the Regulation has duly led to the genesis of the Data Protection Officer. Enabling these responsibilities with existing data management governance responsibilities, and appointing data champions, can be an effective approach. Data protection is indisputably everyone’s responsibility, so the emphasis must be on organisational cooperation.
5. Cascading to Third Parties & a Cloud
Third party contracts and the framework that dictates how these are established, must wholeheartedly reflect any changes to the requisite data protection and security obligations. A compliance policy which standardises how third party contracts are established can also be a useful instrument. Data transference should be shored up with model contractual clauses, which allow all parties to clearly realise their responsibilities. We are alive to the persistent risk of cyber attacks, so it is crucial to remember that your data on the cloud is a business issue, as well as an IT issue. Are you fully apprised of where your business stores its data; on the premises, in the cloud, or both? The increasing trend to shift data and infrastructure to a public or private cloud no doubt presents an economic benefit and technology road map for some organisations. But make no mistake, organisations are accountable for their customer data content, its usage, and their security policy for cloud-based storage. Measures such as encryption, pseudonymisation and anonymisation will help, and should be employed as a matter of course, as well as remaining open to select technologies that help underpin cyber defence.
To conclude
When implementing change, evidence-based decision making shouldn’t be the only strategy; knowing which cogs in an organisation interlink cohesively in practice will greatly assist in a robust framework that threads through to
a mindset shift, policy, data, process and third parties. To reinforce an earlier perspective, data is only growing. So are data breaches and cyberattacks. The garnering of our data to feed algorithms and ‘machine learning’, borne
out of the Silicon Valley revolution, is leading to inevitable change in our lives, but we must strive for a democratic jurisdiction for our data. Organisations must give customers control of their data and the confidence in their data
management processes. Rather than penalty-based scaremongering, think of this as an opportunity to build your brand, to send a robust message to your customers and partners, demonstrating care and respect of their data.
To close, a soundbite from the Information Commissioner’s Office: ‘Data protection challenges arise not only from the volume of the data but from the ways in which it is generated, the propensity to find new uses for it, the complexity of the processing and the possibility of unexpected consequences for individuals.’
Leading Point Financial Markets brings compelling value in the intersection of Data, Compliance, Governance and Operating Model Change initiatives.
If you would like to further consider any of the above impacts on your organisation, please contact saskia.blake@leadingptconsulting.com or rajen.madan@leadingptconsulting.com.