The latest edition of FCA’s Market Watch looks at FCA’s expectations on firms on recording telephone conversations and electronic communications while alternative working arrangements are in place. FCA had previously noted the risk from reduced monitoring and that risks from misconduct may be increased by homeworking, because of the greater ease of using unmonitored or unencrypted technology and the inability to effectively monitor this.
FCA has previously taken action against individuals and firms for misconduct involving the use of WhatsApp and other social media platforms to give investment advice and arrange deals, and it expects to continue to focus on this. It stresses the importance of firms reviewing their recording policies and procedures every time the context and environment they operate in changes, and notes the importance of the role of individual senior mangers in embedding the right culture and governance.
FCA reminds firms of the communications that must be recorded, and how firms must be clear about communicating this, and training staff whenever procedures change. Procedures must also be clear on what to do if there has been a breach.