SlideShare ist ein Scribd-Unternehmen logo
1 von 77
Downloaden Sie, um offline zu lesen
Standards International Ltd
ISO 22222 – Training and Gap Analysis
                           Workshop




                             Welcome…
How to get the most out of the day..
Learning Styles.
                           Light
                            Bulb
                          Moment
                          M      t



                   DO                Think




                   Plan              Write




                            Talk




                                             Raising the standards…
Agenda
•   ISO 22222 - The story so far.

•   ISO 22222 - An insight.

•   What makes ISO 22222 different.

•   The Key El
    Th K Elements.
               t

•   How to document your practice management system.

•   How to create an implementation plan.

•   Self Assessment Gap Analysis
                        Analysis.

•   What happens next?

•   Any Questions?
                                               Raising the standards…
Who we are
•   Established in June 2007 (Pilot Scheme launched in April 2006).
•   Independent leaders in the market place.
•   UKAS Accredited Certification Body
                                  Body.
•   We work with the profession’s leading advisers.
•   Pioneering Best Practice.
•   Privately Owned - Unique Offering.
•   Work done so far:
    o   Awareness Campaigns - Professional and Consumer
                                               Consumer.
    o   Articles, Features, Presentations and The Book.
    o   Partnerships - P f i Wide.
        P t     hi     Profession Wid
    o   The Approved Associate Programme (AAC) .


                                                      Raising the standards…
What are ISO Standards?

• More common to the business market.

• ISO – International Standards Organisation




• Demonstrate the ability to consistently provide a product or service
  that meets customer requirements in line with regulatory
  requirements and…


• Addresses customer satisfaction through the effective application of
  the system, developing processes for continual improvement and the
  prevention of errors and mistakes.


                                                       Raising the standards…
Why have national and international standards?

 • The Kitemark                  • The CE Mark


 • They help businesses to:

   o   Identify d
       Id tif and meet th needs and expectations of it customers
                         t the   d     d      t ti     f its   t
       and other interested parties, e.g. employees, suppliers, owners,
       societies, to achieve a competitive advantage and to do this in an
       effective and efficient manner
                               manner.

   o   Achieve, maintain and improve overall performance and
       capabilities.
       capabilities




                                                      Raising the standards…
Why have an ISO standard for financial planners?

 • Increased pressure to demonstrate professionalism.
 • Demand from clients, professional associations and the regulator.
 • 2000 ANSI contacted BSI (British St d d I tit t ) who t
                  t t d      (B iti h Standards Institute) h turned t th
                                                                  d to the
   FSA for guidance.
 • A UK Committee was formed – headed by David Jackman (Head of
   Industry and T i i )
   I d        d Training).
 • Development supported by 17 other worldwide committees.
 • Developed over nearly 7 y
          p               y years and in March 2006 – ISO 22222 was
   launched!
 • April 2006 – SI launched their ISO 22222 Pilot Scheme.
 • Research carried out by Which? – consumers confused about where to
   turn for the right financial planning advice.
 • ISO 22222 – Addresses this, which is why Which? fully support any work
   to increase professional standards
                             standards.

                                                      Raising the standards…
Why have an ISO standard for financial planners?




                                    Raising the standards…
Adviser Quotes

“Going through the ISO process has enabled us to look at our business in
                          way never before possible. The net result for
              the consumer is a more efficient and transparent process
                         in receiving holistic financial planning advice”

                      Andrew Reeves, The Investment Coach Limited



        “ISO 22222 certification process was the best available overall
             assessment of knowledge, competency and fair customer
                                                           treatment
                                                           treatment”

                          Robin Keyte, director of Towers of Taunton


                                                      Raising the standards…
ISO 22222 – An Insight

• Enables consumers to identify financial planners who possess the right
  knowledge, skills, ethics and experience to deliver their desired level of
  service.
• Codifies professional best practice in financial planning from across the
  world, and will help to increase consumer confidence.
• Not another qualification.
•   Exemption from AF5 – Financial Planning Process (CII).
•   Not a “tick box” exercise – assessment methods include:
           tick box
    File checks / Role Plays / Case Studies / On the job observation.
    Certification Awarded to the individual within a firm.
• Ongoing assessment (encourages internal audits).




                                                       Raising the standards…
Where does ISO 22222 fit in with the
                           current and future landscape?

• Four key documents to review:

  o   Consultation P
      C    lt ti Paper – CP09/31 Delivering th R t il Di t ib ti
                                 D li i g the Retail Distribution
      Review (December 2009).

  o   Policy St t
      P li Statement # 1 – 10/6 Di t ib ti of retail i
                   t            Distribution f t il investments
                                                         t   t
      (March 2010).

  o   Consultation and f db k statement # 2 – (A t
      C    lt ti     d feedback t t   t       (Autumn 2010)
                                                      2010).

  o   Remuneration Code – (Quarter 2 2010).
• Key Objective:

  o   Forcing best business principles to professionals who primarily are
      seen as doing a job.
                                                      Raising the standards…
Key Themes - Proposals

1.   Improve the clarity with which firms describe their services to
     clients.


2.   Address the potential for adviser remuneration to distort
     consumer outcomes; and

3.   Increase the professional standard of advice.




                                                     Raising the standards…
Key Themes - Proposals

1.   Improve the clarity with which firms describe their services to
     clients.

 • Description of advice           • Clarity of - Scope of service,
   services (Independent or          service level agreements,
   restricted).
   restricted)                       brochures, marketing website,
                                     brochures marketing, website
                                     personal profile, company
                                     letters and literature.

                                   • Plus: client authorisation.




                                                   Raising the standards…
Key Themes - Proposals

2.   Address the potential for adviser remuneration to distort
     consumer outcomes.

 • Introduction of Adviser       • Undervaluing knowledge, wisdom
   Charging.                       and experience. Value of services
                                   delivered, what is charged for and
                                   when, clarity of message and
                                   literature. Ongoing services!



 • Setting your own charging
                                 • How calculated, fair!
   tariffs.

 • Individual adviser            • Targets KPIs (quality) and pay
                                   Targets,
   remuneration.                   structure.
Key Themes - Proposals

3.   Increase the professional standards of advice.


     • More focus on setting,           • In-depth assessment methods,
       monitoring and enforcing           scope of service understood,
       standards of competence            competence and CPD activity
       and ethical b h
          d h l behavior.                  li   d
                                          aligned.




     • Need to “prove” initial          • Assessment report and
       and ongoing                        feedback,
                                          feedback independently
       competence.                        assessed annually!



                                                      Raising the standards…
Key Themes – Proposals cont…

3.   Increase the professional standards of advice.

     • Increase in quality and           • How selected, recorded
       control over CPD activity.          and implemented.



     • Increase level of                • Already a requirement of
       q
       qualification to Q
                        QCF               eligibility.
                                          eligibility
       Level 4.


     • Vi ibl adhere t th
       Visibly dh    to the             • Ethi l principles assessed
                                          Ethical i i l            d
       required ethical                   and evidenced.
       standards.


                                                      Raising the standards…
ISO 22222 - Key Differentiators

1.   All about Best Practice – not just about regulatory adherence.

2.   The rules coming out now were already introduced in 2000 with
     the ISO.

3.   Supports your existing compliance provision.

4.   Identifies opportunities for improvement – good business
     principles (IS, BC, CI).

5.   Not limited to UK rules – internationally recognised and
     respected.
     respected




                                                     Raising the standards…
Financial Planner Benefits

• Improved performance.
• Simplified and effective processes and documentation.
• Standardisation of good working practices.
• Improved communication (internally/externally).
• P
  Promotes awareness of quality and professionalism, b tt public
       t               f   lit    d    f i     li    better bli
  awareness and public image.
• Improved sales and marketing opportunities.
    p                        g pp
• Reduced risk = potential reduced insurance costs.
• Supports regulatory requirements.
• The acquisition of a symbol representing
   the internationally recognised
   quality standard
           standard.
                                                    Raising the standards…
Consumer Benefits

• Receive a value added service.
• Assurance of quality through independent third-party
  certification.
       ifi i
• Assurance that regulatory requirements are being adhered to and
  monitored.
• Evidence that continual improvement and their needs are core to
  the business.
• Confidence in the sustainability of the business.
                                   y
• Confidence that the adviser has the right level of knowledge and
  skills to deliver their desired level of service.




                                                  Raising the standards…
ISO 22222 – The Key Elements

1. The Six Steps of the Financial Planning Process.
   • Establishing and defining the client and personal financial planner
      relationship.
   • Gathering client data & determining goals and expectations.
   • Analysing and evaluating the client s financial status.
                                  client’s           status
   • Developing and presenting the financial plan.
   • Implementing the financial planning recommendations.
   • Monitoring the financial plan and the financial planning relationship.

2. Ethical Behaviour and Ethical Financial Planning.
3. Information Security, Client Confidentiality and Data Protection.
4. Risk Management and Business Continuity.
5. Continual Improvement.
                                                           Raising the standards…
Refreshment Break

                    Back in 5 minutes




                          Raising the standards…
ISO 22222 – The Six Steps

1. Establishing and defining the client and personal financial planner
   relationship.
              p
2. Gathering client data & determining goals and expectations.
3. Analysing and evaluating the client’s financial status.
       y g                g
4. Developing and presenting the financial plan.

5.
5 Implementing the financial planning recommendations.
                                      recommendations
6. Monitoring the financial plan and the financial planning relationship.




                                                      Raising the standards…
ISO 22222 – The Financial Plan

1. Key Areas:
•   Financial Statement Analysis, Investment Planning, Tax Planning, Risk
    Management and insurance, Retirement Planning and Estate Planning.


2. To include, but not limited to:
•   Client data - including a schedule of investments, client goals, assumptions,
    balance sheet/net worth statement, current cash flow statement -
    incorporating an income tax assessment, statement of financial position in
    the event of death and disability, retirement planning analysis, investment
    analysis, analysis of other specific future monetary goals, estate planning,
       l         l      f h          f f                    l           l
    recommendations, implementation programme, periodic review and
    plan update strategy.

                                                            Raising the standards…
Ethics & Ethical Financial Planning




                          Raising the standards…
The 10 Key Ethical Principles
• Behaving with integrity.
• Putting clients’ interests first.
• Exercising due care and diligence.
• Working within regulatory and legislative frameworks.
• Carefully and comprehensively managing conflicts of interest.
• Communicating in a clear and appropriate manner.
• Providing suitable and objective recommendations.
• Protecting client confidentiality.
• Making all material disclosures.
• Demonstrating and maintaining appropriate competence.


                                                    Raising the standards…
What is ethical financial planning?
• Using a client centred approach.

• Understanding what the client’s real concerns are.

• Using screened and environmentally focussed investments.

• Being aware of and considering ethical implications of all financial.
      g                        g           p
  products and providers – mortgage, protection, etc.

• Balancing ethical and investment objectives.
          g                          j




                                                     Raising the standards…
Issues for advisers


• Assessing ethical profiles.

    o   Client discussions.

    o   Profiling forms and software (synaptics).

    o   Negative and positive screening.

    o   Asset allocation.

    o   Balancing, risk, objectives and values.




                                                    Raising the standards…
Why are ethics important?

• It’s the client money.

• Their values - not yours.

• Acting in the interest of your client.

• Ethical clients are more ‘connected’.
                            connected .

• … it’s the professional thing to do.




                                             Raising the standards…
Life as an ethical planner

• Not all clients are eco warriors.

• … or treehuggers.



• Interesting.

• Varied.

• Challenging
  Challenging.

• Rewarding.




                      Raising the standards…
Life as an ethical planner
• Clients tend to be:
    o Caring professions.

    o Academics
       Academics.
    o 3rd sector.

    o Independently wealthy.



• They are also:
    o   Loyal.
    o   Sticky.
    o   and well connected.




                                             Raising the standards…
For more information




• UKSIP – Advisers Toolkit and training materials – www.uksif.org
• EIA – Quarterly conferences, IFA Directory –
  www.ethicalinvestments.org.uk
• EIRiS – ethical funds research – www.eiris.org
• National Ethical Investment Week – 7-13 November 2010 – www.neiw.org




                                                    Raising the standards…
The Ethical Question

Q: Do you have any social, ethical, environmental or religious
considerations that you would like us to take into account
in our work for you ?




                                                Raising the standards…
Information Security




           Raising the standards…
Introduction

•   “The blunt truth is that all organisations need to take the protection
    of customer data with the utmost seriousness. I have made clear
    publicly on several occasions over the past year that organisations
    holding individuals’ data must in particular take steps to ensure that
    it is adequately protected from loss or theft. There have been
    several high-profile incidents of data loss in public and private
    sectors during that time which have highlighted that some
    organisations could do much better. The coverage of these incidents
    has also raised public awareness of how lost or stolen data can be
    used for crimes like identity fraud. Getting data protection wrong
    can bring commercial, reputational, regulatory and legal penalties.
    Getting it right brings rewards in terms of customer trust and
    confidence”.
                           Richard Thomas – I f
                           Ri h d Th        Information C
                                                    i Commissioner
                                                          i i
                                                      Raising the standards…
Data protection
Principles of the Data Protection Act 1998
The eight principles require that personal information:

  1.   shall be processed fairly and lawfully and, in particular, shall not be processed unless specific
       conditions are met;
  2.   shall be obtained only for one or more specified and lawful purposes, and shall not be further
       processed in any manner incompatible with that purpose or those purposes;
  3.   shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they
       are processed;
  4.
  4    shall be accurate and where necessary kept up to date;
                         and,      necessary,
  5.   shall not be kept for longer than is necessary for the specified purpose(s);
  6.   shall be processed in accordance with the rights of data subjects under the Act;
  7.
  7    should be subject to appropriate technical and organisational measures to prevent the unauthorised or
       unlawful processing of personal data, or the accidental loss, destruction, or damage to personal data;
  8.   shall not be transferred to a country or territory outside the European Economic Area unless that
       country or territory ensures an adequate level of protection for the rights and freedoms of data
       subjects in relation to the processing of personal data.
                                                                                  Raising the standards…
FSA Principles for Businesses
Principle 2 – Skill, care and diligence

•   A firm must conduct its business and organise its affairs with due
    skill, care and diligence. This will include arranging adequate
    protection for customers’ assets when responsible for them.

•   The concept of ‘care’ includes care towards customers: to the
    extent that the firm owes duties to its customers, it must discharge
    those duties with care. What is ‘adequate’ will, of course, depend
    on the nature of the firm and it counterparties and th b i
       th    t     f th fi      d its     t      ti    d the business it
    undertakes.

    http://www.fsa.gov.uk/pubs/cp/cp13.pdf
    htt //     f        k/ b / / 13 df




                                                     Raising the standards…
Information Security is critical for SMEs
The F t
Th Facts:

•   52% of organisations reported misuse of internet resources. The two most common being
    access to inappropriate websites (41%) and excessive web surfing (36%) - (DTI
    Information Security Breaches survey)

•   Employees waste more than 2 hours a day on recreational computer activities – research
    by AOL & Salary.com

•   30 percent to 40 percent of Internet use in the workplace is unrelated to business. (IDC)

•   70 percent of all Internet porn traffic occurs during the 9 to 5 workday. (Sextracker)

•   85% of all malware threats are delivered by visiting infected websites, three quarters of
    which are legitimate websites.

•   over 90% of cyber attacks exploit known security flaws for which remediation is available
    through timely patch management. (Gartner Research)

•   Phishing attacks are increasing by 25% month on month. (Symantec 2009) – rogue anti
    virus, banking details, promised tax rebates, email account details, etc.
    http://www.silicon.com/publicsector/0,3800010403,39582315,00.htm?s_cid=235
Information security is critical for SMEs
The Facts:
 h
•   53 % of staff say they would take sensitive information from their
    employers if they were fired or made redundant
•   40%+ of emails at work are non-business related (IDC research)
•   A staggering 8500 mobile devices were lost at UK airports in 2007,
    with 400 laptops lost at London airports alone. Even more worrying, a
    Ponemon Institute report in 2008 found that 49% of European business
    travellers said their laptops contained confidential information and
                            p p
    42% said their data was not backed up, or encrypted.
•   67% of UK organizations do nothing to prevent confidential data from
    leaving on USB sticks and other removable devices even though 57%
                                               devices,
    had serious data breach incidents in 2008.



                                                       Raising the standards…
What are the risks?
•   Lost productivity and billing time – irresponsible browsing can be
    costing tens of thousands of pounds for even the smallest
    organisation.
•   Damage to reputation – can you be trusted to keep my information
    confidential?
•   Loss of business – 50% of any loss due to a data breach is the result
    of clients moving their custom elsewhere.
•   Loss of competitive advantage – your client database could well be
    in the hands of a competitor, or worse a criminal.
                      competitor     worse, criminal
•   Disclosure of intellectual property – how long have you been
    developing and protecting that new project?
•   Fines or even closure – The Information Commissioners Office and
    regulatory bodies are taking a much tougher stance on those who are
    negligent, whatever the size or profile of the organisation.

                                                       Raising the standards…
What are the risks?
•   An unencrypted laptop containing details on 109,000 pension schemes
    members with UK pension funds service provider, The Pensions Trust, has
    been stolen from a third-party office in Marlow, Buckinghamshire.

•   The laptop theft is believed to have been targeted, and was carried out at
    The Pensions Trust’s software provider, NorthgateArinso’s offices.
    NorthgateArinso, a global human resources software and services provider,
    says the laptop was stored in a locked room and that the machine itself had
      y        p p
    password protection. The lost data, however, which includes names,
    addresses, national insurance numbers, and bank details for those already
    receiving their pension, was not encrypted.

•   Skipton Financial Services has been found in breach of the Data Protection
    Act for not encrypting the information of 14,000 customers on a laptop
    that was stolen.

•   The laptop - which contained names, dates of birth, national insurance
    numbers and investment amounts - was stolen from a contractor in December
    last year.


                                                         Raising the standards…
What are the risks?
•   Capita Financial Administrators limited were fined £300,000 in 2006 for
                                                          £300 000
    failing to conduct its business with due skill, care and diligence in
    considering the risks posed by financial crime and by failing to take
    reasonable care to organise and control its affairs responsibly and
                           g                                p       y
    effectively.
•   Merchant Securities Group Limited were fined £110,000 in 2008 for not taking
    reasonable care to establish and maintain effective systems and controls for
                                                         y
    countering the risk that customer information held by the Firm might be
    compromised by theft, loss or unauthorised alteration.
•   The UK branch of Zurich Insurance has reported the loss of a back-up data
                                              p                          p
    tape in South Africa that contained the details of 51,000 general insurance
    customers. It claimed that it had written to the customers and ‘other
    parties in the UK' to inform them of the loss and the remedial actions
    being taken
          taken.
•   Do not think you are too small to be affected – from April 2010 the ICO will
    have greater powers to impose sanctions, financial or otherwise, on those
    organisations involved in “The knowing or reckless misuse of personal data”
                                                                           data”.
    http://www.fsa.gov.uk/Pages/library/                    Raising the standards…
What are the risks?




       Raising the standards…
The solution - a 14 point plan

1    Governance
•   Develop a security policy document that everyone from senior
    management t junior members of staff can ‘b i t ’
                t to j i        b   f t ff     ‘buy into’

2    Training and awareness

•   Make everybody aware of the risks

     o   Innovative training programmes

     o   Wall posters

     o   Screensavers

     o   Newsletters



                                                    Raising the standards…
The Solution – a 14 point plan
3 Servers, desktops and laptops
•   If customer data is stored on a laptop, desktop or a file server, you need
    to have the following security precautions in place:
     o   Firewall
     o   Antivirus and antispyware software
     o   Full disk encryption
     o   Removable device encryption
                              yp
     o   Encrypted backups




                                                        Raising the standards…
The Solution – a 14 point plan
4    Password protection

•   Password protection for all computers is essential!!!
     o   Your password should be at least 8 characters long
     o   It should include letters, numbers, capitals and other symbols,
         for example: P@nD4b34R
     o   It should be easy to remember but hard to guess
     o   Avoid any work in the dictionary, personal information such as a
         child or partner’s name or a football team common names and
                  partner s                    team,
         slang
     o   Try playing on normal words such as England – 3enG1@Nd!
     o   Do not write passwords d
                               d down
     o   Do not tell anyone else your passwords
     o   Change your p
               g y     password every 90 days at the very least!
                                      y     y            y

                                                            Raising the standards…
The Solution – a 14 point plan
5    Email security
•   All emails containing customer data must be secure
•   Avoid spam and email borne viruses and malware
•   Police your email usage policy to avoid data leakage and litigation
6    Physical
     Ph i l security
                 i
•   Physical security is a key factor in securing your data
•   Your file database and e mail servers should all be kept in a locked
         file,             e-mail
    cabinet within a secure room to prevent casual access
•   External hard drives that contain customer data should be locked
    away when not in use




                                                        Raising the standards…
The Solution – a 14 point plan
7   Backups
• Full backups of all critical date should be standard practice:
    o   Backup media should be locked away securely while not in use
    o   Only authorised personnel should have access to backup media
    o   Backup
        B k media should be h ld off site f di
               di h ld b held ff i for disaster recovery
    o   If the media is held off site it should be transported and stored
        securely i.e. a lock box or safe
                y
    o   Back up media needs to be encrypted




                                                       Raising the standards…
The Solution – a 14 point plan
8   Access control
• Users should only have permission to access confidential information
  they need to do their job
    o   You should review access permissions for every user at regular
        intervals
    o   Each employee should have their own logon account
    o   Employee access should be revoked as soon as they leave the
        company or are suspended
                             d d
    o   Locations where sensitive or confidential information is stored
        should be audited




                                                         Raising the standards…
The Solution – a 14 point plan
9    Data transfer
• Any movement of data outside of your secure environment eg USB or CD,
  needs to follow these guidelines:
     o    Encrypt all portable media using a suitable encryption technique
     o    Use device control software to control and detect unauthorised
          access to external media such as CDs and USB devices
     o    Keep a record of all of these devices and which personnel are
          allowed to use them and for which purpose
10       Asset management
• You need to keep a record of all computers, laptops, USB devices,
  external hard drives that exist in your business
• You need to maintain a record of all data copied onto media moving
  outside your secure environment and the reason for doing so
                                                         Raising the standards…
The Solution – a 14 point plan
11       Data destruction
• Data removal and destruction is an important part of keeping your
  clients
  clients’ information secure
     o    Paper records need to be shredded in house or by an approved
          agency that must be vetted
     o    Hard drives should be disposed of securely ensuring all data is
          destroyed
     o    Certificates h ld be bt i d from agencies confirming
          C tifi t should b obtained f               i      fi i
          destruction of data from hard drives and recycled computer
          systems




                                                          Raising the standards…
The Solution – a 14 point plan
12   Remote access
• Remote access to your network needs to be secure
• Remote access and VPN software needs to be configured properly for the
  highest possible security level
• Home workers need to ensure that any wireless network is encrypted to
  the highest possible standards
• Home workers need to prevent unauthorised access to their computer
  systems through password protection at l t
     t    th    h        d    t ti     t least




                                                     Raising the standards…
The Solution – a 14 point plan
13       Staff recruitment
• Where legally possible carry out every background check on staff who
  will be exposed to confidential information:
     o    Credit references
     o    CRB checks
     o    CIFAS staff fraud database
     o    References
     o    CV validation
     o    Assess regularly if staff in higher-risk positions may be susceptible to
          coercion




                                                            Raising the standards…
The Solution – a 14 point plan
14   Email and internet access
• Implement monitoring controls for email and internet activity to
  identify potential data leakage
• Filter access to content that allows web based communication such as
  webmail (Hotmail, Gmail, Yahoo, MSN instant messaging) social
  networking sites like Facebook and Myspace
• Restrict or block access to file sharing site




                                                   Raising the standards…
The Solution – a 14 point plan

14    Email and internet access (continued)

• Why?
• More than 60% of companies have disciplined – and more than 30% have
  terminated – employees for inappropriate use of the internet in the workplace
• 80% of companies reported that employees had abused internet privileges, such
  as downloading pornography or pirated software
• 70% of all pornographic downloads occur between 9:00am and 5:00pm
• 25% of employees admit to spending between 10 and 30 minutes per day surfing
  non-work related websites. 22% admit to spending between 30 minutes and 1
  hour. 12% said they spent between 1 and 2 hours online and 13% admitted to
  spending more than 2 hours per day visiting non-work related websites
• 46% of online shopping during the Christmas period occurs at work – is this your
  busiest time of the year?



                                                             Raising the standards…
Business Continuity and Risk Management




                            Raising the standards…
Business Continuity and Risk Management

        An Holistic Management Process.
       • Identifying areas of potential risk.
       • Evaluate the possible threats;
       • Choose appropriate strategies to reduce the likelihood and impact of
         incidents;
       • Choose appropriate strategies that provide for the continuity or recovery
         of the critical activities
                         activities.

        Possible Risks
 Key Persons, Information Technology (IT), Data and Information, Financial Resources,
     Persons                         (IT)           Information            Resources
    Human Resources, Service, Money Laundering, Data Protection and Processing,
Q
Quality and Suitability of Advice, Accounts and Commissions, The Economy, Regulation,
      y               y          ,                         ,           y, g         ,
   Complaints, Training and Competence Requirements, Location and Premises and
                                Health and Safety.
Business Continuity and Risk Management

 Write a Plan.
• Team Lists and Alert Procedure.
• Plan for Major Incidents – Fire, Flood or Attack.
• Business Critical Systems.
• Key Contacts and Business Partners.
• Emergency Procedure – Meeting Place.

 Test and Communicate.




                                                      Raising the standards…
Continual Improvement




          Raising the standards…
Continual Improvement

•   Two Areas of Continual Improvement.

    o     Business
    o     Personal

• PDCA

    o     Plan,
    o     Do,
    o     Check &
    o     Act.




•       Client feedback – Positive and negative.

                                                   Raising the standards…
Continual Improvement
Training and Competence
• FSA current focus on outputs from firms to demonstrate
  effectiveness and to ensure customers are protected.
• No formal requirement from FSA for a written T&C scheme but,
• FSA d
      does require adequate procedures, records and effective
                    d             d          d    d ff
  management controls to be in place.
• All of these achieved by T&C scheme. A good T&C scheme is central
  to ensuring that customers are treated fairly.
• A Training Needs Analysis is essential to its success (plugs the GAP).




                                                     Raising the standards…
Continual Improvement
What should be covered in a T&C scheme?
• Scope - types of staff and activities of firm. Include non-
  authorised as well as authorised.
    th i d         ll      th i d

• Achieving competence - stages of competence, training needs,
  regulatory exams.

• Maintaining competence - keeping relevant knowledge, skills and
  understanding of the market up to date.

• Supervision - additional knowledge and skills requirements, level
  of supervision, spans of control.

• Record keeping - regulatory requirements, methods.



                                                     Raising the standards…
Continual Improvement
Achieving and Maintaining Competence

• What does competence look like? Job description, accountability
  profile and person specification.

• Stages required in achieving competence and standards to be
  reached at each stage
                   stage.

• Use of KPIs in driving standards and further training needs.

• Qualification requirements - FSSC list
                                    list.

• Ongoing assessment - what and how, assessment type, failure
  p
  policy, core and specialist areas.
       y,           p
Records
•   Meet regulatory requirements and achieve g
           g      y q                        good p
                                                  practice.
•   Use technology. Record keeping should not become a burden!
Continual Improvement
Continual Professional Development (CPD)

• Importance – Helps to maintain competence, Relevant and
  interesting, include regulatory changes i.e TCF.

• CPD – Should be planned and include objectives and success
  criteria.
  criteria

• Records – activity undertaken, time spent, objectives met or not!,
  further development needs, how the knowledge has been applied
  and what are the benefits!.
• Signed off against objectives!




                                                   Raising the standards…
Continual Improvement
Continual Professional Development (CPD) - Methods

• Web Research & Online Tutorials and Webinars.
• Exam Study & Books
               Books.
• Newspapers/Broadsheets & Newsletters.
• Current Affairs.
• Professional/technical seminars, workshops and events – Internal.
• Professional/technical seminars, workshops and events – External.
• Technical product and provider presentation – Internal
  Technical,                                    Internal.
• Professional/business and personal development seminars,
  workshops and events.
• Audio CDs.
    Must change when:
•    Environment Changes, O g i ti Ch g and th
     E i         t Ch g    Organisation Changes d there are
     individual performance issues.
                                                   Raising the standards…
How can firms maximise both internal
                             and external learning?

Internal:                   External:
                 g
• Formal training.          •   Formal training course
                                                course.
• Work shadowing.           •   Exam preparation.
• One to one coaching.
                            •   Distance learning.
• Job rotation
       rotation.
                            •   Case studies.
• Role play.
                            •   Conferences.
• Accompanied call.
• Mentoring.




                                            Raising the standards…
Continual Improvement
Maximise your learning by:

• Teaching Others.

• Writing Articles, White Papers and Books.

• Get involved with the profession.

• Get involved with local universities, schools and your community.




                                                    Raising the standards…
Continual Improvement – Client Feedback
Internal and External Feedback

• Client Feedback – Manual or Electronic.
• Client Advisory Board.
Key Considerations

• Establish current feedback methods and process.
•   Review current success, outputs and response rates.
• Identify any gaps in the system, define and agree your wish list.
• Research market and available options.
• Select chosen methods and tools.
    l     h        h d    d    l
• Update or create operational procedures and supporting documents.
• Record monitor measure and ACT!
  Record, monitor,
                                                    Raising the standards…
Documenting your Practice Management System

Two Main Levels

• Level 1 – Guidelines.

• Level 2 – Processes.




                               Raising the standards…
Documenting your Practice Management System

Key Steps

• Identify who does what
                    what.
• What is your desired outcome?
• How best should it be documented?
• Who is currently responsible for the process?
• What tools support the process? – Software systems
                                             systems.
• Roll Out, Test and Amend.
• Include in your Practice Management System
                                      System.




                                                 Raising the standards…
Documenting your Practice Management System

• Meet contractual, statutory and regulatory guidelines.

• Unique reference number, authorisation.

• Clear and concise, simple and understandable, tested and amended,
                    ,    p                    ,                   ,
  quality controlled and well communicated.

• Quality at the core.
  Q     y

• Interrelated and interactive processes.
• Create a library of templates, letters emails and forms
                      templates letters,            forms.




                                                Raising the standards…
Documenting your Practice Management System

Examples….

• Telephone and email enquiries
                      enquiries.

• First meeting confirmation and information.

• Conducting a first meeting and follow up.

• Information gathering.

• Creating a financial plan.

• I l
  Implementing th solutions and strategies.
          ti the l ti         d t t i




                                                Raising the standards…
Documenting your Practice Management System

Creating A Process Improvement Culture

• Have all key p
             y processes been identified and documented?

• Are they effective in producing the desired results?

• A th available i b th h d and soft copy f
  Are they il bl in both hard d ft        formats?.
                                               t ?

• Have they been effectively implemented?

• Have they been logged and quality controlled?




                                                  Raising the standards…
How to prepare for an assessment

• Review your gap analysis.

• Identify your gaps
                gaps.

• Set yourself an assessment deadline.

• All
  Allocate “Gap Manager” and agree ti f
        t “G M         ”   d       timeframes.

• Brief the rest of the team.

• Work through tasks, roll out to the team.

• Engage with a SI Approved Associate Consultant (AAC).

• Collate Evidence ready for the assessment.



                                                Raising the standards…
Lunch




Raising the standards…
Welcome Back

               ISO 22222 - Gap Analysis




                           Raising the standards…
What happens next?
• Assessment Preparation.

• Assessment.
    o     Portfolio of Evidence: case studies, testimonials,
          client feedback. client files, business processes.
• De-brief.
    o   OBS, MiNC, MaNC
• Assessor Sub ts Report.
   ssesso Submits epo t.

• Independent Assessment – HQ.
• If Happy - Confirmation of Certification
                             Certification.
• If not Happy – Rebook Assessment.
• Certification Awarded – Guideline and Letter.

                                                    Raising the standards…
Any Questions..?




                   Raising the standards…

Weitere ähnliche Inhalte

Ähnlich wie Standards International Ltd ISO 22222 Overview

TC68 Amsterdam - ISO 22222 Presentation
TC68 Amsterdam - ISO 22222 PresentationTC68 Amsterdam - ISO 22222 Presentation
TC68 Amsterdam - ISO 22222 PresentationMichelle Hoskin
 
ISO 22222 - Achieving A Competitive Edge Presentation 2010
ISO 22222 - Achieving A Competitive Edge Presentation 2010ISO 22222 - Achieving A Competitive Edge Presentation 2010
ISO 22222 - Achieving A Competitive Edge Presentation 2010Michelle Hoskin
 
AAC Training Presentation 2009
AAC  Training  Presentation 2009AAC  Training  Presentation 2009
AAC Training Presentation 2009Michelle Hoskin
 
ISO 22222 Information Sheet
ISO 22222 Information SheetISO 22222 Information Sheet
ISO 22222 Information SheetMichelle Hoskin
 
ISO 22222 Information Sheet
ISO 22222 Information SheetISO 22222 Information Sheet
ISO 22222 Information SheetMichelle Hoskin
 
ISO Knowledge Management standard
ISO Knowledge Management standardISO Knowledge Management standard
ISO Knowledge Management standardFernando Zeballos
 
ISO Certification in Dubai (2).pdf
ISO Certification in Dubai (2).pdfISO Certification in Dubai (2).pdf
ISO Certification in Dubai (2).pdfZoyaAbdul1
 
Investor in people
Investor in peopleInvestor in people
Investor in peoplephongv
 
quality - security - environment project
quality - security - environment projectquality - security - environment project
quality - security - environment projectIsraa Hussein
 
The Nuts & Bolts of ISO 9001
The Nuts & Bolts of ISO 9001The Nuts & Bolts of ISO 9001
The Nuts & Bolts of ISO 9001BSI America
 
The Product Manager Pathfinder - ProductCamp Toronto - H. Del Castillo, AIPMM
The Product Manager Pathfinder - ProductCamp Toronto - H. Del Castillo, AIPMMThe Product Manager Pathfinder - ProductCamp Toronto - H. Del Castillo, AIPMM
The Product Manager Pathfinder - ProductCamp Toronto - H. Del Castillo, AIPMMHector Del Castillo, CPM, CPMM
 
Independent consultants working together
Independent consultants working togetherIndependent consultants working together
Independent consultants working togetherBryan Cassady
 
ISO 22222 - Information 2013
ISO 22222 - Information 2013ISO 22222 - Information 2013
ISO 22222 - Information 2013Michelle Hoskin
 
The Professional Consultant
The Professional ConsultantThe Professional Consultant
The Professional Consultantmarklaw
 
What is ISO20000
What is ISO20000What is ISO20000
What is ISO20000Ben Kalland
 
+AUDIO Selling Business Analysis Internally
+AUDIO Selling Business Analysis Internally+AUDIO Selling Business Analysis Internally
+AUDIO Selling Business Analysis InternallyIIBA UK Chapter
 
Contract Solutions: Consulting
Contract Solutions: ConsultingContract Solutions: Consulting
Contract Solutions: ConsultingTim Keelan
 
Advisory services to_india_education_v1
Advisory services to_india_education_v1Advisory services to_india_education_v1
Advisory services to_india_education_v1ankur3112
 

Ähnlich wie Standards International Ltd ISO 22222 Overview (20)

TC68 Amsterdam - ISO 22222 Presentation
TC68 Amsterdam - ISO 22222 PresentationTC68 Amsterdam - ISO 22222 Presentation
TC68 Amsterdam - ISO 22222 Presentation
 
ISO 22222 - Achieving A Competitive Edge Presentation 2010
ISO 22222 - Achieving A Competitive Edge Presentation 2010ISO 22222 - Achieving A Competitive Edge Presentation 2010
ISO 22222 - Achieving A Competitive Edge Presentation 2010
 
AAC Training Presentation 2009
AAC  Training  Presentation 2009AAC  Training  Presentation 2009
AAC Training Presentation 2009
 
ISO 22222 Information Sheet
ISO 22222 Information SheetISO 22222 Information Sheet
ISO 22222 Information Sheet
 
ISO 22222 Information Sheet
ISO 22222 Information SheetISO 22222 Information Sheet
ISO 22222 Information Sheet
 
ISO Knowledge Management standard
ISO Knowledge Management standardISO Knowledge Management standard
ISO Knowledge Management standard
 
ISO Certification in Dubai (2).pdf
ISO Certification in Dubai (2).pdfISO Certification in Dubai (2).pdf
ISO Certification in Dubai (2).pdf
 
Investor in people
Investor in peopleInvestor in people
Investor in people
 
quality - security - environment project
quality - security - environment projectquality - security - environment project
quality - security - environment project
 
ISO9001-2015 3-25-19
ISO9001-2015   3-25-19ISO9001-2015   3-25-19
ISO9001-2015 3-25-19
 
The Nuts & Bolts of ISO 9001
The Nuts & Bolts of ISO 9001The Nuts & Bolts of ISO 9001
The Nuts & Bolts of ISO 9001
 
The Product Manager Pathfinder - ProductCamp Toronto - H. Del Castillo, AIPMM
The Product Manager Pathfinder - ProductCamp Toronto - H. Del Castillo, AIPMMThe Product Manager Pathfinder - ProductCamp Toronto - H. Del Castillo, AIPMM
The Product Manager Pathfinder - ProductCamp Toronto - H. Del Castillo, AIPMM
 
5th Anniversary Celebration slides
5th Anniversary Celebration slides   5th Anniversary Celebration slides
5th Anniversary Celebration slides
 
Independent consultants working together
Independent consultants working togetherIndependent consultants working together
Independent consultants working together
 
ISO 22222 - Information 2013
ISO 22222 - Information 2013ISO 22222 - Information 2013
ISO 22222 - Information 2013
 
The Professional Consultant
The Professional ConsultantThe Professional Consultant
The Professional Consultant
 
What is ISO20000
What is ISO20000What is ISO20000
What is ISO20000
 
+AUDIO Selling Business Analysis Internally
+AUDIO Selling Business Analysis Internally+AUDIO Selling Business Analysis Internally
+AUDIO Selling Business Analysis Internally
 
Contract Solutions: Consulting
Contract Solutions: ConsultingContract Solutions: Consulting
Contract Solutions: Consulting
 
Advisory services to_india_education_v1
Advisory services to_india_education_v1Advisory services to_india_education_v1
Advisory services to_india_education_v1
 

Standards International Ltd ISO 22222 Overview

  • 1. Standards International Ltd ISO 22222 – Training and Gap Analysis Workshop Welcome…
  • 2. How to get the most out of the day.. Learning Styles. Light Bulb Moment M t DO Think Plan Write Talk Raising the standards…
  • 3. Agenda • ISO 22222 - The story so far. • ISO 22222 - An insight. • What makes ISO 22222 different. • The Key El Th K Elements. t • How to document your practice management system. • How to create an implementation plan. • Self Assessment Gap Analysis Analysis. • What happens next? • Any Questions? Raising the standards…
  • 4. Who we are • Established in June 2007 (Pilot Scheme launched in April 2006). • Independent leaders in the market place. • UKAS Accredited Certification Body Body. • We work with the profession’s leading advisers. • Pioneering Best Practice. • Privately Owned - Unique Offering. • Work done so far: o Awareness Campaigns - Professional and Consumer Consumer. o Articles, Features, Presentations and The Book. o Partnerships - P f i Wide. P t hi Profession Wid o The Approved Associate Programme (AAC) . Raising the standards…
  • 5. What are ISO Standards? • More common to the business market. • ISO – International Standards Organisation • Demonstrate the ability to consistently provide a product or service that meets customer requirements in line with regulatory requirements and… • Addresses customer satisfaction through the effective application of the system, developing processes for continual improvement and the prevention of errors and mistakes. Raising the standards…
  • 6. Why have national and international standards? • The Kitemark • The CE Mark • They help businesses to: o Identify d Id tif and meet th needs and expectations of it customers t the d d t ti f its t and other interested parties, e.g. employees, suppliers, owners, societies, to achieve a competitive advantage and to do this in an effective and efficient manner manner. o Achieve, maintain and improve overall performance and capabilities. capabilities Raising the standards…
  • 7. Why have an ISO standard for financial planners? • Increased pressure to demonstrate professionalism. • Demand from clients, professional associations and the regulator. • 2000 ANSI contacted BSI (British St d d I tit t ) who t t t d (B iti h Standards Institute) h turned t th d to the FSA for guidance. • A UK Committee was formed – headed by David Jackman (Head of Industry and T i i ) I d d Training). • Development supported by 17 other worldwide committees. • Developed over nearly 7 y p y years and in March 2006 – ISO 22222 was launched! • April 2006 – SI launched their ISO 22222 Pilot Scheme. • Research carried out by Which? – consumers confused about where to turn for the right financial planning advice. • ISO 22222 – Addresses this, which is why Which? fully support any work to increase professional standards standards. Raising the standards…
  • 8. Why have an ISO standard for financial planners? Raising the standards…
  • 9. Adviser Quotes “Going through the ISO process has enabled us to look at our business in way never before possible. The net result for the consumer is a more efficient and transparent process in receiving holistic financial planning advice” Andrew Reeves, The Investment Coach Limited “ISO 22222 certification process was the best available overall assessment of knowledge, competency and fair customer treatment treatment” Robin Keyte, director of Towers of Taunton Raising the standards…
  • 10. ISO 22222 – An Insight • Enables consumers to identify financial planners who possess the right knowledge, skills, ethics and experience to deliver their desired level of service. • Codifies professional best practice in financial planning from across the world, and will help to increase consumer confidence. • Not another qualification. • Exemption from AF5 – Financial Planning Process (CII). • Not a “tick box” exercise – assessment methods include: tick box File checks / Role Plays / Case Studies / On the job observation. Certification Awarded to the individual within a firm. • Ongoing assessment (encourages internal audits). Raising the standards…
  • 11. Where does ISO 22222 fit in with the current and future landscape? • Four key documents to review: o Consultation P C lt ti Paper – CP09/31 Delivering th R t il Di t ib ti D li i g the Retail Distribution Review (December 2009). o Policy St t P li Statement # 1 – 10/6 Di t ib ti of retail i t Distribution f t il investments t t (March 2010). o Consultation and f db k statement # 2 – (A t C lt ti d feedback t t t (Autumn 2010) 2010). o Remuneration Code – (Quarter 2 2010). • Key Objective: o Forcing best business principles to professionals who primarily are seen as doing a job. Raising the standards…
  • 12. Key Themes - Proposals 1. Improve the clarity with which firms describe their services to clients. 2. Address the potential for adviser remuneration to distort consumer outcomes; and 3. Increase the professional standard of advice. Raising the standards…
  • 13. Key Themes - Proposals 1. Improve the clarity with which firms describe their services to clients. • Description of advice • Clarity of - Scope of service, services (Independent or service level agreements, restricted). restricted) brochures, marketing website, brochures marketing, website personal profile, company letters and literature. • Plus: client authorisation. Raising the standards…
  • 14. Key Themes - Proposals 2. Address the potential for adviser remuneration to distort consumer outcomes. • Introduction of Adviser • Undervaluing knowledge, wisdom Charging. and experience. Value of services delivered, what is charged for and when, clarity of message and literature. Ongoing services! • Setting your own charging • How calculated, fair! tariffs. • Individual adviser • Targets KPIs (quality) and pay Targets, remuneration. structure.
  • 15. Key Themes - Proposals 3. Increase the professional standards of advice. • More focus on setting, • In-depth assessment methods, monitoring and enforcing scope of service understood, standards of competence competence and CPD activity and ethical b h d h l behavior. li d aligned. • Need to “prove” initial • Assessment report and and ongoing feedback, feedback independently competence. assessed annually! Raising the standards…
  • 16. Key Themes – Proposals cont… 3. Increase the professional standards of advice. • Increase in quality and • How selected, recorded control over CPD activity. and implemented. • Increase level of • Already a requirement of q qualification to Q QCF eligibility. eligibility Level 4. • Vi ibl adhere t th Visibly dh to the • Ethi l principles assessed Ethical i i l d required ethical and evidenced. standards. Raising the standards…
  • 17. ISO 22222 - Key Differentiators 1. All about Best Practice – not just about regulatory adherence. 2. The rules coming out now were already introduced in 2000 with the ISO. 3. Supports your existing compliance provision. 4. Identifies opportunities for improvement – good business principles (IS, BC, CI). 5. Not limited to UK rules – internationally recognised and respected. respected Raising the standards…
  • 18. Financial Planner Benefits • Improved performance. • Simplified and effective processes and documentation. • Standardisation of good working practices. • Improved communication (internally/externally). • P Promotes awareness of quality and professionalism, b tt public t f lit d f i li better bli awareness and public image. • Improved sales and marketing opportunities. p g pp • Reduced risk = potential reduced insurance costs. • Supports regulatory requirements. • The acquisition of a symbol representing the internationally recognised quality standard standard. Raising the standards…
  • 19. Consumer Benefits • Receive a value added service. • Assurance of quality through independent third-party certification. ifi i • Assurance that regulatory requirements are being adhered to and monitored. • Evidence that continual improvement and their needs are core to the business. • Confidence in the sustainability of the business. y • Confidence that the adviser has the right level of knowledge and skills to deliver their desired level of service. Raising the standards…
  • 20. ISO 22222 – The Key Elements 1. The Six Steps of the Financial Planning Process. • Establishing and defining the client and personal financial planner relationship. • Gathering client data & determining goals and expectations. • Analysing and evaluating the client s financial status. client’s status • Developing and presenting the financial plan. • Implementing the financial planning recommendations. • Monitoring the financial plan and the financial planning relationship. 2. Ethical Behaviour and Ethical Financial Planning. 3. Information Security, Client Confidentiality and Data Protection. 4. Risk Management and Business Continuity. 5. Continual Improvement. Raising the standards…
  • 21. Refreshment Break Back in 5 minutes Raising the standards…
  • 22. ISO 22222 – The Six Steps 1. Establishing and defining the client and personal financial planner relationship. p 2. Gathering client data & determining goals and expectations. 3. Analysing and evaluating the client’s financial status. y g g 4. Developing and presenting the financial plan. 5. 5 Implementing the financial planning recommendations. recommendations 6. Monitoring the financial plan and the financial planning relationship. Raising the standards…
  • 23. ISO 22222 – The Financial Plan 1. Key Areas: • Financial Statement Analysis, Investment Planning, Tax Planning, Risk Management and insurance, Retirement Planning and Estate Planning. 2. To include, but not limited to: • Client data - including a schedule of investments, client goals, assumptions, balance sheet/net worth statement, current cash flow statement - incorporating an income tax assessment, statement of financial position in the event of death and disability, retirement planning analysis, investment analysis, analysis of other specific future monetary goals, estate planning, l l f h f f l l recommendations, implementation programme, periodic review and plan update strategy. Raising the standards…
  • 24. Ethics & Ethical Financial Planning Raising the standards…
  • 25. The 10 Key Ethical Principles • Behaving with integrity. • Putting clients’ interests first. • Exercising due care and diligence. • Working within regulatory and legislative frameworks. • Carefully and comprehensively managing conflicts of interest. • Communicating in a clear and appropriate manner. • Providing suitable and objective recommendations. • Protecting client confidentiality. • Making all material disclosures. • Demonstrating and maintaining appropriate competence. Raising the standards…
  • 26. What is ethical financial planning? • Using a client centred approach. • Understanding what the client’s real concerns are. • Using screened and environmentally focussed investments. • Being aware of and considering ethical implications of all financial. g g p products and providers – mortgage, protection, etc. • Balancing ethical and investment objectives. g j Raising the standards…
  • 27. Issues for advisers • Assessing ethical profiles. o Client discussions. o Profiling forms and software (synaptics). o Negative and positive screening. o Asset allocation. o Balancing, risk, objectives and values. Raising the standards…
  • 28. Why are ethics important? • It’s the client money. • Their values - not yours. • Acting in the interest of your client. • Ethical clients are more ‘connected’. connected . • … it’s the professional thing to do. Raising the standards…
  • 29. Life as an ethical planner • Not all clients are eco warriors. • … or treehuggers. • Interesting. • Varied. • Challenging Challenging. • Rewarding. Raising the standards…
  • 30. Life as an ethical planner • Clients tend to be: o Caring professions. o Academics Academics. o 3rd sector. o Independently wealthy. • They are also: o Loyal. o Sticky. o and well connected. Raising the standards…
  • 31. For more information • UKSIP – Advisers Toolkit and training materials – www.uksif.org • EIA – Quarterly conferences, IFA Directory – www.ethicalinvestments.org.uk • EIRiS – ethical funds research – www.eiris.org • National Ethical Investment Week – 7-13 November 2010 – www.neiw.org Raising the standards…
  • 32. The Ethical Question Q: Do you have any social, ethical, environmental or religious considerations that you would like us to take into account in our work for you ? Raising the standards…
  • 33. Information Security Raising the standards…
  • 34. Introduction • “The blunt truth is that all organisations need to take the protection of customer data with the utmost seriousness. I have made clear publicly on several occasions over the past year that organisations holding individuals’ data must in particular take steps to ensure that it is adequately protected from loss or theft. There have been several high-profile incidents of data loss in public and private sectors during that time which have highlighted that some organisations could do much better. The coverage of these incidents has also raised public awareness of how lost or stolen data can be used for crimes like identity fraud. Getting data protection wrong can bring commercial, reputational, regulatory and legal penalties. Getting it right brings rewards in terms of customer trust and confidence”. Richard Thomas – I f Ri h d Th Information C i Commissioner i i Raising the standards…
  • 35. Data protection Principles of the Data Protection Act 1998 The eight principles require that personal information: 1. shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met; 2. shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes; 3. shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed; 4. 4 shall be accurate and where necessary kept up to date; and, necessary, 5. shall not be kept for longer than is necessary for the specified purpose(s); 6. shall be processed in accordance with the rights of data subjects under the Act; 7. 7 should be subject to appropriate technical and organisational measures to prevent the unauthorised or unlawful processing of personal data, or the accidental loss, destruction, or damage to personal data; 8. shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data. Raising the standards…
  • 36. FSA Principles for Businesses Principle 2 – Skill, care and diligence • A firm must conduct its business and organise its affairs with due skill, care and diligence. This will include arranging adequate protection for customers’ assets when responsible for them. • The concept of ‘care’ includes care towards customers: to the extent that the firm owes duties to its customers, it must discharge those duties with care. What is ‘adequate’ will, of course, depend on the nature of the firm and it counterparties and th b i th t f th fi d its t ti d the business it undertakes. http://www.fsa.gov.uk/pubs/cp/cp13.pdf htt // f k/ b / / 13 df Raising the standards…
  • 37. Information Security is critical for SMEs The F t Th Facts: • 52% of organisations reported misuse of internet resources. The two most common being access to inappropriate websites (41%) and excessive web surfing (36%) - (DTI Information Security Breaches survey) • Employees waste more than 2 hours a day on recreational computer activities – research by AOL & Salary.com • 30 percent to 40 percent of Internet use in the workplace is unrelated to business. (IDC) • 70 percent of all Internet porn traffic occurs during the 9 to 5 workday. (Sextracker) • 85% of all malware threats are delivered by visiting infected websites, three quarters of which are legitimate websites. • over 90% of cyber attacks exploit known security flaws for which remediation is available through timely patch management. (Gartner Research) • Phishing attacks are increasing by 25% month on month. (Symantec 2009) – rogue anti virus, banking details, promised tax rebates, email account details, etc. http://www.silicon.com/publicsector/0,3800010403,39582315,00.htm?s_cid=235
  • 38. Information security is critical for SMEs The Facts: h • 53 % of staff say they would take sensitive information from their employers if they were fired or made redundant • 40%+ of emails at work are non-business related (IDC research) • A staggering 8500 mobile devices were lost at UK airports in 2007, with 400 laptops lost at London airports alone. Even more worrying, a Ponemon Institute report in 2008 found that 49% of European business travellers said their laptops contained confidential information and p p 42% said their data was not backed up, or encrypted. • 67% of UK organizations do nothing to prevent confidential data from leaving on USB sticks and other removable devices even though 57% devices, had serious data breach incidents in 2008. Raising the standards…
  • 39. What are the risks? • Lost productivity and billing time – irresponsible browsing can be costing tens of thousands of pounds for even the smallest organisation. • Damage to reputation – can you be trusted to keep my information confidential? • Loss of business – 50% of any loss due to a data breach is the result of clients moving their custom elsewhere. • Loss of competitive advantage – your client database could well be in the hands of a competitor, or worse a criminal. competitor worse, criminal • Disclosure of intellectual property – how long have you been developing and protecting that new project? • Fines or even closure – The Information Commissioners Office and regulatory bodies are taking a much tougher stance on those who are negligent, whatever the size or profile of the organisation. Raising the standards…
  • 40. What are the risks? • An unencrypted laptop containing details on 109,000 pension schemes members with UK pension funds service provider, The Pensions Trust, has been stolen from a third-party office in Marlow, Buckinghamshire. • The laptop theft is believed to have been targeted, and was carried out at The Pensions Trust’s software provider, NorthgateArinso’s offices. NorthgateArinso, a global human resources software and services provider, says the laptop was stored in a locked room and that the machine itself had y p p password protection. The lost data, however, which includes names, addresses, national insurance numbers, and bank details for those already receiving their pension, was not encrypted. • Skipton Financial Services has been found in breach of the Data Protection Act for not encrypting the information of 14,000 customers on a laptop that was stolen. • The laptop - which contained names, dates of birth, national insurance numbers and investment amounts - was stolen from a contractor in December last year. Raising the standards…
  • 41. What are the risks? • Capita Financial Administrators limited were fined £300,000 in 2006 for £300 000 failing to conduct its business with due skill, care and diligence in considering the risks posed by financial crime and by failing to take reasonable care to organise and control its affairs responsibly and g p y effectively. • Merchant Securities Group Limited were fined £110,000 in 2008 for not taking reasonable care to establish and maintain effective systems and controls for y countering the risk that customer information held by the Firm might be compromised by theft, loss or unauthorised alteration. • The UK branch of Zurich Insurance has reported the loss of a back-up data p p tape in South Africa that contained the details of 51,000 general insurance customers. It claimed that it had written to the customers and ‘other parties in the UK' to inform them of the loss and the remedial actions being taken taken. • Do not think you are too small to be affected – from April 2010 the ICO will have greater powers to impose sanctions, financial or otherwise, on those organisations involved in “The knowing or reckless misuse of personal data” data”. http://www.fsa.gov.uk/Pages/library/ Raising the standards…
  • 42. What are the risks? Raising the standards…
  • 43. The solution - a 14 point plan 1 Governance • Develop a security policy document that everyone from senior management t junior members of staff can ‘b i t ’ t to j i b f t ff ‘buy into’ 2 Training and awareness • Make everybody aware of the risks o Innovative training programmes o Wall posters o Screensavers o Newsletters Raising the standards…
  • 44. The Solution – a 14 point plan 3 Servers, desktops and laptops • If customer data is stored on a laptop, desktop or a file server, you need to have the following security precautions in place: o Firewall o Antivirus and antispyware software o Full disk encryption o Removable device encryption yp o Encrypted backups Raising the standards…
  • 45. The Solution – a 14 point plan 4 Password protection • Password protection for all computers is essential!!! o Your password should be at least 8 characters long o It should include letters, numbers, capitals and other symbols, for example: P@nD4b34R o It should be easy to remember but hard to guess o Avoid any work in the dictionary, personal information such as a child or partner’s name or a football team common names and partner s team, slang o Try playing on normal words such as England – 3enG1@Nd! o Do not write passwords d d down o Do not tell anyone else your passwords o Change your p g y password every 90 days at the very least! y y y Raising the standards…
  • 46. The Solution – a 14 point plan 5 Email security • All emails containing customer data must be secure • Avoid spam and email borne viruses and malware • Police your email usage policy to avoid data leakage and litigation 6 Physical Ph i l security i • Physical security is a key factor in securing your data • Your file database and e mail servers should all be kept in a locked file, e-mail cabinet within a secure room to prevent casual access • External hard drives that contain customer data should be locked away when not in use Raising the standards…
  • 47. The Solution – a 14 point plan 7 Backups • Full backups of all critical date should be standard practice: o Backup media should be locked away securely while not in use o Only authorised personnel should have access to backup media o Backup B k media should be h ld off site f di di h ld b held ff i for disaster recovery o If the media is held off site it should be transported and stored securely i.e. a lock box or safe y o Back up media needs to be encrypted Raising the standards…
  • 48. The Solution – a 14 point plan 8 Access control • Users should only have permission to access confidential information they need to do their job o You should review access permissions for every user at regular intervals o Each employee should have their own logon account o Employee access should be revoked as soon as they leave the company or are suspended d d o Locations where sensitive or confidential information is stored should be audited Raising the standards…
  • 49. The Solution – a 14 point plan 9 Data transfer • Any movement of data outside of your secure environment eg USB or CD, needs to follow these guidelines: o Encrypt all portable media using a suitable encryption technique o Use device control software to control and detect unauthorised access to external media such as CDs and USB devices o Keep a record of all of these devices and which personnel are allowed to use them and for which purpose 10 Asset management • You need to keep a record of all computers, laptops, USB devices, external hard drives that exist in your business • You need to maintain a record of all data copied onto media moving outside your secure environment and the reason for doing so Raising the standards…
  • 50. The Solution – a 14 point plan 11 Data destruction • Data removal and destruction is an important part of keeping your clients clients’ information secure o Paper records need to be shredded in house or by an approved agency that must be vetted o Hard drives should be disposed of securely ensuring all data is destroyed o Certificates h ld be bt i d from agencies confirming C tifi t should b obtained f i fi i destruction of data from hard drives and recycled computer systems Raising the standards…
  • 51. The Solution – a 14 point plan 12 Remote access • Remote access to your network needs to be secure • Remote access and VPN software needs to be configured properly for the highest possible security level • Home workers need to ensure that any wireless network is encrypted to the highest possible standards • Home workers need to prevent unauthorised access to their computer systems through password protection at l t t th h d t ti t least Raising the standards…
  • 52. The Solution – a 14 point plan 13 Staff recruitment • Where legally possible carry out every background check on staff who will be exposed to confidential information: o Credit references o CRB checks o CIFAS staff fraud database o References o CV validation o Assess regularly if staff in higher-risk positions may be susceptible to coercion Raising the standards…
  • 53. The Solution – a 14 point plan 14 Email and internet access • Implement monitoring controls for email and internet activity to identify potential data leakage • Filter access to content that allows web based communication such as webmail (Hotmail, Gmail, Yahoo, MSN instant messaging) social networking sites like Facebook and Myspace • Restrict or block access to file sharing site Raising the standards…
  • 54. The Solution – a 14 point plan 14 Email and internet access (continued) • Why? • More than 60% of companies have disciplined – and more than 30% have terminated – employees for inappropriate use of the internet in the workplace • 80% of companies reported that employees had abused internet privileges, such as downloading pornography or pirated software • 70% of all pornographic downloads occur between 9:00am and 5:00pm • 25% of employees admit to spending between 10 and 30 minutes per day surfing non-work related websites. 22% admit to spending between 30 minutes and 1 hour. 12% said they spent between 1 and 2 hours online and 13% admitted to spending more than 2 hours per day visiting non-work related websites • 46% of online shopping during the Christmas period occurs at work – is this your busiest time of the year? Raising the standards…
  • 55. Business Continuity and Risk Management Raising the standards…
  • 56. Business Continuity and Risk Management An Holistic Management Process. • Identifying areas of potential risk. • Evaluate the possible threats; • Choose appropriate strategies to reduce the likelihood and impact of incidents; • Choose appropriate strategies that provide for the continuity or recovery of the critical activities activities. Possible Risks Key Persons, Information Technology (IT), Data and Information, Financial Resources, Persons (IT) Information Resources Human Resources, Service, Money Laundering, Data Protection and Processing, Q Quality and Suitability of Advice, Accounts and Commissions, The Economy, Regulation, y y , , y, g , Complaints, Training and Competence Requirements, Location and Premises and Health and Safety.
  • 57. Business Continuity and Risk Management Write a Plan. • Team Lists and Alert Procedure. • Plan for Major Incidents – Fire, Flood or Attack. • Business Critical Systems. • Key Contacts and Business Partners. • Emergency Procedure – Meeting Place. Test and Communicate. Raising the standards…
  • 58. Continual Improvement Raising the standards…
  • 59. Continual Improvement • Two Areas of Continual Improvement. o Business o Personal • PDCA o Plan, o Do, o Check & o Act. • Client feedback – Positive and negative. Raising the standards…
  • 60. Continual Improvement Training and Competence • FSA current focus on outputs from firms to demonstrate effectiveness and to ensure customers are protected. • No formal requirement from FSA for a written T&C scheme but, • FSA d does require adequate procedures, records and effective d d d d ff management controls to be in place. • All of these achieved by T&C scheme. A good T&C scheme is central to ensuring that customers are treated fairly. • A Training Needs Analysis is essential to its success (plugs the GAP). Raising the standards…
  • 61. Continual Improvement What should be covered in a T&C scheme? • Scope - types of staff and activities of firm. Include non- authorised as well as authorised. th i d ll th i d • Achieving competence - stages of competence, training needs, regulatory exams. • Maintaining competence - keeping relevant knowledge, skills and understanding of the market up to date. • Supervision - additional knowledge and skills requirements, level of supervision, spans of control. • Record keeping - regulatory requirements, methods. Raising the standards…
  • 62. Continual Improvement Achieving and Maintaining Competence • What does competence look like? Job description, accountability profile and person specification. • Stages required in achieving competence and standards to be reached at each stage stage. • Use of KPIs in driving standards and further training needs. • Qualification requirements - FSSC list list. • Ongoing assessment - what and how, assessment type, failure p policy, core and specialist areas. y, p Records • Meet regulatory requirements and achieve g g y q good p practice. • Use technology. Record keeping should not become a burden!
  • 63. Continual Improvement Continual Professional Development (CPD) • Importance – Helps to maintain competence, Relevant and interesting, include regulatory changes i.e TCF. • CPD – Should be planned and include objectives and success criteria. criteria • Records – activity undertaken, time spent, objectives met or not!, further development needs, how the knowledge has been applied and what are the benefits!. • Signed off against objectives! Raising the standards…
  • 64. Continual Improvement Continual Professional Development (CPD) - Methods • Web Research & Online Tutorials and Webinars. • Exam Study & Books Books. • Newspapers/Broadsheets & Newsletters. • Current Affairs. • Professional/technical seminars, workshops and events – Internal. • Professional/technical seminars, workshops and events – External. • Technical product and provider presentation – Internal Technical, Internal. • Professional/business and personal development seminars, workshops and events. • Audio CDs. Must change when: • Environment Changes, O g i ti Ch g and th E i t Ch g Organisation Changes d there are individual performance issues. Raising the standards…
  • 65. How can firms maximise both internal and external learning? Internal: External: g • Formal training. • Formal training course course. • Work shadowing. • Exam preparation. • One to one coaching. • Distance learning. • Job rotation rotation. • Case studies. • Role play. • Conferences. • Accompanied call. • Mentoring. Raising the standards…
  • 66. Continual Improvement Maximise your learning by: • Teaching Others. • Writing Articles, White Papers and Books. • Get involved with the profession. • Get involved with local universities, schools and your community. Raising the standards…
  • 67. Continual Improvement – Client Feedback Internal and External Feedback • Client Feedback – Manual or Electronic. • Client Advisory Board. Key Considerations • Establish current feedback methods and process. • Review current success, outputs and response rates. • Identify any gaps in the system, define and agree your wish list. • Research market and available options. • Select chosen methods and tools. l h h d d l • Update or create operational procedures and supporting documents. • Record monitor measure and ACT! Record, monitor, Raising the standards…
  • 68. Documenting your Practice Management System Two Main Levels • Level 1 – Guidelines. • Level 2 – Processes. Raising the standards…
  • 69. Documenting your Practice Management System Key Steps • Identify who does what what. • What is your desired outcome? • How best should it be documented? • Who is currently responsible for the process? • What tools support the process? – Software systems systems. • Roll Out, Test and Amend. • Include in your Practice Management System System. Raising the standards…
  • 70. Documenting your Practice Management System • Meet contractual, statutory and regulatory guidelines. • Unique reference number, authorisation. • Clear and concise, simple and understandable, tested and amended, , p , , quality controlled and well communicated. • Quality at the core. Q y • Interrelated and interactive processes. • Create a library of templates, letters emails and forms templates letters, forms. Raising the standards…
  • 71. Documenting your Practice Management System Examples…. • Telephone and email enquiries enquiries. • First meeting confirmation and information. • Conducting a first meeting and follow up. • Information gathering. • Creating a financial plan. • I l Implementing th solutions and strategies. ti the l ti d t t i Raising the standards…
  • 72. Documenting your Practice Management System Creating A Process Improvement Culture • Have all key p y processes been identified and documented? • Are they effective in producing the desired results? • A th available i b th h d and soft copy f Are they il bl in both hard d ft formats?. t ? • Have they been effectively implemented? • Have they been logged and quality controlled? Raising the standards…
  • 73. How to prepare for an assessment • Review your gap analysis. • Identify your gaps gaps. • Set yourself an assessment deadline. • All Allocate “Gap Manager” and agree ti f t “G M ” d timeframes. • Brief the rest of the team. • Work through tasks, roll out to the team. • Engage with a SI Approved Associate Consultant (AAC). • Collate Evidence ready for the assessment. Raising the standards…
  • 75. Welcome Back ISO 22222 - Gap Analysis Raising the standards…
  • 76. What happens next? • Assessment Preparation. • Assessment. o Portfolio of Evidence: case studies, testimonials, client feedback. client files, business processes. • De-brief. o OBS, MiNC, MaNC • Assessor Sub ts Report. ssesso Submits epo t. • Independent Assessment – HQ. • If Happy - Confirmation of Certification Certification. • If not Happy – Rebook Assessment. • Certification Awarded – Guideline and Letter. Raising the standards…
  • 77. Any Questions..? Raising the standards…