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Digitising Historical Records for Compliance with the FCA’s Consumer Duty


In today’s digital age, the Financial Conduct Authority (FCA) has introduced new conduct rules known as the Consumer Duty. This regulatory framework aims to prioritise the interests of consumers and ensure fair treatment across the financial services industry. As organisations navigate these evolving compliance requirements, digitising historical records of client information has emerged as a valuable strategy. In this article, we will explore how digitisation can help organisations comply with the FCA’s Consumer Duty and the benefits it offers.

I. Digitising Historical Records for Compliance

Digitising historical records of client information can significantly aid organisations in meeting their compliance obligations under the FCA’s Consumer Duty. Here are some key advantages of digitisation:

Enhanced Data Accessibility

Digitised records allow for quick and easy access to client information, enabling organisations to efficiently address client queries, requests, and complaints. This improves response times, strengthens client relationships, and demonstrates a commitment to customer-centricity.

Robust Data Security

Digital storage solutions provide enhanced security measures, including encryption and access controls. This helps protect sensitive client information, ensuring compliance with data protection regulations and reducing the risk of data breaches.

Efficient Record Management

Digital records eliminate the need for physical storage, reducing administrative burdens and costs associated with paper-based systems. Advanced search functionalities and data analytics tools enable organisations to retrieve and analyse information rapidly, aiding decision-making processes.

Improved Compliance Monitoring

Digitisation allows for the implementation of automated compliance monitoring systems. These systems can flag potential regulatory breaches, monitor client interactions, and help identify areas where additional training or process improvements may be required.

II. Understanding the FCA Consumer Duty

The FCA Consumer Duty is a set of conduct rules that places a greater emphasis on consumer outcomes. It aims to enhance transparency, fairness, and accountability within the financial services sector. By complying with these rules, organisations can strengthen their relationships with clients and improve the overall customer experience.

III. Responsibility for Compliance

Within a firm, the responsibility for compliance with the Consumer Duty falls on several stakeholders. Senior management is ultimately accountable for ensuring the firm’s compliance with regulatory obligations. Compliance teams play a crucial role in interpreting and implementing the rules, while frontline staff members are responsible for delivering fair treatment to clients in their day-to-day interactions.

IV. Elements of the FCA Consumer Duty

The FCA Consumer Duty comprises three key elements that organisations need to address:

Duty of Care

Organisations are expected to act in the best interests of their clients, taking reasonable steps to avoid foreseeable harm. This includes providing clear and accurate information, suitable products and services, and effective complaint handling procedures.

Duty to Exercise Skill, Care, and Diligence

Organisations must demonstrate a high level of professionalism, expertise, and diligence in their dealings with clients. This involves ensuring staff members have the necessary skills and knowledge to deliver quality advice and services.

Duty of Communications

Organisations should communicate with clients in a way that is clear, fair, and not misleading. It includes providing information that is easy to understand, avoiding jargon, and being transparent about costs, risks, and potential outcomes.


Complying with the FCA’s Consumer Duty is paramount for organisations in the financial services industry. By embracing digitisation and transitioning from traditional paper-based records to digital formats, organisations can achieve greater efficiency, transparency, and accountability. Digitised historical records provide organisations with the tools they need to deliver on their responsibilities and build strong client relationships. Embracing technology and leveraging digital solutions is a proactive approach to meeting compliance obligations and embracing a customer-centric ethos in the digital era.