Effective 28 March 2020

  • Under current protocols, advisers are responsible for undertaking their own due diligence on contracted paraplanners, and they may reserve the right to request confirmation or evidence of the below statements. As a paraplanner we therefore ask that you kindly read, and upon registration, confirm you understand the below preferred processes.
  • The below should be read in conjunction with our terms & conditions, this list should not be considered exhaustive:

Company Information

  • Confirm you can provide access to records of your company details. These include, but are not limited to: Company trading name (and/or previous trading name(s)), company directors, company address, company tax registration numbers (i.e. VAT) and company contact details.
  • Confirm that your company as not entered into any involuntary or voluntary state of receivership in the last five years.
  • Confirm that no director in your company has been involved in any firm which has been liquidated on gone into receivership within the last three years.

Information Security, Data Security & Governance

  • Confirm your company has an appointed individual who has ultimate responsibility for Data Protection & Information Security
  • Evidence your Data Protection / Privacy / Information Security policy
  • Confirm your company is registered with the relevant Data Protection Authority.
  • Confirm your company is not subject to any enforcement actions or ongoing investigations by the Data Protection Authority
  • Evidence the controls / verification / audit trails you have in place regarding the amendment of client data
  • Evidence how you restrict unauthorised access to client and service data
  • Confirm you operate on a suitably encrypted platform throughout the provision of your services
  • Confirm access to where data is stored is physically restricted
  • Confirm you are able to delete/ destroy client records at a clients request
  • Evidence your policy for protecting back ups
  • Evidence your Anti-Virus policy and confirm you have taken appropriate measures to protect your systems at all times.
  • Provide on request a list of all staff with access, and detailing the extent of that access to client records and service data.
  • Confirm you adhere to all relevant data sharing protocols and legislation

Risk & Regulatory

  • Confirm your company has no outstanding legal action against it.
  • Confirm your company has not had to pay a financial penalties in respect of failure to perform or suffered a deduction for liquidated and ascertained damages in respect of any contract held.
  • Confirm your company has not had a contract terminated prematurely for failure to perform to the terms of an agreed contract.
  • Confirm your company complies with and will comply with all regulations or legislative requirements relevant to the provision of paraplanning services.
  • Confirm your company retains appropriate indemnity insurance for the services you provide.
  • Confirm if your company, or the services you provide, have ever been subject to a review or audit by the FCA
  • Evidence your policies and processes to ensure a client can retrieve all data in the event that a contract is cancelled or your business ceases trading.

Financial Crime

  • Evidence your policies and procedures in place for prevention and detection of fraud and financial crime.
  • Confirm who within your company is responsible for financial crime and fraud prevention
  • Be able to describe any data security arrangements you currently follow to mitigate the risk of financial crime and fraud
  • Confirm there have been no major financial crime incidents/failings in the previous eighteen months.
  • Confirm you understand comply with all of your obligations under the UK Criminal Finance Act 2017
  • Confirm you understand and comply with the UK Anti-Bribery 2010 Act and any Anti-Bribery legislation relevant to your business
  • Confirm whether yourself, any of your employees, ultimate beneficial owners, or controllers, would be considered Politically Exposed Persons.
  • Confirm that you would provide appropriate warning and share details of any known or perceived and/or potential conflict of interest between you/your firm and one of your clients.
  • Evidence the systems and controls you have in place in relation to AML & Sanctions
  • Confirm your policy and procedures for dealing with Sanctions list screening
  • Confirm your process for Suspicious Activity Reporting
  • Evidence your employee/contractor/supplier vetting process in relation to Sanctions checking
  • Confirm you do not outsource and/or offshore any of your processes in relation to the services being provided.

Business Continuity, Responsibility, Fitness & Propriety

  • Evidence you have an effective IT continuity plan and that all critical service data is backed up and readily available.
  • Confirm which individual in your company has ultimate responsibility for the provision or your services, evidence the skills and experience to warrant this responsibility.
  • Evidence your approach to recruitment
  • Evidence your approach to continued professional development
  • Evidence how you background check staff which may be involved in the provision of your services
  • Evidence you pay the legal minimum remuneration, minimum wage.