ICOB 2.8 Record keeping

General record-keeping standards, which continue to apply, can be found in SYSC 3.2.20 R. ICOB 2.8 provides further details of the standard expected of firms where there is an obligation in ICOB requiring firms to maintain adequate records to evidence compliance. An overall view of the record-keeping requirements in ICOB is in ICOB Sch 1.

A record would be "readily accessible" if it was available for inspection within two business days of the request being received.

Where a firm keeps standard, generic documents as records it should be able to identify which version, by date or reference number, was provided to the customer.

1. (1)

   A firm may arrange for records to be kept in such form as it chooses provided the record is readily accessible for inspection by the FSA.

2. (2)

   Where a firm chooses to maintain records in electronic form, it should take reasonable steps to ensure that:

   1. (a)

      the electronic record accurately records the original information; and

   2. (b)

      the electronic record cannot be subject to unauthorised or accidental alteration.

Each rule in ICOB that requires a record to be made and retained specifies that the record must be kept for a minimum period of three years. A firm should consider retaining records for longer periods in case customers complain or take legal action against the firm. A firm should, in particular, consider what constitutes an appropriate retention period for records which relate to non-investment insurance contracts which may give rise to claims some time after the inception of the contract (e.g. employers' liability insurance).