Evolution or revolution? The experts’ view on GDPR (part 1)

The General Data Protection Regulation (GDPR) will come into force on 25 May, with the aim of prompting a paradigm shift in the way we think about data, and how it is attained, managed, processed and erased. There’s no doubt that this much-needed new governance will pose major challenges for wealth and investment managers, but will this be a complete revolution for firms, or a mere evolution of the processes they have in place?

Wealth Dynamix joined forces with EY to host a seminar with GDPR experts from PIMFA (The Personal Investment Management & Financial Advice Association), the IRTA (International RegTech Association) and a number of client-facing organisations. The panel looked at the complexities GDPR will pose for an industry that has been built on client insight and understanding.

Roopalee Dave, Director, Wealth and Asset Management at EY, noted that since MiFID II went live on 3 January 2018, GDPR has consumed much of the industry’s attention – and presented multiple obstacles and issues from an operational and governance perspective. But with businesses navigating multiple competing challenges, from squeezed margins through to Brexit, many firms are taking a tactical vs strategic approach to adapt to the requirements of this new regulation.

With just over a month until GDPR comes into force, several questions continue to cause concern, which, PIMFA explained, even the regulator is still unclear about the best approach firms should take. Yet as the Information Commissioner’s Office (ICO) assumes investigative powers and the ability to impose sanctions on businesses that do not comply with this impending regulation, the pressure is on for firms to act in the best interests of their clients, regardless of the ambiguities that they face.

Delegates were resolute in the need for this new regulation to catch up with the immense technological advances that took place over the 20 years following the Data Protection Act. As Johnny Beloe, Senior Product Consultant at Wealth Dynamix said, “GDPR isn’t the end game – it’s a much needed response to the complexities of the present data environment; an environment which will further increase in complexity as technology continues to evolve, presenting a host of further challenges that will no doubt require further regulatory response.”

So, with a matter of months until businesses need to be GDPR ready, how are service providers adapting to the requirements of this new regulation? The panel agreed that there has been something of a change in mind-set as financial services firms consider their use of client data – but this is not without its difficulties.

Unlike its predecessors, GDPR requires data to be regulated at the outset. In an industry that is driven by client insight, the exchange of personal data is a natural part of the prospecting process. While at this juncture the individuals in question are not yet clients, the relevance of specific information increases as advice is given in the context of this information.

The panel was largely in agreement that health information poses significant complexities for financial services providers. Giulia Lupato, Senior Policy Advisor at PIMFA said, “The level of insight required for financial planning is very different to that needed for insurance purposes. Whether firms are dealing with comprehensive wealth management or tax planning, the health of the customer does come into play. They need to understand how to manage this.”

So, how can they manage this, when the industry waits to see what GDPR means in practice? PIMFA suggested that, for the time being, and lacking alternative lawful grounds, the only option available to firms processing their customers’ health data appears to be explicit consent – it is unclear whether alternative grounds, such as “substantial public interest”, are allowed. A connected issue is whether the need for explicit consent can be bypassed where a vulnerable customer is involved, by leveraging necessity to protect the vital interests of the customer. This interpretation hangs on whether a person’s financial stability can be considered a “vital interest”. Both the ICO and the FCA have acknowledged that processing of health data is an integral part of a firm’s performance of their duty to act in the best interest of the client and that therefore the issue of what is the appropriate grounds to process it needs to be cleared and ambiguities removed.

The panel discussed the challenges for wealth and investment management firms that typically hold insight not only on individuals but their connected parties, from spouses to children – with additional complexities posed by trusts. Vulnerable clients were a prevalent theme throughout the discussions, specifically the capacity of a power of attorney and the potential to challenge explicit consent due to the data subject’s ill health. When asked whether it would be possible to seek the attorney’s consent in place of that of the individual in question, PIMFA advised that they are seeking clarifications on this point and on the possibility to apply the lawful grounds of protecting a client’s vital interests in these circumstances. While the regulators iron out the questions arising from these complex nuances, the panel underlined the importance of contracts in determining the use of data for the long term.

Roopalee noted that there are differences in clients’ individual requirements and ways in which the industry should respond to these. “Wealth management as an industry, whether investment management or financial planning, the affluent or ultra-high net worth segment, is all about understanding the client and their needs – and this involves a lot of personal client data,” she said.

The panel discussed the breadth of data firms have at their disposal and the importance of considering whether this is fundamental to their ability to provide a wealth management service for clients. In some cases, you’d find out the names, date of birth and details about family members, which are all part of the wealth management experience. GDPR will prompt firms to take stock and determine exactly what they need for their core business services. If firms don’t need this information, then they should not be collecting it.

IRTA’s Head of Strategic Initiatives, Richard Maton, looked at the implications of opt-in functionality for marketing purposes – specifically as these will have typically been selected by one individual, while products and services may cater for multiple family members. The panel also discussed the potential to review pre-existing marketing processes to determine whether they gain opt-in consent now and the consequences around those clients who opt-out.

The panel agreed that while the FCA and the ICO tussle with the finer details of GDPR, compliance is not enough. Johnny said, “Businesses need to think about how they can demonstrate that they’re being compliant. They need to be able to show the regulator what data they hold and why they hold it, in an easy and immediate way. This requires a shift in processes as well as mindset.”

The industry is following suit, as Ian Cornwall, Director of Regulation at PIMFA said: “PIMFA is working hard to encourage the link between compliance and IT teams who hold day-to-day responsibility for automated processes.”

The wealth and investment management industries centre on long-standing relationships and insight that often goes far beyond the client in question. Firms will face multiple challenges and potentially unforeseen scenarios as this new regulation play out in practice.

Our second report on the Wealth Dynamix GDPR roundtable will look at the experts’ view on the breadth of GPDR and the best ways to impart this regulation within organisations.

Please click here to download our GDPR brochure.

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Wealth Dynamix delivers Client Lifecycle Management solutions to the world’s leading private banks and wealth and asset management firms.

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Gabriel Chan

Head of Sales – APAC

An accomplished, results-driven sales and marketing professional, Gabriel has held sales and marketing leadership positions in Singapore and China at some of the world’s most successful and respected global technology enterprises.

During more than 20 years spent at IBM, Sun Microsystems and Microsoft, Gabriel developed and implemented sales and channel strategies to support strategic business objectives.

His specialism is growing and extending sales territories to grow revenues and increase market share.

Travis Morgans

Head of Consultants

Travis combines 15 years of software delivery, business modelling and leadership experience with a passion for transforming business needs into effective digital solutions. Before joining Wealth Dynamix in March 2018, Travis led Operations for Nikon – a role which incorporated CRM product ownership responsibility and initiated over 10 years of MS Dynamics experience, from 2011 to Dynamics 365​.

 Since joining the Wealth Dynamix team, Travis has been instrumental in designing and delivering some of our most strategic WDX1 projects. Leading the consulting team for WDX1, he is responsible for their recruitment and development. The team’s complex remit supports a fundamental aim – to ensure Wealth Dynamix delivers the best client experience. ​Travis is also responsible for ensuring the WDX1 product is designed and evolved in the most adaptable way possible to drive adoption across our client base, existing and future.  

Joanne Donoghue

Chief Marketing Officer

An experienced, tenacious marketer, Jo joined the Wealth Dynamix team in 2021 as Head of Marketing and quickly rose to the position of Chief Marketing Officer. A Brand and Marketing specialist with a proven track record in BRB and B2C communications, Jo combines a customer-centred approach with strategic thinking.

Having held senior Marketing positions in numerous FTSE 100 businesses, including Asda Stores Ltd, The Co-operative Retail Group, plus financial services brands MBNA, OneFamily, TransUnion, The Co-operative Group, she possesses a wealth of experience in the fields of finance and technology.

Jo is passionate about activating the Wealth Dynamix brand across every channel, taking a holistic marketing approach to drive consistency, salience and thought-leadership activity.

About – Agustin Collazo

Head of Strategic Client Relationships

Agustin joined Wealth Dynamix over six years ago bringing a wealth of experience in change management.

Having experienced first-hand the challenges of managing clients through change, Agu now brings that expertise to Wealth Management firms looking to leverage technology in order to help them connect more effectively with their clients.

Agu has a deep technical knowledge of our solutions that allows him to deliver our products effectively, unlocking the full potential of every feature.

As our Head of Strategic Client Relationships, Agu’s specialist expertise supports firms to become more efficient, transparent and dependable using our CLM solutions.

Juan Stoppa

Head of Development

Juan has over 20 years’ experience developing and implementing CRM solutions and has spent the last 10 focusing primarily on the Client Lifecycle Management (CLM) in the Wealth Management industry.

Currently Head of Development, Juan is responsible on overseeing the technical direction of the product.

Before joining Wealth Dynamix, Juan has worked for Barclays, Fujitsu and Ciber delivering large scale CRM projects in the financial services industry.

Juan has a first degree in Telecommunication Engineering from Universidad Blas Pascal and a MSc in Business Information Technology from London South Bank University.

Ben Altmira

Director of Operations & Change

An internationally experienced change management professional, Ben is responsible for overseeing projects both internally, and for clients.

In a career spanning more than 20 years in global banking, finance and management consulting, Ben has led strategy formulation, project planning, change management adoption, business networking consultation and transformational change projects at Fortis Investments, Barclays Wealth and Investment Management and Verisure Securitas Direct. Since beginning his career at Deloitte, Ben has also amassed a wealth of experience working on complex CRM system implementations, and is a PROSCI-certified Change Practitioner and a Certified Scrum Master (Scrum Alliance).

David Backx

Director of Pre-sales and Implementations

When David joined Wealth Dynamix in 2015 he brought with him a vast amount of experience delivering large-scale Microsoft Dynamics CRM projects. As a Senior Business Analyst at Royal Bank of Scotland David managed deployments with more than 2000 users, for both Business and Commercial Banking, as well as working on key AML initiatives for RBS International. In his current role at Wealth Dynamix David supports the growth and strategic direction of client implementations in Europe. Wealth Dynamix leverages David’s product expertise to shape the product roadmap and ensure that the firm delivers solutions with the right capabilities, that will be enthusiastically adopted, by all customers.

Prior to his involvement in the wealth management sector, David worked as a waste management contracts manager, working with Multi Services Kent to ensure effective waste clearance and re-use at the 2012 London Olympics.

Cedric Neuville

Director of Pre-sales and Consulting Europe

Since joining Wealth Dynamix in 2019, Cédric has worked closely with clients to ensure that the WDX and CLMi solutions are deployed efficiently and effectively.

In a career spanning more than 25 years, Cédric has become an accomplished business and global project management leader covering both technology and financial markets sectors. Having held various roles in private banking (front, middle and back office) and brokerages, in both functional and technical roles, Cédric has led many projects including client onboarding implementations and KYC reviews, regulatory compliance projects (including PSD2, MIFID2/PRIIPS, GDPR, CRS, Rubik) and digital transformation projects (online and mobile design and implementation).

Cédric has vast experience building and managing international project teams, having created three offshore teams in Tunisia and India, managed a 70-employee company as Deputy CEO and a startup Fintech founded to create smartphone apps.

Johnny Beloe

Director of Pre-Sales

As Director of Pre-Sales, Johnny is responsible for maintaining the firm’s pre-sales policies, methodologies and resourcing. He is also leads some of WDX’s largest pre-sales analysis exercises, conducted for a wider variety of financial services firms spanning multiple jurisdictions.

Continual engagement with existing and prospective clients helps to inform the WDX1 product strategy, roadmap and pricing.

Johnny has spent his whole career in financial technology in various consultancy and
pre-sales roles. His expertise covers the full stack of systems required by leading Private Banks and Wealth Managers, encompassing core banking solutions, portfolio management solutions, Client Lifecycle Management (CLM) solutions and more.

William Rouse

Commercial Director UK MEA

William’s commercial expertise in connecting technology to solve wealth management business challenges was borne out of his early career as a stockbroker, followed by a variety of Client Relationship Management and Sales roles in asset management and banking.

Having experienced first-hand the challenges of doing the job, William recognises that an unwavering focus on client service is required to build progressive and mutually beneficial partnerships in FOR the longer term. Having gained further experience working for financial technology service providers including Calastone and Contemi, he has the specialist expertise needed to identify how to leverage technology to help wealth managers connect more effectively with their clients, and become more efficient, transparent and dependable.

In addition to his role as Commercial Director at Wealth Dynamix, responsible for new business development in the UK, US and Middle East, William sits on the board of the Securities Investment Management Association (SIMA) where he is actively involved in exploring industry trends and challenges.

Dominic Snell

Chief Product Officer

An experienced and accomplished specialist in CRM technology and wealth management, Dominic is responsible for defining and leading the product roadmap for Client Lifecycle Management (CLM) solutions at Wealth Dynamix. Experienced in SaaS strategy definition, Dominic formulated the development and launch plan for the firm’s cloud-based CLMi solution.

Prior to joining Wealth Dynamix in 2014, Dominic held senior positions in both RBS and Barclays Wealth and Investment Management, where he was responsible for leading enterprise-scale CRM implementation projects.

With more than 15 years wealth management and WealthTech experience he has vast expertise and insights into best practice CRM and CLM execution.

Francois De Lescure

Chief Revenue Officer

François joined Wealth Dynamix in 2020 to grow the company’s presence in France and further extend business operations across Europe and has since been designated Chief Revenue Officer, a member of the board. 

Having closed several flagship deals for the company across Europe and Switzerland, today his role encompasses responsibility for new and existing revenues, recruiting, structuring and managing the sales team, plus owning the business forecast and reseller channels.

Previously, François served as Chief Sales and Marketing Officer, Executive Committee member and investor at DreamQuark, an Artificial Intelligence software startup. At DreamQuark, he secured the firm’s first recurring revenues with Tier-1 banks and insurance companies, won the Fintech of the Year award and enabled A and B level fundraising. Before that François spent almost 10 years at Nokia Networks, leading European Sales for Analytics Software.

François has an MBA awarded by INSEAD and an engineering degree from the École Centrale de Nantes.

Natalie Levine

Chief Operating Officer

Currently Chief Operating Officer and Board Member at Wealth Dynamix, Natalie is responsible for the strategic direction of operations across the business. A wealth and investment management industry expert, with more than 25 years experience delivering large-scale technology projects, Natalie plays a pivotal role in ensuring the efficient running of the firm and meeting key business goals.

Prior to joining Wealth Dynamix in 2019, Natalie was Head of Technology at Bridgepoint Advisers, a UK-based private equity investment firm. She joined Bridgepoint following an 18-year tenure at Quilter Cheviot, where she was Head of Technology responsible for Operations and execution of the firm’s business plan.

Brent Randall

Co-founder and CFO

A wealth and investment management industry expert, Brent has more than 25 years of experience in developing front to back software solutions that address sector-specific operational and compliance challenges.

Prior to co-founding Wealth Dynamix in 2012, he was a Director at Third Financial Software, where he drove product development.

Previously, he led business development and product strategy for the wealth management division of Financial Objects.

Brent spent 13 years at DST (now SS&C) until 2007, where he was Associate Director responsible for the global product strategy of institutional front office and wealth management solutions.

He graduated from Downing College, Cambridge, with an honours degree in Geography.

Gary Linieres

Co-founder and CEO

With a lifetime career in wealth management, beginning in front office sales more than 25 years ago, Gary is recognised as a highly successful, award-winning executive and serial entrepreneur.

Currently CEO at Wealth Dynamix, one of Europe’s fastest growing WealthTech firms which he founded in 2012, Gary has pioneered a new approach to Client Lifecycle Management (CLM) and built solutions suited to both enterprise-scale and mid-size financial institutions.

In his early career Gary excelled in a wide variety of FinTech sales management and executive roles in the UK, Switzerland and France.

Following his tenure as Managing Director at Financial Objects, which saw revenues grow by more than 300% on his watch, Gary founded and subsequently exited from Third Financial Software after it became a leading front office technology provider.

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