Firms need to ensure that their systems and controls identify breaches. Alongside the MI and monitoring it is important that firms have an open and transparent culture so that breaches are disclosed and dealt with promptly.
Recording breaches may help the firm identify trends, training needs or foreseeable harm.
For clarity a breach is where an action or inaction is in contravention of the firm’s own processes or a regulatory or legal requirement.
The first step is ensuring all employees understand what constitutes a breach and the . . .
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