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FCA Update July 2018 Guidance for firms outsourcing to the ‘cloud’ and other third party IT services

The FCA finalised guidance is relevant to firms who are interested in outsourcing to the cloud and other third party IT services. They have updated the draft guidance in the following areas:

  • physical access to business premises, including data centres

  • the scope of firms’ obligations relating to supply chain and sub-contracting arrangements

  • clarifying expectations around aspects of risk management, including concentration risk

  • points around the choice and control in relation to the jurisdictions where data is processed, stored and managed

  • the provisions to ensure firms have effective access to data

  • specific expectations around exit plans.

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