Mobile Communications Recording for UK FSA Compliance

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Overview The UK Financial Services and Markets Act 2000, has been amended to include the recording of mobile communications made by advisors to their clients from mobile devices issued for business purposes from 14th November 2011. It is imperative that Financial Services Institutions comply with the regulation by this date whilst maintaining an unimpeded service for their clients. Recorded mobile communications must be held in an environment which ensures controlled access to the system with visibility to an audit trail. The recorded data must be stored for at least six months.

Enabling You to be FSA Compliant Together with Natterbox, Fujitsu can help Financial Institutions achieve regulatory compliance with the new FSA mobile communications recording rules. Natterbox’s market leading and innovative product is backed by Fujitsu’s global telecom expertise and helpdesk services to provide a resilient mobile communications recording and retention management solution. Today, Fujitsu already provides MVNE (Mobile Virtual Network Enabler) services for a major mobile network operator, in turn offering MVNO (Mobile Virtual Network Operator) services to

300,000 users through two well-recognised high street brands.Fujitsu is proud to work with Natterbox to bring market leading innovation to our customers. Fujitsu and Natterbox together bring mobile communications recording and retention management to Financial Institutions, supported by Fujitsu’s international network of helpdesks and world class business continuity services. Our people, our unique technology and our commitment to establishing long term relationships align directly with our customers business objectives. The Solution – Will it be Ready in Time?Fujitsu understands the importance of the timeliness of the service introduction. We have carried out detailed due diligence on the Natterbox technology and our own ability to deliver all the elements of the service required to be operational by 14th November 2011. We are confident that we can support Financial Institutions in meeting the necessary timescales, subject to contract. Our solution can be fully implemented in six weeks, assuming we have the necessary contract and data points in place. The different stages of deployment are outlined in the diagram below.

■ Current provider details

■ User details, type, phone number – sufficient for PAC

■ Device unlock status

■ Device make, model, IMEI – required for unlock

■ Delivery location – Office is default

■ Service configuration requirements

Initiation

■ Obtain PAC codes

■ Obtain Unlock codes

■ Configure service

■ Service design signoff

Setup / preparation

■ Apply PAC

■ Email instructions

■ SIM delivery

■ Online registration

Deployment

■ Onsite with users

■ Users will ignore instruction

■ VIP users

■ Phone unlocking

■ New phone setup

Provisioning

Weeks 1 & 2 Week 3 Week 4 Weeks 5 & 6

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Are You Doing this for the First Time? We have experience in setting up and running similar services and also the logistics involved in the deployment and migration of mobile services for large numbers of users, including within our own organisation. Based on our experience, we are confident the timescales required are possible, providing we achieve focus on some of the key activities that will determine the critical path. Examples of this would be working jointly together to capture all the logistical data of end users’ devices and mobile phone numbers to ensure seamless device unlocking and number porting. We have recently carried out a mobile migration programme for over 11,000 users and 17,000 devices in the UK. We are confident that we can meet FSA timescales with minimal disruption to clients. Inevitably, there may be future changes in legislation and other legal requirements that will need to be met. This means the choice of solution should have a degree of flexibility in order to accommodate these requirements. Confidence in our Solution Ease of Implementation, Full Compliance and Scalable Growth As a world leading systems integrator evaluating solutions for implementing FSA’s regulation for Financial Institutions, Fujitsu performed due diligence on two technology strategies for achieving compliance:

■ Software installed on the user’s mobile device

■ Network and cloud computing based solution, on-net or via MVNO

We concluded that a network based solution, either on-net or via MVNO, was the most robust solution to achieve FSA compliance for mobile communications recording and accordingly we decided to bring to market an MVNO-based solution. With such a solution, the disruption to your advisors would be limited to a SIM card swap for their mobile devices. The advantages are many, with an array of value added services available via a fully managed, pay by use network service. The speed of deployment, provisioning, flexibility, agility and scalable growth path delivered by a network-based solution represent compelling benefits for your organisation.

Fujitsu and Natterbox in Partnership Fujitsu chose Natterbox as our exclusive technology partner for mobile communications recording due to their:

■ Current and core technology

■ History with compliance solutions for email, particularly around secure storage, retention policy management, access management and audit

■ History of working with Fujitsu over the last decade

■ Supply chain through the maturity of Natterbox’s MVNO and relationship with the mobile network operator

■ Complete coverage of devices, with necessary licences in place where required e.g. RIM licence for Blackberry

■ Roadmap for product innovation and growth

The Fujitsu partnership complements Natterbox’s technology and innovation with our renowned service delivery capability, global coverage, highly secure Data Centres and networks.

Our longstanding telecoms history and supplier relationships that are both broad and deep, allow us to drive costs down and provide a world class service to our joint, end customers.

1171_natterbox_diagram2

MobileOperator

Caller Mobile User

Secure Online WebAccess And Control

Policy Engine

Optional CRM Integration

Secure,Redundant

Storage

Cloud(Off PremisesRecording)

Onsite Recording

On PremisesRecording

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Copyright © Fujitsu Services Ltd 2011. All rights reserved. No part of this document may be reproduced, stored or transmitted in any form without prior written permission of Fujitsu Services Ltd. Fujitsu Services Ltd endeavours to ensure that the information in this document is correct and fairly stated, but does not accept liability for any errors or omissions. 1171/08.11/IDEAS BRA01

Contact: Stuart Finnes Fujitsu Services, 22 Baker Street, London, W1U 3BW Tel: +44 (0) 7867 829 623 Email: Stuart.finnes@uk.fujitsu.com Web: uk.fujitsu.com