Are you a key worker?
As well teaching years one and six, which have now gone back to school, teachers are being asked to continue to provide care for a limited number of children whose parents are critical to the Coronavirus response and cannot be safely cared for at home. This includes parents who are needed for the provision of essential financial services and are, therefore, considered key workers.
The FCA has explained that a number of different types of roles may be considered as providing essential services, which is individuals who are essential:
- in the overall management of the firm that are affected by the Senior Managers Regime
- in running of online services and processing
- in running of branches and providing essential customer services, such as those dealing with consumer queries (including via call centres), client money and client assets and those maintaining access to cash and other payment services
- in keeping payments processing and of cash distribution services functioning
- in facilitating corporate and retail lending and administrating the repayment of debt
- to the operation of payments processing
- in the processing of claims and renewal of insurance
- in the operation of trading venues and other critical elements of market infrastructure
- to risk management, compliance, audit, and other functions necessary to ensure the firm meets its customers’ needs and its obligations under the regulatory system
- in providing support to allow the functioning of the above roles, such as finance and IT staff.
The FCA confirmed that firms are best placed to decide which staff are essential for the provision of financial services, however it only expects a limited number of people to be identified as being key financial workers. A key financial worker fulfils a role which is necessary for the firm to continue to provide essential daily financial services to consumers, or to ensure the continued functioning of markets.
You may want to consider issuing a letter to all individuals it classifies as key workers, clearly identifying them as such, that they can present to schools on request. The FCA recommend that the letter includes the sentence, “the individual has been designated as a key worker in relation to their employment by [firm name]” and is signed by someone with appropriate authority.
If you have any compliance questions, please speak your dedicated BDM, who will be happy to assist.