In October 2009, the next stage of the Companies Act introduces several changes which will change the way we look at data. Although all of the changes can be argued as a point of interest the one which will make the most impact will be the changes to the Director’s residential address.
As an independent consultant I was tasked by a leading accountancy firm to find a cost effective solution to combat the act’s changes. This solution had to sit alongside their existing data, could not have a major impact upon their workload nor change their current terms and conditions of trade. After carefully researching the market it became apparent that there were several possible solutions however other than the cost the other main difference was that some will leave a footprint on an individual’s credit file and some will not. Choosing the right solution in this case could not have been more vital bearing in mind that leaving a footprint and requiring a consumer license would have a major impact on this business.
But rather than just explain the solutions l have quickly summarised the changes to the Act so you could see whether it will impact your business too.
A vital change introduced in October is in the service addresses area. From then, only the service addresses of UK directors will be held on the public record as general information; the residential address will be protected information, available only to regulatory authorities such as the police and HMRC.
Data from Companies House, the main information source of data for all major credit information agencies will therefore become a great deal more limited. Information providers say they will only be able to display what is on the public record at UK Companies House.
Information professionals must now take the required steps to comply with the Companies Act and find alternative methods. Becoming educated about the various technologies and options in this area is vital. Information professionals should also acquire the necessary internal support and budget to underpin compliance and bridge the gap between where the organisation is and where it needs to get. Experts warn that companies will need to make absolutely sure they understand the registrar’s expectations and requirements about how information must be submitted.
Your choices are simple, to find the address of a director who has opted out you can ask your client’s permission to run a consumer credit check. However, bear in mind you may need to re-write your current terms and conditions to enable this consumer search. Also remember you may also need to apply for a Consumer Credit Licence and there is the risk of compromising your relationship with this client.
The second choice is to invest in a solution which does not leave a footprint, is designed for AML and KYC purposes, is accessed easily on-line and can be run alongside your current data solutions. Although limited to only a few providers and bearing in the mind the costs of these can vary considerably the good news is that now my task is complete I am now able to share my findings on these services with you too.
If you are ready for the impact of the Act and you have done your research and invested wisely then this may not be of interest to you. However, if you are still unsure that you are ready or want to see the data options please feel free to contact me to discuss this further.
Contributed by Simon Howard, Director, Intelligent Commercial Data Solutions Ltd
email: simon@icds.org.uk
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