connected A Tenet Group Publication Issue 67 Spring 2018

SPECIAL FEATURES General Data Protection Regulation (GDPR) – What do I need to know? Nice to tweet you! New social media policy and service

OTHER FEATURES Up Close and Personal with Simon Broadley, Adviser Propositions Director. Tenet Paraplanning – a potential extension to your business! Smart-Beta: An active approach to passive investing?

TENET COMMUNITY Just Take TWO! TenetConnect member and principal of ADS Financial Planning, Alan Sensicall, recently celebrated two milestones in the same month.

Our continuing journey through the regulatory landscape…

The Latest Provider Support Offering insight into market conditions and adviser opportunities

Welcome - 3

CONTENTS… what’s in this issue

Editor’s Foreword

4 Our continuing journey through the regulatory landscape…

Steve Jones, Adviser Relationship Director, takes us on a walk through the regulatory news and the latest about our new social media policy and extensive marketing support. approach to passive investing? The Active vs Passive debate is a long standing one within the investment industry. Both approaches have attributes that make them desirable in different areas and market conditions. – Round One – starting April 2018, Masterclass One – starting May 2018, Cycle Two Professional Development Meetings – starting May 2018 and CPD Webinars. Book your places today! 10 Up Close and Personal with… Simon Broadley, Adviser Propositions Director. 12 General Data Protection Regulation (GDPR) – What do I need to know? The GDPR will introduce new concepts and rights for the data subjects, some of which will have a significant impact on how you handle and use personal data. 6 Smart-Beta: An active 8 Have you planned your calendar of events for 2018? Coming soon - Non-Investment Roadshows

Hello and a warm welcome to the Spring issue of Connected .


Our regular readers will notice a change in this issue, as Steve Jones, Adviser Relationship Director takes over the mantle for the industry update fromHelen Ball. In this edition he takes us on a walk through the latest regulatory news and highlights our new social media policy that enables firms to post financial promotions using the extensive marketing support now available. Take a look at both his article on pages 4 & 5 and also the dedicated article on the new social media materials on page 18. Connected is a ‘lively’ magazine this time around, as we have news and articles from a number of Tenet business areas. I have highlighted a few below but as you read your way through the magazine, I am sure you will find a number of areas of interest. Also in this issue General Data Protection Regulation (GDPR) is looming and like me you may have already started to receive communications from companies holding your data referring to this new regulation. But as a business what do you need to know? GDPR will introduce several new concepts and data subject rights, so our article on page 12 provides a detailed overview of what you need to know and do. Under the spotlight in this issue is our new Adviser Propositions Director, Simon Broadley. Simon has also taken up the role of Managing Director of TenetLime. Having joined Tenet in early January, we speak to Simon in his first few months about his plans going forwards and also ask a few personal questions, so you can get to know him a bit better. Paraplanning at Tenet has grown rapidly over the last few years in response to demand from our members. As more and more advisers start to use the service, in this issue of Connected , we answer some of the frequently asked questions we get from new users…but don’t just take our word for it – read what Alan Johnston of City Gate Aberdeen Ltd has to say about the service. Finally, do you have an adviser friend, business contact or ex-colleague who is looking for their next career move or may like to join the Tenet network? Recommend advisers to Tenet and you could be in the £££. See pages 20 & 21 for more on this. I hope you find Connected an interesting and useful read, and if you want me to include anything else in future issues, don’t hesitate to get in touch – email Best wishes Sara J Healey Marketing Consultant



14 The Tenet Platform The Future is Bright 18 Nice to tweet you!

New social media policy and service 20 Recommend advisers to Tenet and win, win, win… And our winner of the first prize draw!


22 Tenet Paraplanning

– a potential extension to your business!

23 BREAKING NEWS! - New Training &

Development Support The Tenet Training Team has created new Protection Training material to support opportunities within the Protection market.


PROVIDER SUPPORT 24 – 40 Latest News and Products


Editor Sara Healey

Published quarterly by Tenet Group Limited 5 Lister Hill, Horsforth, Leeds, LS18 5AZ

Connected Magazine is for internal purposes only and is not intended as an advertisement. As a result this should not be issued in any form to clients. Not all the products in this feature are the responsibility of the Tenet Group Limited. Terms and Conditions. Although every effort has been made to ensure the accuracy of the information contained in this publication, The Tenet Group cannot accept responsibility for any errors it may contain. The Tenet Group cannot be held responsible for the loss or damage of any material, solicited or unsolicited. No reproduction of any part of this publication, in any form or by any means, without prior written consent from The Tenet Group. The views expressed in this publication do not necessarily reflect those of the advertisers or the publishers.

Tel 0113 239 0011 Fax 0113 239 5322

Connected - a Tenet Group publication­

4 - Industry Update

Our continuing journey through the regulatory landscape

Welcome to our first edition of Connected for 2018 and to start with, some positive news. In February, we were pleased to announce that in response to your feedback, we updated our social media policy and marketing support to enable firms to post

This content has been designed for Facebook, Twitter and LinkedIn and is ready for you to pick up and use - which you’ve done with enthusiasm and we’ve already had some great comments. We know this is something that many of you have wanted to be able to do for some time and we’re keen to identify any needs that we are not meeting within our support going forwards, as there is always room for improvement within any proposition. I’m also pleased to announce that Tenet continues to add to its awards tally, being presented with Legal & General’s Business Quality Award for Customer Excellence (Networks) in February for the second consecutive year. This is awarded based on protection business quality, compared against all other networks in the channel, so is an excellent result and is an accolade that speaks volumes about the quality of our advisers. So, thank you for continuing to work in partnership with us to achieve such high standards. Looking to the wider industry, what are the key regulatory milestones in the months ahead? They will come as no surprise, as they are regulatory activities that we have been talking about for some time but let’s have a walk through them to see where we are up to. Insurance Distribution Directive (IDD) At the time of writing, the European Commission has proposed to delay the Insurance Distribution Directive (IDD) to 1 October 2018. This is currently under consideration by the European Parliament and European Council. Consequently the UK Government has stated that they will delay the legislation bringing the IDD into force, pending a decision at EU level. This does not change the new, ongoing cost disclosure requirements however (just the effective date) or any other changes we have previously communicated in terms of the impact of the IDD. If you have already adjusted your process, the focus of your CPD activities and updated your initial disclosure documentation regarding your insurance services, it is not necessary to unwind this as you have simply prepared for the change in advance. If you are yet to make the relevant changes, you can either wait for the implementation date to be confirmed or continue to make the adjustments in advance. We will confirm the date once known. We do not propose to unwind the policy changes we have already made, but will not expect compliance with these until the revised implementation date is confirmed.

Steve Jones Adviser Relationship Director

financial promotions, recognising this as an increasingly important way of engaging on a regular basis with clients. Members who have ‘opted in’ to our social media now have access to over 80 compliance approved promotional posts and adverts across different product themes and to coincide with the timing of key events and the start or end of a month.

Industry Update - 5

General Data Protection Regulation (GDPR) Forthcoming General Data Protection Regulation is a huge subject, which we’ve aimed to break down into bitesize guidance over the past months. While some of the basic principles of the existing regime will be retained, the GDPR will introduce several new concepts and data subject rights, including the “right to be forgotten”, data portability and accountability. Some of these new concepts could have a significant impact on firms, and may require a change to both the handling and use of personal data. Please see our article on page 12 for an overview of what you need to know and do. It is your responsibility to ensure compliance under GDPR however and you should already be giving thought to how GDPR will affect your particular business model. It will be important to ensure all staff receive appropriate training and we suggest that you retain records of this. We recommend the Information Commissioner’s own website for more information and practical guidance and we issued a useful checklist at the start of the March, in the same way that we did for MiFID2 and IDD, which summarises all the actions and links to the relevant Tenet communications. On the subject of data protection, it’s important to be aware that the preferred method for sending documents to Tenet’s Advice Support Team is for them to be uploaded onto Tenet Advantage and notification sent to the relevant email address that the file is ready for assessment - this will ensure you meet your data protection responsibilities and the clients data is secure. Alternatively you can send by a file share facility and notify the relevant email address. Senior Managers & Certification Regime (SM&CR) The FCA published its first Consultation Paper in July, proposing to extend this regime to all the firms it regulates, having already done so for the banks in 2016. The FCA’s second consultation paper however confirmed that appointed representative firms are out of scope for the time being (until such time as the legislative powers are provided to bring them under the regime too) so will simply remain subject to the Approved Persons Regime. Even directly authorised firms are likely to not have to comply with SM&CR until mid-to-late 2019 now, as insurers appear to be next on the FCA’s list.

Adviser Software Market Recent research conducted by Ian McKenna’s company, the Finance & Technology Research Centre, identified three main contenders in the adviser software market and we’re pleased to share that focus:solutions (who develop Tenet Advantage) was selected as one of these. It’s reassuring to have external validation therefore that we are partnering with the right people. Those of you who attended the Adviser Forum in December will have seen Focus present a technology session, demonstrating how they can support advisers to work smarter and all of this functionality will be built into our back office system over time. Our schedule for implementation is currently slightly behind plan, but will start with the launch of our remuneration module, so we would ask you to please bear with us. Exit or succession planning Exit or succession planning will at some stage feature in any firm’s strategic plans. Just a reminder that Tenet has for many years brought together firms within the organisation whose principals are looking to acquire other client banks or exit the business themselves. In doing so, we have provided comprehensive guidance and support alongside significant funding assistance. In 2016, the group embarked on a pilot practice buyout initiative whereby the group itself would look to acquire the client banks of exiting investment firms. We completed the first acquisition in early 2016 and we now have completed three deals in total, with a further transaction nearing completion and discussions on-going with several others. In addition the Board has now approved a further refinement to this initiative to enable Tenet, under the right circumstance, to acquire the share capital of firms looking to exit. This provides a further option for principals planning their future direction. If you think this may be of interest and would like to arrange a discussion, please speak to your Account Manager. In summary, there’s a lot going on – as MiFID2 is bedding down into everyday practice, GDPR is looming, but remember that we’re here to help. Plus our schedule of professional events are also designed to cover key regulatory issues, with insight from our provider partners on how they can support you.

6 - Special Feature

SMART-BETA: An active approach to passive investing?

Kate Quarmby Trainee Technical Services and Research Consultant

Active or Passive? Many investors are confused as to where this investment type sits, as previously there were two main categories; active or passive, which is pretty black and white. Smart-Beta is still technically classed as a passive strategy, because it is restricted to the index and it doesn’t have a fund manager who can make changes to the investment style based on topical factors or opinions on how the market will move. Instead it uses a computer programme to select stocks based on the strategies chosen to try and exploit market inefficiencies. The ‘active’ component means it does have the potential to offer superior risk-adjusted returns relative to the traditional market-cap weighted index trackers due to the many different factors or strategies that are used within the fund. Types of Smart-Beta There are numerous strategies used in Smart-Beta ETFs which offer a ‘twist’ on the conventional market-cap weighted indices. This could be focusing on volatility, dividends, size or style to name a few (we will look at these in detail below), rather than weighting blindly on size like the characteristic index fund. These strategies can broadly fit into one of two categories, return- orientated and risk-orientated. • Return-orientated: enhance returns compared to a benchmark • Risk-orientated: aim to provide a smoother return through market cycles Due to the many different approaches some Smart-Beta ETFs can be quite complex to understand, in particular some of the multi- factor ETFs, using several different strategies within the fund. However, there are less complicated options, with many ETFs using only one factor and investing in companies methodically based on that aspect only. Low volatility Low volatility is the biggest growing risk orientated strategy. Although return orientated funds are dominating the market of Smart-Beta’s, the uptake in low volatility ETFs has been substantial. These funds pick the lowest volatility stocks and give those the highest weighting, with the intention of offering smoother returns at a lower risk. These minimum volatility funds will tend to lag behind cap-weighted trackers in periods of market upswings but provide a degree of protection against market downturns. Holding these types of ETFs will not generate mind- blowing performance but should offer a smoother ride and an above average risk-adjusted return.

The Active vs Passive debate is a long standing one within the investment industry. Both approaches have attributes that make them desirable in different areas and market conditions. Passive funds are cheap and cheerful simply tracking an index; however, they lack the ability of an actively managed fund which aims to beat the return of the market. This is where Smart-Beta Exchange Traded Funds (ETFs) comes in, blurring the line between the two strategies.

What are Smart-Beta ETFs? Smart-Beta, Strategic Beta or Factor Investing, whatever its name, is proving popular at the moment, providing a ‘best of both worlds’ alternative to the typical active or passive approach. The aim of Smart-Beta is to achieve alpha, the active return on an investment relative to a benchmark, and increase diversification from cap- weighted index funds at only a marginally higher price than the standard index tracker. This could be achieved whilst retaining a significantly lower cost than actively managed funds. Smart-Beta is in essence a development of the traditional financial beta, which measures the volatility of an investment against the market as a whole. A stock with a beta of 1 has experienced the same level of volatility as the index, with a beta of above or below 1 demonstrating a higher or lower volatility respectively. The increased popularity in Smart-Beta strategies is driven by speculation of whether active managers can meet their primary objective of outperformance and tracker funds offering no control over where the funds are invested.

Special Feature - 7

Equal Weighted This is one of the more simplistic approaches, the ETF would apply the same weighting to every stock in the index e.g. if it was a FTSE 100 Equal Weighted Smart-Beta ETF, every stock held would represent 1% of the fund, providing more exposure to the smaller cap securities and less to the largest companies in the FTSE. Fundamentals A downfall of standard trackers is that they replicate the market return based on the size of the companies within the chosen index, meaning they are buying more shares in the most expensive companies and selling out of the cheapest. Some fundamentally weighted ETFs are based on sales, cash flow and most commonly dividends. The dividend focussed ETFs are portfolios constructed by weighting the stocks based on the highest yielding companies from the chosen index. Style Active managers have been investing based on style for a long time. Style-investing focussed ETFs essentially try to replicate what an active fund manager does, but instead of a person picking out the stocks, a computer programme systematically picks stocks based on the factors targeted. The most popular style based ETFs used are growth, momentum and value. None of these are new strategies and have been adopted by active managers for many years. Taking value as an example, the ETF would try to replicate what active managers do by running a programme to systematically select stocks with the lowest prices, giving them the highest weighting, and selling out of the overpriced securities. Multi Factor Investing Then there are multi-factor ETFs, which as the name suggests, will weight the stocks based on several of the strategies described above. These are used as a way to further diversify away from using single factor Smart-Beta funds but can end up being far too complicated resulting in a lower take up and many even being closed. There can be many different combinations of how Multi-factor ETFs are constructed. The majority tend to have a principal factor, such as using low volatility as a starting point and then use other factors – value/growth/momentum to further diversify the ETF.

Conclusion Smart-Beta strategies straddle the middle ground between the transparent and low-cost structure of passive indexing and the potential for excess return that is the goal of active investing. However, they should not be viewed as a ‘silver bullet’ and care should be taken to ensure you fully understand the risks involved and whether they are appropriate based on your client’s circumstances. Smart-Beta is an interesting area currently with passive managers entering this space based on their previous experience, and some active managers seeking opportunity in a growing area. TS&R monitor this market as part of the ETF Panel Research. However, we have limited panel coverage for Smart-Beta ETFs as the majority are in their infancy and have yet to prove their approach has played out. Watch this space! The Technical Services & Research team are always on hand to answer any questions you have about Smart-Beta, or anything else technical, so feel free to give us a call on 0113 2395317 or email

8 - Events Focus

Have you planned your calendar of events for 2018? Attending our events will provide you with an excellent insight into current markets, new legislation, new products and services. It is a chance to network with your colleagues, product providers and Tenet staff, plus you get 3-4 hours of CPD awarded and recorded for you. All events are free of charge, so, don’t miss out - plan your calendar today.


NON-INVESTMENT ROADSHOW – ROUND ONE Starting April 2018 These events will be aimed at our Non-Investment advisers. The events will cover topics such as Mortgage, General Insurance and Protection. They will combine stand up formal presentations and interactive round tables. We recommend advisers attend both rounds of Roadshows as the content will be different at each. Target Audience: Mortgage and Protection advisers Approx Timings: 9.00am arrival 9.30am start - 3.30pm finish CPD: Approx. 3hrs 30 minutes unstructured To book your place on a Non-Investment Roadshow One visit: 17/04/2018 Durham 18/04/2018 Leeds 19/04/2018 Manchester (Merseyside) Haydock Park Racecourse 24/04/2018 Cumbernauld The Westerwood 26/04/2018 Belfast Stormont Hotel 01/05/2018 Birmingham Village Solihull 02/05/2018 Bristol Doubletree Bristol North 03/05/2018 Southampton Hilton at the Ageas Bowl 10/05/2018 London Millennium Hotel London Knightsbridge* Ramside Hall* Village Leeds South* Date Location Venue

MASTERCLASS ONE Starting May 2018 This year we will continue our exceedingly popular Masterclass events. Tenet will utilise the expertise of providers and fund managers, to create a valuable event; giving key industry insights, technical guidance and sales support. The purpose of these events is to provide a higher level of education, through the use of case studies, planning scenarios to provide you with a greater understanding of each product and a proposition’s place in the market. Target Audience: Investment, Pension and Protection advisers Approx Timings: 9.00am arrival 9.30am start – 3.30pm finish CPD: Approx. 3hrs 30 minutes structured

To book your place on a Masterclass One visit:




01/05/2018 Leeds

Village Leeds South*

02/05/2018 Manchester (Merseyside) 03/05/2018 Glamorgan

Haydock Park Racecourse

The Vale Hotel 15/05/2018 Cumbernauld The Westerwood 17/05/2018 Belfast Stormont Hotel 22/05/2018 Southampton Hilton at the Ageas Bowl 23/05/2018 London Millennium Hotel London Knightsbridge* 24/05/2018 Birmingham Village Solihull

*New venue

Events Focus - 9

CPD WEBINARS - Get your 30 minutes of CPD for each webinar you view! Throughout 2018, Tenet will be hosting a series of CPD webinars which are available to view from the comfort of your home or office, at a time to suit you. So if you need to top up your CPD, take a look at the webinars that are available. All you need is a device to view it on and your headphones! WEBINARS AVAILABLE TO WATCH ON-DEMAND NO 1: Bank of Ireland

‘Small Portfolio Landlords Are Confident About The Future – So You Can Be Too!

Presented by David MacKenzie, Corporate Account Manager on 23rd February 2018

Bank of Ireland will present the findings of their latest independent survey of small portfolio landlords, providing an indication of how landlords feel about the market. There is much to talk through including landlord optimism, tenant demand, their understanding of government changes and how their portfolios are performing. There is also detail of their recent activity, and what small landlords are intending to do in the near future. To finish, Bank of Ireland will talk through what they are doing to help this area of the market.


These events are designed with the main aim to meet advisers’ development needs and provide valuable insight into key industry issues. The PDMs offer a variety of important information from both our provider partners and Tenet’s senior management. Target Audience: Investment, Pension and Protection advisers Timings: 8.45am arrival 9.15am start - 3.15pm finish CPD: Approx. 3hrs 45 minutes structured

WEBINARS COMING SOON... We recommend registering for all the webinars, then opt out as and when, if you are not available or the content is not relevant.

To book your place on Cycle Two PDMs, visit: Date Location Venue 22/05/18 Manchester (Merseyside)

No 2 : The Exeter Content to be confirmed 27/04/2018 No 3: Shawbrook Content to be confirmed 25/05/2018 No 4: L&G Content to be confirmed 29/06/2018 No 5: Together Content to be confirmed 28/09/2018 No 6: TBC Content to be confirmed 26/10/2018 No 7: TBC Content to be confirmed 30/11/2018

Haydock Park Racecourse

23/05/18 24/05/18 05/06/18 06/06/18 07/06/18

Gloucester Glamorgan

Stonehouse Court*

The Vale Hotel

Cumbernauld The Westerwood


Ramside Hall*


Village Leeds South*



Sandy Park Conference Centre

14/06/18 20/06/18 21/06/18 26/06/18 27/06/18 28/06/18 03/07/18 10/07/18 11/07/18

Birmingham Village Solihull

Southampton Hilton at the Ageas Bowl Bishops Stortford Down Hall Country House Hotel


Tankersley Manor

Nottingham Nottingham Belfry


Reading Belfast

Hilton Reading Stormont Hotel Hilton Maidstone



Millennium Hotel London Knightsbridge*


If you have any queries, please call the events team on 0113 239 5334 or email You can book our events online – simply visit:

If you have any queries, please call the events team on 0113 239 5334 or email

10 - Up close and personal with…

Up close and personal with… Simon Broadley Under the spotlight in this issue is our new Adviser Propositions Director, Simon Broadley. He additionally took up the role of Managing Director of TenetLime. Having joined Tenet in early January, we speak to Simon in his first few months about his plans going forwards and also ask a few personal questions, so you can get to know him a bit better.

I also want to establish more robust insight and feedback in terms of how we compare to our competitors, to identify if there are things that we’re not doing, or not doing as well as our peers. I certainly don’t want or feel we need to change the essence of our business, so it’s evolution that I’m talking about, not revolution. 3. What are your hobbies and interests outside the office? With two young sons (aged 5 and 1), my free time for hobbies isn’t what it used to be! However, between the Lego building, swimming lessons and endless children’s parties, I’m a keen sports fan and have been a Bradford City season ticket holder for 25 years. My real passion however is cooking and wine, where I have to admit to being a bit of a wine geek, to the point of making notes about what I drink. I am very partial to an Italian red, thanks for asking! 4. What kind of music gets your toes tapping?  I’ve got quite an eclectic taste in music, ranging from Motown and Ska to 90s Britpop.

1. Can you give us a brief history of your career to date?

I’ve been in the financial services industry for over 20 years now, most recently as Head of Insurance and Investments at Yorkshire Building Society Group. I also did a stint as the group’s Head of Product Development and I’ve additionally been seconded into roles to lead sizeable remediation programmes, so I’ve first-hand experience of what things look like when they go wrong – and how to avoid them happening in the first place! 2. What are you looking forward to in your new job at Tenet? I’ve joined the group at a real time of stability and opportunity and having the luxury of deciding how and where you want a business to grow is both refreshing and liberating. Tenet has a very positive reputation in the market, which provides us with a firm foundation to build on. There is always room for improvement however, and I want to start off by fundamentally reviewing our member propositions, asking how we can enhance them and what needs are we not meeting?

Up close and personal with… - 11

5. What book are you currently reading? Hugh Johnson’s pocket wine book is always to hand, plus I’m reading ‘Traction’ by Gino Wickman. I’ll be hoping to apply some of his business principles going forwards, to help align our priorities right across the group in 2018 and ensure that we are all pulling in the same direction. 6. What’s your favourite film of all time? That’s a tough one. I would have said previously something like Scarface or Casino – but more recently the TV is dominated by my two sons, Jack and Oliver, so Despicable Me has to be up there!

7. If you could trade places with anyone for the day who would it be and why? Donald Trump’s executive assistant, as I’d like to see first- hand whether the reports and rumours are all true! 8. What’s the biggest lesson you’ve learnt in life? To be here now and appreciate the moment. 9. And finally, tell us an interesting fact about yourself... I once competed in the Latvian Open Golf Championships! Before you get the picture that I’m some kind of pro, I’m definitely not, but a friend’s brother was a pro at a course in Riga and somehow got me in. It was quite intimidating once I arrived and realised that the championships was the real deal – needless to say, I didn’t do too well against the competition, but think I played as well as I ever have done.

I am very partial to an Italian red... thanks for asking!

12 - Special Feature


The GDPR will take effect in the UK on 25 th May 2018, replacing the current Data Protection Act.

It’s important that you comply with the GDPR, especially with increased fines in the offing, so please don’t assume this doesn’t apply to you or your business – you as the firm are the data controller and need to ensure that you are compliant.

What is the new regulation? Whilst the basic principles of the existing Data Protection Act regime will be retained, the GDPR will introduce new concepts and rights for the data subjects, some of which will have a significant impact on how you handle and use personal data. The biggest change is the increased fines for data breaches. Currently, the Information Commissioners Office (ICO) fines have been limited to £500k, but GDPR increases this to the higher of 4% of the annual turnover or € 20,000,000. In the GDPR world, data controllers will need to be prepared for the ICO taking stricter enforcement action independently of the FCA to utilise the increased fines, creating an additional financial risk in conjunction with the existing legal and reputational risk. What is the current position? How you collect, store, use and hold the personal data of your clients and employees is currently governed under the Data Protection Act 1998 (DPA). Just as Tenet is required, you also are required to be registered data controllers and hold an ICO data protection licence. You are responsible for personal data and are required to comply with the eight data protection principles under the DPA. Tenet will process members’ personal information for the purposes of providing services under the contract it enters into with the members, and as part of our legal obligation to monitor members’ compliance with the requirements of the Financial Conduct Authority, we will process client’s personal information. In terms of your responsibilities as data controllers under GDPR, the key areas are summarised below:

• Data Processing - Data controllers must have a legal ground for processing personal data. Legal grounds are: - Explicit consent - the data subject has given you explicit consent. - Performance of a contract – for example to provide financial services under the client agreement. - Meeting legal obligations – for example to meet regulatory requirements e.g. from the FCA. - In the legitimate interests of the data controller – for example, to promote and manage the business, such as defending advice claims. • Third Party Data Processors - You must have a written agreement between you as the data controller and the third party data processor to be able to process personal data e.g. if you share personal data with your third party IT supplier / third party paraplanner, you need a data processing agreement in place and we have provided a template document for you to use. Tenet will undertake this with the product providers on its panels and its partnered suppliers. • Data Breaches - The GDPR makes it mandatory to report data breaches to the Information Commissioners Office (ICO) within 72 hours, unless the breach is unlikely to cause damage to the individual. You should review your internal data incident reporting procedures or introduce some simple steps so you can detect, report and investigate a data incident and include these procedures in a policy, including staff training, a reporting process and a data incident log. Network firms will also need to notify Tenet’s Data Protection Officer.

Special Feature - 13

• Data Protection Officers - Some organisations must have a Data Protection Officer (DPO); this is someone responsible for data protection compliance within your firm. We think our members will not fall into the category but you still need to appoint a ‘Privacy Officer’ who has sufficient skills to meet your obligations under GDPR. This can be an existing member of staff that already has some knowledge of data protection, or can gain the knowledge through training. • Privacy Policy and Notices - You, as data controllers are required to take ‘appropriate measures’ to provide information about how you process your clients’ personal data. The client agreement currently includes a basic privacy notice that tells your clients who you are, what you are doing with the data and who you share it with - that includes sharing it with Tenet and also captures your clients’ consent for marketing activities. You (as do Tenet) may also have a privacy policy on your website, including more detailed information about how you handle clients’ personal data, making this information easily available. Going forwards, the privacy notice in the client agreement will be replaced with a standalone privacy notice that will signpost to your own and Tenet’s privacy policy, via a link to the corresponding websites. You need to start thinking about revising your existing privacy policy or introducing a privacy policy to be GDPR compliant.

• Data Subjects Rights - Data subjects have the right: - To be informed about how their data is processed (through a privacy notice/ privacy policy). - To have their data rectified if inaccurate or incomplete. - To restrict the processing of their personal data. - To object to their personal data being processed. • Data Subject Request s – Data subjects can request: - A copy of their personal information (under a DSAR), provided free of charge and in an intelligible form. - To have their personal data transferred electronically (referred to as ‘portability’). - To have their personal data deleted, (‘erasure’) unless there is a reason to retain it, such as to defend an advice claim. • Accountability, Transparency and Data Minimisation - It is your responsibility to clearly demonstrate that your organisation complies with the principles of GDPR by implementing systems and processes, for example by implementing data protection policies, undertaking staff training, internal audits, IT security, appoint a Privacy Officer, document lawful grounds for processing and introduce principles of data minimisation (e.g. ensure you collect the minimum amount of data for each specific purpose) and privacy controls in your business. • Training - Staff awareness and training is critical to protecting personal data, so you must ensure all staff within your organisation have had data protection training. We recently circulated our own GDPR checklist, which provides a useful summary of the actions firms need to complete, but if you have questions on any elements of this, please contact the Compliance Helpdesk in the first instance. We also recommend the Information Commissioners’ own website for more information and practical guidance. Finally, on the subject of data protection, it’s important to be aware that the preferred method for sending documents to Tenet’s Advice Support Team going forwards is for them to be uploaded onto Tenet Advantage and a notification sent to the relevant email address that the file is ready for assessment - this will ensure you meet your data protection responsibilities and the clients’ data is secure. Alternatively you can send by a file share facility and notify the relevant email address.

16 - 2017 Adviser Forum Recap


Our 2017 Adviser Forum, held on 7th December at the iconic Queens Hotel in Leeds, was deemed a big success. With over 200 people in attendance, the main event in Tenet’s calendar brought together advisers, some of our provider and lender partners, and Tenet staff who all enjoyed a day of insight and networking. As this is our first edition of Connected this year, we wanted to take a step back to December and provide a reminder of what happened on the day, share some pictures with you, and let you know the date and location for this year’s Adviser Forum so you can save the date in your diary. So what happened at the 2017 Adviser Forum? Throughout the day we had a number of engaging presentations, commencing with breakout sessions in the morning, and then, after lunch which provided networking opportunities in the ever-popular trade fair, we moved onto

the main forum event. Our key note speakers included our CEO, Martin Greenwood, who provided a Tenet business update, Robert Peston, the Political Editor of ITV News and host of the weekly political discussion show, ‘Peston on Sunday’, and Bonita Norris the youngest British woman to conquer Everest. We also had presentations from our main stage providers – Royal London, M&G Investments, Just, Vitality, Aegon, Bank of Ireland and Shawbook Bank. After a successful day, those that were able to stay into the evening enjoyed a gala dinner and Gatsby themed entertainment all of which was provided as a benefit of being a member of Tenet. It was great to see so many people in Gatsby themed attire as it really made a difference to the ambience of the event. All in all, we received some fantastic feedback about the event and we’d like to take the opportunity to thank everyone that attended.

So, what about the 2018 Adviser Forum? Whether you were able to enjoy the 2017 event and are keen to find out when the next one is, or you weren’t able to make it and want to find out what you’re missing out on, we are sure you will want to get a date in your diary for the 2018 Adviser Forum. So, here you go…

In partnership with our main stage partners:

Event Focus - 17

Our top achievers from TenetConnect and TenetLime were invited to join us on the prestigious yacht hotel – The Sunborn in London. They enjoyed an evening of food, drinks and magical entertainment. We recognised the achievements through an awards ceremony that took place on Thursday 1st February. Details of the winners can be found below. Watch this space for an announcement about next year’s event and how you could be there... The TenetConnect lucky winners were…


Large Firm of the Year 2017 (4 or more advisers) – NORTH

Small Firm of the Year 2017 (1-3 advisers) – NORTH

The shortlist is: WFI Financial LLP G Sturgess Financial Planning Ltd Create Financial Management LLP ANDTHEWINNER IS Create Financial Management LLP

Crandles & Co LLP City Gate Aberdeen Ltd Scotia Independent Financial Services

The shortlist is:

ANDTHEWINNER IS City Gate Aberdeen Ltd

Large Firm of the Year 2017 (4 or more advisers) – SOUTH

Small Firm of the Year 2017 (1-3 advisers) – SOUTH

Lothbury Wealth Management Limited Direct Financial Planning (UK) Ltd Sovereign Asset Management Ltd

The shortlist is:

The shortlist is: Bluechip Financial Ltd Finance Planning Wealth Management Ltd Gerry Dupree &Co ANDTHEWINNER IS Finance PlanningWealthManagement Ltd

ANDTHEWINNER IS Sovereign Asset Management Ltd

Adviser of the Year 2017 SOUTH

Adviser of the Year 2017 NORTH

The shortlist is: Phil Cross, Direct Financial Planning (UK) Ltd Robert Shirley, Sovereign Asset Management Ltd Nathan Harris, Lothbury Wealth Management Ltd ANDTHEWINNER IS Phil Cross, Direct Financial Planning (UK) Ltd

The shortlist is: Gavin Sturgess, G Sturgess Financial Planning LtdKaren Scott, Create Financial Management LLP Roger Lee, Create Financial Management LLP Alan Johnston, City Gate Aberdeen Ltd ANDTHEWINNER IS Alan Johnston, City Gate Aberdeen Ltd

18 - Marketing Support

NICE TO TWEET YOU! New social media policy and service

On 1st February 2017 we updated our social media policy to enable appointed representative firms to post financial promotions on social media. What’s more, Tenet’s Marketing team announced details of a new social media service they’ve developed which provides access to a wide range of social media posts and adverts. These are approved by Compliance so you can use them quickly and easily. So, here’s a reminder of what’s now available to help you promote your business on social media.

What was the update to the social media policy?

creating yourself. However, to make it quick and easy for you to post promotional content on social media, the Marketing team have created a new service which is now available to you. What’s more, it is free as a benefit of

Before 1st February, appointed representative firms could post social media content subject to getting their social media pages approved by the Compliance Helpdesk and following the ‘opt in’ process, but posts which constituted as a financial promotion were not permitted. We understand this was a frustration for some firms that wanted to use social media to actively promote their business, so we listened to feedback and responded by updating the policy to now allow financial promotions on social media. If you’re using, or are intending to use, social media, please familiarise yourself with the updated Social Media Policy and process which is in the Compliance Support section of the extranet. As with all financial promotions, they must be approved by the Compliance Helpdesk first – this includes social media posts you are

being a member of TenetConnect. New social media service

Our new social media service, which forms part of the overall Marketing Toolkit, provides you with access to a range of social media posts across different product themes, as well as posts which are designed to coincide with the timing of key events, such as the Bank of England base rate announcement, and the start or end of a month. The content has been designed for Facebook, Twitter and LinkedIn and is designed to work alongside advert images which have been produced as jpegs. In many cases it is necessary to include the relevant advert image

Marketing Support - 19

to make the post compliant (as it carries any necessary risk warnings) but there are also some posts which can be posted with or without an advert. These posts are all designed to be added on your own social media page as a free way of promoting your business, alongside other posts of a non-promotional nature. If you’re intending on paying Facebook for advertising, then they are not keen on having wording on images, so please get in touch with the Marketing team to discuss an alternative approach. How do you access the social media support? All the available social media content is available via the Marketing Toolkit section of the extranet. Simply click on ‘Grow Your Business’ in the top menu bar and then on ‘Marketing Toolkit’ and you will see a dedicated social media page. To use the social media content, simply copy and paste the approved wording onto your Facebook, LinkedIn or Twitter page, along with the relevant advert image (you will need to save the advert image to your computer first, and then upload the social media post).

And finally… We hope you find the new social media service useful. If you have any feedback, particularly if you have success using the posts we have provided, then we’d love to hear from you. To provide feedback, please email or call Jonathan Hydes, Head of Marketing & Communications: email or call 0113 239 0011.

Follow Tenet on Social Media Please make sure you look us up and follow us.

LOTS MORE MARKETING SUPPORT AVAILABLE There is a range of support available via the Tenet Marketing Team. This includes brochures, leaflets, websites and more. For more details and to see all the support available, visit the Tenet Extranet or call 0113 239 0011

Special Feature - 21

Announcing the winner of the first member-get-member prize draw…

Did you know you can earn £££s by recommending advisers to Tenet? With our member-get-member scheme, you can benefit financially from helping us grow the network. Maybe you know someone who used to be an adviser but no longer has Competent Adviser Status (CAS) and is looking to re-enter the industry? Or maybe an ex-colleague would welcome a new career move? Perhaps you know an adviser or firm with another network that is not happy with the service they are receiving? Whatever the reason, maybe it’s worth discussing with them if they would be interested in joining Tenet? If you recommend a new adviser or advisers to us and they join the network, either as a registered individual within another network AR firm that is looking to recruit (i.e. not your own business), or they set up their own AR firm, then you will be paid a referral fee - the amount depends on the number of advisers that join. Plus, until 31st May 2018, every new referral will get your name into the hat to win £250* in shopping vouchers.

And the winner is…

We are really pleased to announce the winner of the first prize draw. Nigel Heckman of Just Mortgages referred Rhodri Sellers of Cartref Mortgages Ltd. Commenting on his win, Nigel said:

“Rhodri was originally a mortgage client of mine. I had arranged several mortgages for him over the past few years and he expressed an interest in learning more about the industry on each occasion, which resulted in him eventually doing his exams and then looking for a network to support his own advisory firm. He asked me about Tenet and I had no hesitation in recommending their services, based on my own experiences over the past nine years. I’ll be using the vouchers towards some warm weather clothing for a trip to Lapland in December 2018.”

So could you be in line for the next prize draw… and of course the referral fee? If you have a friend, business contact or ex-colleague you would like to help, then please contact us. Email or call us on 0113 239 5312. For full details, including terms and conditions, please visit the extranet at We look forward to hearing from you!

22 - Special Feature

Tenet Paraplanning - a potential extension to your business!

Paraplanning at Tenet has grown rapidly over the last few years in response to demand from our members. In 2017 we helped over 117 firms with over 1,100 cases. As more and more advisers start to use our services, in this issue of Connected, we answer some of the frequently asked questions we get from new users…

What can Paraplanning do for me? We can support you with everything from comprehensive administrative tasks and research to full report writing, or a more bespoke and tailored service designed to complement your business. What sort of cases do you do? Pretty much everything! We work on a wide range of cases, from straight forward protection cases, pension and ISA funding and platform reviews, to the more complex work like DB Transfer Reviews, QROPs, Estate Planning, VCT/EIS Cases and Equity Release to name but a few. We also offer a Centralised Investment Proposition (CIP) design service, working to your firm’s requirements and Tenet policy to provide a proposition that will How much does it cost? We offer competitive fixed prices for the majority of case types. For anything else, we operate bespoke pricing at an hourly rate. We will always provide you with a personalised quote at the start of the process based on your exact requirements so you know the total amount you will have to pay. What do I get? Obviously, this depends on what work we are carrying out for you, but for normal paraplanning you get a fully compliant (Pre-Sale Approved) file containing research, illustrations, cash flows and Suitability Report. We can also send you two professionally bound copies of the finalised report, complete with your company logo for you to present to your client. As one of the key benefits of paraplanning is to save you time, you can be assured that once we have all the initial documents we require for a case there will be minimal work required from you. We have developed a Case Submission form to ensure this process is as streamlined as possible and to enable us to commence work on your case without delay. To save you the hassle of having to collate all the information yourself, full data gathering is available at no additional charge. In these instances, we have a Letter of Authority for your client to sign to allow us to do this for you. • TVAS Reports – for Defined Benefit Transfer Reviews Sometimes you won’t need us to do a full Defined Benefit suitability review, so we can produce a TVAS report only for your case using Select A Pension; a fully independent service. As part of the TVAS, we can gather the required data at no additional cost. make the advice process easier for your business. Please give us a call to talk about your specific case. How do I get started? Give us a call and we will talk you through the process. Our most popular services are: • Full Research &ReportWriting

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