The Financial Conduct Authority (FCA) and the Information Commissioner’s Office (ICO) published a joint statement on 27 March 2026 relating to firms’ approaches to vulnerable client data.
You can read the statement here: Joint FCA and ICO statement on regulatory expectations regarding firms’ approaches to vulnerability related data | FCA .
The statement included FCA and ICO expectations relating to the sharing of client data, encouraging manufacturers and distributors “to work collaboratively, sharing relevant information as necessary to deliver good outcomes for customers” and noting that “data protection law is an enabler to responsible data sharing”.
We encourage advisers to share relevant vulnerability information with us where it can help support better client outcomes, as effective collaboration between advisers and platforms can help ensure that your clients receive appropriate, tailored support from our specially trained staff. You can be confident that we apply robust data protection standards in line with UK GDPR and the Data Protection Act 2018, ensuring all information is processed for a clear and proportionate purpose and is protected through strong security controls, including encryption and secure storage.
To let us know about your client’s vulnerability and the support they require, please call your Client Service Team or send us a secure email. Alternatively, for new portfolios, you can provide this information during the Guided Application process on Transact Online. We are currently developing functionality on Transact Online to enable you to notify us of vulnerabilities for existing clients too, which we hope to launch soon. We will let you know when this is available.