Digital Journeys, Data Quality, and Honesty in Compliance

Unknown Speaker

Hello and welcome back to the B-Compliant Podcast! I’m Vicky Pearce, and as always, I’m joined by Rachel MacRae. Today, we’re diving into the FCA’s latest findings on digital customer journeys, data quality, and why honesty with the regulator is absolutely non-negotiable. Rachel, shall we kick off with the digital side of things?

Rachel MacRae

Absolutely, Vicky! I’ve been itching to talk about this one. So, the FCA’s review focused on how consumer credit firms design their online acquisition journeys, but honestly, the lessons here are for anyone with a digital presence. It’s all about how the design of your website or app can shape customer behaviour and understanding—sometimes for better, sometimes for worse.

Unknown Speaker

Yeah, and it’s not just about making things quick and easy, is it? The FCA pointed out that while speed is nice, it can come at the expense of clarity. I mean, we’ve all seen those journeys where you’re nudged to click through as fast as possible, but you’re left thinking, “Wait, what did I just agree to?” That’s what they call ‘sludge’ practices, right?

Rachel MacRae

Exactly! And the FCA highlighted some good practice too—like firms using inclusive design, making sure their platforms are accessible, and actually testing with real users. I love that they mentioned using clear, simple language and even adding friction points, you know, those little pauses that make you stop and think before you commit. It’s not about slowing people down for the sake of it, but making sure they really understand what they’re signing up for.

Unknown Speaker

And it’s so important for vulnerable customers, isn’t it? The FCA said some firms just weren’t meeting the needs of people with lower financial literacy or those in tricky circumstances. It’s not enough to just have a slick journey—you’ve got to think about everyone who might use it.

Rachel MacRae

That reminds me of a client we worked with last year. They wanted to make their onboarding journey as fast as possible, but when we looked at it, it was all about speed and not much about clarity. We helped them redesign it so there were clear explanations at each step, and we even got feedback from frontline staff and real customers. It made a massive difference—people felt more confident, and the firm actually saw fewer complaints about confusion. It’s about supporting clarity over just ticking the “quick” box.

Unknown Speaker

That’s a great example, Rachel. And it ties in with what the FCA said about using behavioural data—like tracking where people drop out of the journey. If you’re not looking at that, you’re missing a trick. It’s not just about how many people finish the process, but whether they’re getting the right outcome at the end.

Rachel MacRae

Totally. And the FCA’s going to keep an eye on this, so it’s not a “fix it once and forget it” thing. Firms need to keep testing, keep improving, and always have the Consumer Duty front and centre. It’s about making sure digital design actually helps customers, not just the business.

Unknown Speaker

So, moving on from digital journeys, let’s talk about data quality. The FCA’s review this week was technically about benchmarks, but honestly, the message is for everyone. Rachel, what stood out to you?

Rachel MacRae

Well, the big thing for me is that it’s not just about having loads of data—it’s about making sure it’s accurate, reliable, and actually useful. The FCA was really clear: you need robust systems and controls, not just a spreadsheet here and there. It’s about how you gather, store, and report your data, and whether you can actually demonstrate that it supports good outcomes for clients.

Unknown Speaker

Yeah, and it’s not just a compliance box-ticking exercise. Good data quality underpins everything—reporting, management information, governance, even business continuity. If your data’s a mess, you’re going to struggle if the regulator comes knocking, or if you’re thinking about selling or restructuring. I mean, we’ve seen firms get tripped up by this, haven’t we?

Rachel MacRae

Oh, absolutely. I remember one case where a firm thought they had everything sorted, but when it came to a regulatory request, they couldn’t actually pull the right data together. It delayed everything. The FCA’s s.165 information request recently was a wake-up call for a lot of people—are you collecting the right data, is it stored securely, can you actually retrieve it when you need to?

Unknown Speaker

And it’s not just about being able to find it. You’ve got to show how that data supports the outcomes you’re delivering. If you can’t demonstrate that, you’re on shaky ground. The FCA’s message is pretty clear: even if you’re not in the benchmarks sector, these principles apply to everyone. It’s a good time to review your controls and make sure they’re still fit for purpose.

Rachel MacRae

Yeah, and if you’re not sure, we can help! It’s much better to find the gaps now than wait until you’re under the microscope. Data quality isn’t glamorous, but it’s absolutely essential for compliance and for running a resilient business.

Unknown Speaker

Right, let’s get into the last bit—honesty with the FCA. The H2O AM case is a real eye-opener, isn’t it?

Rachel MacRae

It really is. So, Jean-Noel Alba, who was the Deputy CEO at H2O AM, got fined over a million quid and banned from financial services for deliberately misleading the FCA. He gave false information, got staff to make up meeting minutes, and submitted documents that were, well, let’s just say, not exactly what they claimed to be. The message couldn’t be clearer: you’ve got to be truthful with the regulator, no matter what.

Unknown Speaker

Yeah, and it’s not just about avoiding fines. It’s about trust. The FCA knows mistakes happen, but if you try to cover them up, that’s when things get really serious. If you spot an error in your regulatory communications, the best thing you can do is be upfront about it. The FCA will work with you if you’re honest, but they won’t tolerate dishonesty.

Rachel MacRae

And that’s where good governance comes in. You need clear audit trails for key decisions, and staff who are trained to engage with the regulator in a transparent way. It’s not just a compliance team thing—it’s got to be embedded across the whole business. If you build a culture where people feel safe to admit mistakes and ask questions, you’re much less likely to end up in hot water.

Unknown Speaker

Absolutely. And if you’re ever unsure, get advice early. It’s always better to check than to guess and hope for the best. That’s probably a good note to wrap up on, actually. Rachel, thanks for another great chat—and thanks to everyone for listening. We’ll be back soon with more updates and insights. Take care, Rach!

Rachel MacRae

Thanks, Vicky! Always a pleasure. And thanks to all our listeners—see you next time on the B-Compliant Podcast. Bye!