Record Keeping Policy

Introduction

Bamboo Marketing NW Limited T/A PCPBuddy has implemented this policy to ensure orderly records are kept of our business and internal organisation, including all services and transactions undertaken by us. This enables the Financial Conduct Authority (FCA) to monitor our compliance with regulatory requirements and, in particular, to ascertain that we have complied with all obligations with respect to our clients.

1. General Record-Keeping Requirements

As a minimum, PCPBuddy will retain records of any advice given to, and correspondence with, our clients, and any correspondence with third parties in the course of providing claims management services. We will also keep records in accordance with each relevant module of the FCA Handbook, including but not limited to:

• Matters and dealings (including accounting records) (SYSC 3.2.20 R)
• Details of orderly records of services and transactions undertaken (SYSC 9.1.1R)
• Conflict of interest (SYSC 10.1.6 R)
• Employment history of employees (SYSC 22.9.1R)
• Complaints (DISP)

2. Specified Record-Keeping Requirements

PCPBuddy adheres to the Claims Management Conduct of Business Sourcebook (CMCOB), the specialist FCA Sourcebook for regulated claims management activities. In addition to general record-keeping requirements, CMCOB sets out further record-keeping requirements including but not limited to:

• Due diligence measures taken in respect of lead generators used (CMCOB 2.2.2R)
• Source of sale leads (CMCOB 2.2.4R)
• Telephone calls and electronic communications (CMCOB 2.3.2R and 2.3.6R)
• Client confirmation that they have alternative methods of pursuing a claim and the reasons for not using them (CMCOB 4.3.1R)

3. Retention of Records

PCPBuddy has appropriate systems and controls in place with respect to the adequacy of, access to, and the security of our records, so that we fulfil our regulatory and statutory obligations. With respect to retention periods:

• Records should be retained only for as long as is relevant for the purposes for which they are made
• Retention periods are set in accordance with our Data Protection Policy and any applicable regulatory timeframe
• Once a retention date has passed, records must be securely destroyed in accordance with our secure disposal procedure

4. Responsibility and Monitoring

All members of the management team are responsible for ensuring our record keeping obligations are met in accordance with FCA requirements. All records will be updated when appropriate and retained in accordance with our Data Protection Policy.

• Records are reviewed regularly to ensure accuracy and continued compliance
• Any records no longer required will be securely destroyed
• Access to records is restricted to authorised personnel only