Communications technology is changing more rapidly than ever before, and any firm hoping to stay on top of its compliance responsibilities must possess the agility to quickly react to this whirlwind evolution. For compliance teams, the goal is to reduce the risk of interruptions in recordkeeping oversight as much as possible — which can be incredibly difficult in an era where new communication networks are vanishing as quickly as they emerge. This challenge is not new for firms who have been seeking to move from legacy on-premises email archives, as well as those that have been left abandoned by vendors who have chosen to focus their R&D investments on information security, storage, or other pursuits. However, this challenge has recently increased for other communications tools beyond email. Let’s look at two networks that have recently reached End of Life (EOL) — CME Pivot Chat and Google Plus, and review options users of these and other networks should take to avoid disruption of compliance efforts when a supported communication channel goes dark.
First – CME Pivot Chat.
Users of the popular CME Pivot chat program are already aware that the service was shuttered as of February 28, 2019. According to the official FAQ, “CME Group has decided to no longer offer a stand-alone chat platform.” The FAQ directs CME Pivot users toward chat features incorporated into CME Direct Mobile — which is a browser-based version of the CME Direct trading suite that will be sufficient for those that seek to minimize disruption to users and IT infrastructure to capture that communications source. However, we are also seeing other firms who are using this news as an opportunity to evaluate other networks that have experienced explosive growth since they had licensed CME Pivot. This includes a complete spectrum of single purpose trader chat applications to full-featured, multi-modal collaborative platforms including Symphony, Slack, and the combination of Office365 and Microsoft Teams. Slack now has over 10 million monthly average users and is headed for a ‘unicorn’-style IPO, while Symphony is adding users at a rate of 10,000 per month. Both offer quick, intuitive user experiences, security appropriate for financial services firms, and a full set of unique apps that will likely see both platforms continuing their impressive growth into the future. Compliance teams can manage risk as all major collaborative platforms provide sufficient connectivity for content and metadata to be captured and archived by third party compliance tools.
Second – Google Plus.
Following the discovery of a vulnerability that was exposing user data to the public, Google is now closing down its Google Plus social network. As of April 2, all Google Plus accounts and pages created by users will be shut down and Google will begin the process of deleting all Google Plus content. While this scouring will take some time and content may continue to exist beyond the April 2 deadline, all content on Google Plus should be considered unavailable as of that date.
Google offers no alternative social collaboration tool for users of Google Plus, and firms should carefully consider the question of whether Google is focused on serving the compliance-driven communications marketplace. As with WeChat and WhatsApp, compliance risk can be created if communications tools are designed for use by consumers and broad, cross-industry business usage. Fortunately, firms are not lacking in options for users that are subject to regulatory compliance requirements. For example, Linkedin, the most dominant social network for most businesses, provides a mature set of capture and third-party regulatory control capabilities to meet books-and-records and supervisory obligations. Workplace by Facebook is also gaining adoption with regulated organizations wanting to safely enable employees on a familiar platform for instant messaging and collaboration.
Next – Instagram.
As we saw in Facebook’s recent decision to migrate users from Instagram Personal Accounts to Instagram Business Accounts, users were first notified in late 2018, and have until 2020 to make the switch. However, while this amount of advance notice is useful, it is never guaranteed. With the inevitability of the next network being added into the business communications ecosystem, and others simultaneously fading away, your organization will eventually face a network lifecycle disruption and replacement situation.
When that time comes, IT and compliance teams should focus on a few key areas:
- Know Your Workforce and Clients: Changing demographics are creating a new set of preferences for communications. Understanding the tools that are gaining favor with your employees and your clients is critical to setting up supervision policies that are current for applications and accounts being used on behalf of your employees and your firm.
- Know the Modalities: Each tool is unique, so understanding the communications options available on new networks can provide earlier insight and guide decisions regarding the potential sunsetting of older, single purpose tools prior to the arrival of a disruptive EOL notice.
- Know the Providers: Examine the contractual EOL provisions of existing tools and those under consideration, as well as the existence of communications processes, migration support, and time provided to extract information from retired networks.
- Know the Third-Party Platforms: As firms continue to add networks, use of third-party solutions become even more critical to provide the underlying infrastructure, resources, and expertise to work directly with content providers in order to anticipate tool updates and potential EOL situations.
- Keep Policies & Training Up to Date: As your mix of networks continues to evolve, making sure that your communications policies are current to reflect the features and modalities of each is vital. Additionally, providing regular updates to users on potential network changes will enable them work proactively with clients to ensure that business communications are not disrupted through transitional periods.
It’s never too early to start preparing for change amongst your communications tools — and doing so well before you actually need to replace a new platform will drastically reduce the potential for mishaps in transition or gaps in compliance processes.
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