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Users and Entities

Learn how Corterum manages and distinguishes between data about an individual and their access to the Corterum system.

Corterum Team avatar
Written by Corterum Team
Updated over 3 years ago

Background

The Senior Managers and Certification Regime (“SM&CR”) potentially involves a number of complex relationships. For example,

  1. Some staff members may need to access the Corterum system but may not be subject to the SM&CR (e.g. data processors who may be “Ancillary Staff”);

  2. It may be necessary to maintain SM&CR data about other staff members, but they may not require access to the Corterum system;

  3. Some staff members may work for multiple group companies (all of which are subject to the SM&CR) but perform different roles across different group companies; or

  4. Despite the fact that ex- members of staff may no longer require access to the Corterum system, it is necessary to maintain information about those ex- members of staff (e.g. for the purposes of responding to a regulatory reference request).

Within Corterum we are able to model all of these dynamic relationships. We do this through the concepts of “Users” and “Entities”. We explain both of these concepts below.

Users

The concept of a “User” refers to an individual who needs to access the Corterum system, for whatever reason. Nothing more.

Entities

There are actually three types of “Entity” within Corterum:

  1. Person Entities;

  2. Business Entities; and

  3. Regulator Entities.

However, for the purposes of this article, we will focus on “Person Entities” only.

It is easiest to think of an “Entity” as an empty ‘box’. Within this box we can store information about individuals. However, only STATIC data is stored within the Person Entity ‘box’. In other words, only information which TYPICALLY DOES NOT CHANGE is stored within the “Entity” (e.g. name, age, address data, Individual Reference Number, National Insurance Number). SM&CR data about an individual (which may change) is not stored within that individual’s Person Entity.

Why do we do this?

Consider the example of Bill Green. Bill is a Senior Manager for two group companies – Mega Fund LLP and Super Fund LLP. However, Bill performs DIFFERENT Senior Management Functions for each fund. More specifically, Bill is SMF 1 (Chief Executive) with respect to Mega Fund LLP and is SMF 3 (Executive Director) with respect to Super Fund LLP). Obviously, whilst Bill’s Senior Management Functions are DIFFERENT, his STATIC DATA remains the same.

Now imagine that Bill works for a firm of IFAs which has 20 group companies and performs different Senior Management Functions across all of those group companies. Hopefully you can see how the complexity associated with mapping Bill’s relationship with the overall group scales rapidly. We must track the different Senior Management Functions Bill performs for each group company separately and accurately. At the same time, we would rather not input Bill’s static data 20 times (once for each group company).

To address this issue, Corterum saves Bill’s static data into his “Person Entity”. Corterum then allows administrator users to ‘link’ Bill’s “Person Entity” to all relevant group companies. When combined, Bill’s “User” and his “Entity” allow Bill to both access the system and his data.

Obviously, we only want to give Bill access to the Corterum system for so long as he is an employee of the firm. This is where Bill’s “User” again becomes relevant. If Bill ever leaves the firm, his “Person Entity” is simply ‘disabled’ and his “User” account deleted. Bill no longer has access to the Corterum system, but the SM&CR data about Bill remains intact.

How Entities link to Corterum fees

In Corterum, you are charged by reference to the number of ACTIVE Person Entities registered on the system. In other words, you are charged by reference to the number of staff about whom you are actively tracking SM&CR data. Conversely, you are NOT charged by reference to INACTIVE Person Entities. As such, you will NOT be charged for any members of staff who have left the firm (provided that you have ‘disabled’ their Person Entity within Corterum).

The interaction between Users and Entities

The following are good ‘rules of thumb’ and help in understanding the interaction between Users and Entities:

  1. Any member of staff who wishes to access the Corterum system must be a “User”.

  2. "Users” are NOT required to have linked “Entities”.

  3. However, any individual about whom you wish to save SM&CR data must have a “Person Entity”.

  4. Entities can be linked to multiple SM&CR companies to obviate the need to input duplicate data.

An example

The interaction between “Users” and “Entities” is perhaps best explained by way of a few simple examples, as set out in the table below:

Description

Existing User

Entity Required?

Comments

Joe Bloggs - Current SM&CR employee

Yes

Yes

Joe accesses the system – therefore he is a “User”. Joe has SM&CR information about him stored within the system – therefore he requires a “Joe Bloggs Person Entity” to be created so as to enable information about him to be saved and managed.

Jane Smith - Ex-employee (was subject to SM&CR)

No

Yes

Jane Smith was a Senior Manager but has now left the firm. Given that she has left the firm she is no longer a “User” of the Corterum system. However, we need to retain information about Jane (e.g. in order to be able to respond to a regulatory reference request or if new information about Jane subsequently comes to light which requires us to amend an old regulatory reference). As such, a “Jane Smith Person Entity” is still required (albeit it will be ‘disabled’ so that we are not charged for it).

Jim Jones - Ancillary Staff Administrator

Yes

No

Jim is responsible for SM&CR data input into the Corterum system. However, Jim is not himself subject to the SM&CR (Jim has been classified as “Ancillary Staff”).

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