On 20 March 2020, the FCA published a new web page in which it set out the steps firms should take to help identify key workers in financial services.
The FCA states that firms themselves are best placed to decide which staff are essential for the provision of financial services. However, to identify essential staff, firms should first identify the activities, services or operations which, if interrupted, are likely to lead to the disruption of essential services to the real economy or financial stability. Firms should then identify the individuals that are essential to support these functions. Firms should also identify any critical outsource partners who are essential to continued provision of services, even where these are not financial services firms. The FCA recommends that the Chief Executive Officer Senior Management Function is accountable for ensuring an adequate process so that only roles meeting the definition are designated.
The FCA adds that firms should consider whether they should issue a letter to all individuals they identify as key workers that clearly identifies them as such and that can be presented to schools on request. The FCA recommends that the letter includes the sentence “the individual has been designated as a key worker in relation to their employment by [firm name]” and is signed by someone with appropriate authority.