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UK financial services · Public-content screening

Proportionate social-media screening for defined risk—not blanket monitoring

Review relevant publicly available content for defined roles or trigger events—with human verification, protected-data controls and an evidence trail for your decision.

  • Public content onlyRelevant publicly available content for a defined role or trigger
  • Human-reviewedHuman verification and protected-data controls
  • Decision support, not a decisionAn evidence trail for your decision

Trusted by

Michigan State UniversityViacomCBSSotheby's International RealtyTitan Growth

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Walk through the evidence, source context and protected-data controls that should support a proportionate review process.

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Where it fits

Use screening where the role or event justifies it

A good screening programme defines the reason, scope and decision standard before collecting public information.

Screening should be necessary for an identified risk, transparent, fair and proportionate. See the ICO’s current draft vetting guidance.

A defined, risk-based assessment

  • A sensitive appointment with a documented risk rationale
  • A credible conduct trigger requiring proportionate fact-finding
  • A fitness-and-propriety review tied to specific role standards
  • A consistent policy that is communicated to the person
  • A review with an appropriate response and correction process

Routine or curiosity-driven monitoring

  • Monitoring the entire workforce because the data is available
  • Looking for political, religious or other protected attributes
  • Using an automated score as the employment decision
  • Investigating information with no role or conduct relevance
  • Keeping reports without a defined retention purpose

Evidence

Evidence, context and controls—not a black-box score

A reviewer should be able to understand what was found, where it came from, what was withheld and what judgement still belongs to the firm.

How it works

A scoped review from policy question to evidence record

The final employment or regulatory decision remains with the authorised people in your firm.

01

Set the purpose

Document the role, trigger, lawful basis, review criteria and retention period.

02

Verify identity

Resolve public profiles carefully so information is not attributed to the wrong person.

03

Assess public content

Apply the defined criteria while retaining source context, date and evidential detail.

04

Limit exposure

Withhold protected or irrelevant information from the decision view where the process allows.

05

Use human judgement

Review the evidence, invite context where appropriate and record the firm’s own rationale.

Controls

Design the review to minimise irrelevant exposure

Technology can support a controlled process, but it does not replace lawful-basis, policy, transparency or human accountability.

Restricted decision view

Configure the process so reviewers do not receive unnecessary protected or irrelevant detail simply because it appears in a public source.

Documented criteria

Define the conduct and role criteria before review. Preserve which criterion was applied and why a finding reached the report.

Context and correction

Keep source context available and give the person an appropriate way to explain, challenge or correct material information.

Controlled retention

Retain the report and evidence only for a documented period aligned to your policy, legal obligations and the purpose of the assessment.

The method

The method matters as much as the source

Public information does not become fair, relevant or reliable merely because a manager can find it in a browser.

The method matters as much as the source
ControlAd hoc manager searchConfigured review workflow
PurposeOften implicit or undocumentedDefined role, trigger and criteria
Protected informationVisible directly to the decision-makerDesigned to restrict irrelevant exposure
Identity and contextReviewer-dependentHuman verification and source context
ConsistencyVaries by manager and searchConfigured criteria and review record
Audit trailBrowser history or notesEvidence, source, date and rationale
Person’s contextMay be requested late or not at allResponse step built into the firm’s process
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PS25/23

Use the rules to define the question—not to justify surveillance

PS25/23 changes how specified misconduct can engage COCON and informs FIT, but the FCA explicitly says firms need not monitor private lives or social media.

Read the practical FCA guide

Define the regulatory relevance

Identify the COCON, FIT or people-risk question and the evidence needed to answer it.

Apply materiality and reliability

Do not treat an allegation, opinion or isolated signal as a conclusion without context.

Keep the firm accountable for the decision

The report supports analysis; it does not determine fitness, discipline or employment outcome.

The record

See what the decision-maker should receive—and what they should not

Walk through the evidence, source context and protected-data controls that should support a proportionate review process.

Request a screening workflow review

Walk through the evidence, source context and protected-data controls that should support a proportionate review process.

Request a screening workflow reviewReview the workflow

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