Personally addressed
The information is provided to the individual customer.
Customer portals & Durable Medium
Keep the portal for active service. Don’t turn it into the permanent archive.
Your customer portal can be a Durable Medium. But relying on it for the customer's permanent document record creates a long-term infrastructure obligation that goes far beyond displaying documents online.
Documentd separates permanent document delivery from the live customer portal, so the portal can keep doing the job it was built for.
No portal replacement required. No major transformation project required.
Start with the regulatory position
A secure customer portal can be a Durable Medium
The FCA says an interactive secure website can constitute a Durable Medium when the relevant characteristics are met. The information must be personally addressed, remain accessible in future, and allow unchanged reproduction of information from previous periods.
Accessible later
The customer can return to it for an adequate period.
Reproduced unchanged
The information originally supplied can still be reproduced in the same form.
So the question is not whether a portal can do the job. It can.
The commercial question is whether you want the live customer portal to carry that long-term responsibility.
Read the FCA guidanceTwo very different jobs
A live service portal and a permanent document record are not the same thing
Customer portals are usually designed to show what is true now. Durable documents preserve what the customer was given at a particular point in time.
Customer portal
Live information & interaction
The account changes, balances move, transactions complete, forms are submitted and current information is updated.
- Designed around active customers
- Information naturally changes
- Authentication supports live service
- Technology is expected to evolve
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Durable document record
Point-in-time information the customer keeps
The important thing is precisely that the record does not change after it has been supplied.
- Designed around historic access
- Settled information remains unchanged
- Access may outlast the active relationship
- Records must survive future system changes
A portal is excellent at serving the active customer.
That does not automatically make it the cheapest place to maintain the
customer's permanent document history.
The hidden infrastructure obligation
Making the portal the permanent copy changes what the portal has to support
Long-term document access is not mainly a storage problem. It brings retention, identity, support, migration and control requirements into the portal architecture.
Historic document retention
Previously supplied information must remain available for as long as the applicable requirement demands.
Unchanged historic versions
The portal needs to preserve what the customer was actually given, not simply show the current version.
Former-customer access
If customers still need their documents after the relationship ends, the access model has to accommodate them.
Long-term authentication
Password recovery and identity processes may need to continue for people who no longer have an active account.
Migration continuity
Portal replacements and migrations have to preserve historic access and document integrity.
Deletion and change controls
Operational processes must not silently overwrite or remove the settled information customers are meant to retain.
Where the cost really comes from
The expensive part is not storing the PDF
Storage is cheap. The continuing operational environment around the document is what creates complexity.
Former customers still need a way back in
Authentication, account recovery and identity controls can remain necessary long after the active service relationship has ended.
Legacy access becomes a servicing obligation
Someone still needs to handle forgotten credentials, old accounts and requests for historical information.
Every future portal change inherits the archive
Redesigns and migrations must preserve historic documents, access rights and unchanged versions.
Old accounts extend the attack surface
Keeping legacy user access alive can extend identity-management and security responsibilities beyond the active relationship.
The issue is not: “Can our portal store documents?” The issue is:
“Do we want to maintain the whole access environment around those
documents for as long as they need to remain available?”
A simpler architecture
Separate active service from permanent document delivery
Documentd lets each system concentrate on the job it does best.
Live services, account information and transactions.
Important point-in-time documents the customer should keep.
Your existing systems communicate and service the customer. Documentd delivers the important documents they need to keep.
The right tool for the right information
Keep live information in the portal. Deliver settled documents separately.
Documentd is not intended to replace the portal or duplicate everything inside it. Use it selectively where the customer should receive their own point-in-time record.
Keep in the portal
Live information & service
- Live balances and valuations
- Transactions
- Tasks and forms
- Secure messaging
- Current account information
- Interactive reporting
- Service requests
- Profile and account management
Deliver with Documentd
Important point-in-time records
- Statements
- Agreements
- Policy documents
- Terms and conditions
- Regulatory notices
- Tax documents
- Confirmations
- Other important point-in-time records
Documents can still appear in the portal for convenience. Documentd simply gives the customer a separate long-term copy that does not depend on the portal remaining their archive.
The account-closure test
What happens to the documents when the customer leaves?
This is where the difference between an active portal and a permanent document record becomes clearest.
The business may reasonably want to close the operational account when the relationship ends. But the customer may still need statements, agreements, tax documents, notices or other records that were supplied during the relationship.
The customer should not need permanent access to your operational system simply to keep documents they have already received.
Read the detailed portal and Durable Medium guideNo portal redevelopment required
Add the delivery layer without rebuilding the customer experience
Documentd can sit alongside the portal you already have. You do not need to turn the portal itself into a different product just to give customers a permanent document copy.
Keep the portal
Leave live servicing, transactions and account interaction where they already work.
Identify the documents customers need to keep
Separate important point-in-time documents from live information that naturally changes over time.
Add Documentd as the delivery layer
Deliver those documents into the customer's own Keepd space. Integration can be as light or as automated as you need.
Start manually, use existing email workflows, or integrate through the API for automated delivery. The portal itself does not have to become the permanent archive.
Try Documentd freeA simpler Durable Medium architecture
Keep the portal. Give the customer their own permanent copy.
Use your portal for the live services customers need while the relationship is active. Use Documentd for the important documents they should be able to retain, review and retrieve later.
About regulatory requirements
A customer portal can constitute a Durable Medium where the relevant conditions are satisfied. Some FCA rules also permit information to be provided through a website that does not itself constitute a Durable Medium, subject to separate website conditions.
Whether a particular communication satisfies an applicable regulatory requirement depends on the rule, the information being provided and the way the delivery process is configured. Documentd is designed around the characteristics identified in the FCA definition and guidance; firms remain responsible for determining the requirements applying to their own communications.
FCA Handbook definition of Durable Medium