Handling Terminated Relationships

If one of your clients terminates their business relationship with you, you still need to fulfill two obligations regarding their data:

• The AML Act establishes the record-keeping requirement for which you must store information about terminated customers for 5 years from the end of the business relationship.
• The GDPR establishes the data minimization requirement for which you must delete information about terminated customers after 5 years from the end of the business relationship.

Therefore, you need to make sure that you keep the data about terminated customers for 5 years and delete the data after that same timespan.

Penneo KYC lets you meet these requirements easily. To this end, you need to mark the client relationship as terminated in the system, and Penneo KYC will handle the rest automatically.

Navigate to that client relationship, and click on it. At the bottom of the tab, press Mark client relationship completed.

Next, set the date of termination of the client relationship. The termination date can also be back in time (days, months, or years before the day you set it up in the system).

The client relationship will then be moved to the "Terminated Client Relationships" folder, where it will be stored for 5 years and then automatically deleted.

The client relationships moved to the "Terminated Client Relationships" folder are highlighted in gray as shown below.

For the client relationships moved to the "Terminated Client Relationships" folder, you will be using Penneo KYC as a data archive. This service is included in your Penneo KYC subscription. More specifically, client relationships that you’ve marked as terminated and stored in the system (waiting for automatic deletion) are not counted as active client relationships. In other words, you do not pay for them.

When marking a client relationship as terminated, you make room to take in a new client without increasing your total number of clients. For example, suppose your subscription allows you to create 50 client relationships, and you’ve used all 50 of them. When you mark one client relationship as terminated, you will see that your number of used client relationships becomes 49 out of 50. Therefore, you can create a new client relationship in the system.