As part of the FCA’s Future of Data Collections (FDC) strategy, a transformation programme was launched in 2018. To help deliver the programme, Sopra Steria was chosen by the FCA to replace the Gabriel system with the new RegData platform.
The aim was to make the regulatory data submission process easier for all 52,000 firms and over 120,000 users, while giving the FCA better capabilities and capacity to collect, manage and process complex regulatory data.
Understanding the Challenge
As part of the transformation programme, one key area of change identified was the replacement of the Gabriel platform.
Gabriel had been in existence since 2008 and was at the heart of the FCA’s operations. Firms and users who used Gabriel to submit data ranged from large multinational banks who provide daily reports, to smaller organisations who submit information
once a year.
The reasons for change were clear – a need for a user-centric cloud-based solution.
The Gabriel platform was built in a physical data centre and many firms and end users were finding it difficult to submit the required information within the existing platform. If the FCA didn’t replace the Gabriel platform they were in danger of
losing the trust of firms and end users. Additionally, FCA employees wanted access to real time information and reporting so quicker decisions could be made.
Sopra Steria’s involvement in the FDC programme started in April 2020, initially to support Service Design, Service Readiness and Operational Acceptance Testing. This later expanded to include the critical matter of data migration.
With these challenges to contend with as well as the actual delivery of a large-scale migration, the right solution, working approach and leadership were required.
The Sopra Steria and FCA teams quickly agreed how they would work together and share information.
JAGPAL JHEETA, Head of Regulatory Systems, FCA
Having already worked together for over 10 years across a range of programmes, the FCA had confidence that Sopra Steria had the underlying knowledge and experience to successfully migrate the data from Gabriel to the RegData platform.
The scope of work included:
- Understanding the Gabriel platform and the vision for the new RegData platform
- Moving data from a physical data centre to a cloud-based environment
- A full and resilient migration plan
- Service design for the new platform as well as creating service experience benefits required by the FCA
- Making sure when data was migrated that it was accessible, safe and secure
- Acceptance testing after migration to ensure any problems which had occurred could be identified and rectified
- Capturing lessons learnt from each migration phase for continuous service improvements
Programmes of this scale and magnitude had never been previously undertaken or delivered against this challenging backdrop of Covid and Brexit. It was crucial that the FCA and Sopra Steria worked as ‘one team’ for a successful migration, testing and implementation so the right service delivery could happen.
SHONA BROWN, Executive Client Director, Sopra Steria
We knew that migrating away from the Gabriel platform would be a challenge. Keeping the reporting facility live for firms throughout was critical. We were impressed with how Sopra Steria successfully migrated historic data across, while ensuring a reliable and resilient platform was always available for our users.
MATTHEW TYRRELL, Senior Manager/FDC Programme Accountable Executive, FCA
Collaboration was key. It wasn’t just the FCA and Sopra Steria teams who had to be aligned. As this platform change was going to affect other underlying systems and processes, over 180 other people employed across five different technology suppliers
were also brought into the collaboration. The key was making sure regular meetings took place, but not just concentrating on the tasks in hand. The meetings were specifically designed to be agile in their approach, making sure everyone had a deep
understanding of the objectives at each migration phase.
Obviously to migrate such large volumes of data in one go would have been an impossible task and would have potentially left the FCA open to a range of operational risks. Therefore, it was decided to undertake the migration incrementally.
- Incremental approach
Before starting a migration, the FCA, its technology suppliers and Sopra Steria worked together to make sure all the data records in that phase were accurate. This involved testing the data on the Gabriel platform and then again after the
migration. This was to ensure consistency and to make sure no records were lost or damaged along the way.
By adopting this incremental approach, the teams could quickly identify if anything had gone wrong and undertake steps to rectify any problems. Only when data had been fully tested were firms and users invited to use the new RegData platform.
- Phased cohorts
The successful managing of firms throughout the migration ensured that the regular reporting cycles weren’t impacted. Firms were added to particular cohorts for migration based on their reporting needs and the complexity of data processed.
As functionality was being deployed to RegData in phases, it was important to only migrate firms to RegData if all the functionality they needed was available.
Code for more complex data and reporting was introduced iteratively so larger firms were the last to migrate from Gabriel to RegData. The success of the migration was also down to careful planning to avoid undertaking migrations around peak
data submission periods.
- Concurrent systems
As Gabriel was continuing to run alongside RegData, it was critical that any Gabriel changes during the Programme timescales were also reflected in RegData at the same time. The team at Sopra Steria held
regular touchpoints with the team at the FCA to support both Gabriel and RegData concurrently as migrations were completed.
The data migration process evolved as lessons were learnt from each previous migration. This avoided repeated
errors, improved the user onboarding process and ensured a faster, repeatable migration event.
The Key Outcomes
Results from the new platform have been really positive with users commenting that it’s faster and easier to use.
Additionally, any problems users encountered following the migration have been fixed quickly. It’s now much easier for the FCA to scale to meet user demands because the platform has been built with flexible technology.
The new platform infrastructure gives real time insights and reporting, making it quicker and simpler to fix issues and make improvements to the user experience.
The main benefits for the FCA include:
- Lower operational running costs. The platform is now in the cloud and on a more stable architecture making it easier to manage, maintain and make upgrades.
- The RegData platform can cope with any sudden increases in demand. As the platform is now built on cloud technology, the platform is no longer constrained by being housed in a physical datacentre.
- The UX design enables users and firms to submit their regulatory submissions more quickly and to have visibility of all their historical records.
The design, delivery and improved user experience of the new RegData platform has given the FCA a real opportunity to achieve its FDC strategy. As the platform matures, the FCA plans to further improve the user experience, making sure regulatory reporting
is no longer seen as an arduous task.
The improvements made via this platform migration means the FCA can demonstrate to the industry that it is a modern and collaborative regulator with users and firms at its heart.