Electronic communications include:

• Fax;
• Email; and
• Instant messaging.

A firm must also take reasonable steps to prevent communication that utilizes privately-owned equipment that the firm is unable to monitor and capture.

There is a carve out for discretionary investment managers in respect of communications with firms or person subject to the recording obligations in COBS 11.8.5R.

Reasonable steps must be taken to retain all records for a period of at least 6 months. The records must be stored in medium that:

• Is readily accessible;
• Tracks any changes made; and
• Cannot be manipulated or altered.