Compliance Settings

Settings > Compliance is where the firm decides how its barriers and access log behave, and where the person who reviews that setup records the review. It has four parts: the last review, the firm's settings, ORCA support access, and a panel describing how ORCA works for every firm.

Every setting starts where ORCA starts, which is how ORCA behaved before this page existed. A firm that never opens the page sees no difference. Every change on the page goes on the access log, whether or not the log is switched on.

The page records what the firm chose and who reviewed it. It doesn't say the setup meets any set of rules. That judgement stays with the firm.

Who Can Open It

The page sits beside Access log in the Settings menu. It opens for anyone who can open Settings, and for anyone whose role holds the Compliance permission, unless the firm keeps the log to Compliance (see below).

The Compliance permission is a tick box inside a role, labelled Access compliance. Open the role in Settings > Staff > Roles to tick it (see Accounts & Users). Nobody holds it until the firm gives it to a role. Someone who holds it but can't open Settings sees just Access log and Compliance in the Settings menu, and a Compliance link in the sidebar.

The Last Review

The top card, The last review, says who last reviewed the setup, their role, the date, and the rules they read it against, with any note they left. Until someone records one, it reads "Nobody has reviewed this setup yet."

Below that, ORCA compares the setup now with the setup at that review:

If anything has changed, a box headed Changed since the last review lists each difference in words, for example "Who can change a deal team: now Only people with the Compliance permission, was Anyone who can edit the record." Barriers switched on, changed or taken down are listed too.
If nothing has, it reads "Nothing on this page, and no barrier, has changed since."

Earlier reviews are listed under Earlier reviews, newest first. A review can't be edited or removed.

Recording a review

Read through the firm's settings and the How ORCA works today panel.
Under Record a review, fill in Your role (for example, Head of Compliance) and Rules you read it against. The rules box offers a few suggestions, or type your own, such as "Not regulated".
Add a Note if you want one.
Press Record my review.

ORCA saves your name, the date, what you typed, and a copy of every setting and every barrier as they stand at that moment. That copy is what later changes are measured against. The review also goes on the access log as Signed off the setup.

Only someone with the Compliance permission can record a review. Until anyone in the firm holds it, someone with Settings can. ORCA support can't record one.

The Firm's Settings

Choose, then press Save settings. Each change is written to the access log as Changed a compliance setting, one line per change, saying what it is now and what it was.

Who can read the access log and change these settings

Anyone with Settings, with every name shown. Where ORCA starts. Anyone who can open Settings, or who holds the Compliance permission, can read the log, with every record named.
Anyone with Settings, with barred names hidden. A line about a record behind a barrier reads "A record you can't open" to anyone not on that record's team, and its detail is left out. That applies on screen, in the CSV download, and in the review report and export alert emails.
Only people with the Compliance permission. Only they can read the log and open this page. Changing a section's barrier then needs the permission too. An administrator without it can't read the log, change these settings or switch this back.

Under the choices, the page names everyone who holds the Compliance permission now. If nobody does, it reads "Nobody holds the Compliance permission yet. Before choosing the last option, open a role in Settings > Staff > Roles and tick "Access compliance"." You can't choose the last option until someone active holds it: saving it refuses with "Nobody active holds the Compliance permission yet. Open a role in Settings > Staff > Roles and tick "Access compliance" first, so the firm can still open its log." That stops a firm locking itself out of its own log.

If you choose the last option without holding the permission yourself, saving takes you back to the dashboard with "Saved. Only people with the Compliance permission can open the Compliance page and the access log now."

Deal teams

Who can change who is on a record's team, in a section with a barrier.

Anyone who can edit the record. Where ORCA starts.
Only people with the Compliance permission. Whoever creates a record still sets its first team. After that, anyone else who changes the team is refused with "Only people with the Compliance permission can change who is on a deal team here. Nothing was saved." Their edit form says so above the fields, and everything else on the record saves as usual.

Tick Ask for a reason when someone joins or leaves a team and the record's edit form gains a box, "If you change the deal team, say why". A team change saved without a reason is refused with "Say why the deal team is changing. The reason goes on the access log. Nothing was saved." With the access log on, the reason goes on the Changed the team line.

Both rules apply however the team is changed: the edit form, a cell in a list, the API or an import.

ORCA support on barred records

Can open them, and each view is logged as ORCA support. Where ORCA starts. With the access log on, each view is marked ORCA support.
Only while the firm has granted access. Without a grant, ORCA support meets the barrier like anyone else, seeing only what the roles we hold in your account allow. See Granting ORCA support access.

If the log can't be written

Barred records don't open. Where ORCA starts. If ORCA can't write the access log line for a barred record, the record doesn't open. Every other page opens and we are alerted.
No record page opens until the log can be written again.

Either way, the person sees "This record could not be opened just now. Please try again." This matters only while the access log is on. The page says whether it is on now.

Review report

An email covering the period's refused attempts, deal team changes, barrier changes, exports and downloads (a count, with the largest), ORCA support views, and changes on the Compliance page and to the log. It ends with the last review and anything that has changed since, and links to the access log for the period.

Off. Where ORCA starts.
Weekly. Sent on Mondays, covering the seven days before.
Monthly. Sent on the 1st, covering the month before.

Both go out in the morning, in your account's time zone. Under Send it to, tick who gets it. Only people who can read the access log are listed, and if the firm keeps the log to Compliance, the email goes only to those who hold it. Each person gets their own copy, with barred names hidden from them if the log would hide them.

Each list in the email shows up to ten lines, then says how many more are in the log. If the access log is off, the report covers only what ORCA always writes down: barrier changes, changes on the Compliance page, and the log's own switch.

Export alert

Tick Email the people below whenever someone exports from a section with a barrier to hear about each export as it happens: a list, a report, totals, a PDF or the whole account. Then:

And for any export over this many rows (optional): also send an alert for any export, from any section, with more rows than this.
Tell: tick who gets the alerts. The same people are listed as for the report.

The email is headed "An export to know about". It says who exported what, from which section, and why it was sent, with the record and detail where there is one (hidden, as on the log, from anyone not on a barred record's team). Alerts are sent whether or not the access log is on. An alert never stops an export: if the email can't be sent, the export carries on and we're told.

Granting ORCA Support Access

When ORCA support on barred records is set to Only while the firm has granted access, an ORCA support access card appears below the settings.

With no grant, it reads "ORCA support can't open barred records now. If we need to, to help with a problem, we'll ask, and someone here grants it."
Press Grant for 1 day or Grant for 7 days to let us in. The card then says until when, and that each view is logged.
Press Withdraw now to end a grant early. A grant also ends by itself when its time runs out.

Granting and withdrawing are always written to the access log, as Let ORCA support in and Withdrew ORCA support.

ORCA support can read the Compliance page, so we can see how your account is set up when you ask for help. We can't change any setting, grant ourselves access or record a review. Those choices are the firm's.

How ORCA Works Today

The last card isn't settings. It describes how ORCA behaves for every firm, so a review can take it into account:

Who sees every record behind a barrier. Each barred section, who it's limited to, and which roles see every record in it, with a link to the barrier. Being an administrator doesn't open a barred record.
Whose history suggestions read. Each relationship with counterparty suggestions on, and whether it uses "Only what they can open" or "Firm memory, no names".
What counts as a view, and what isn't logged. See What Gets Logged.
How long the log is kept: with no end date. Nobody can edit or remove a line, and there is no tamper-evidence beyond our normal backups.
Integrations: API keys can't read barred records, and webhooks don't send them.
What someone outside a team sees: "not found", and "A record you can't open" where an open record links to a barred one.
What a barrier does not cover. The same limits as What a Barrier Doesn't Reach, plus one more: a company's "last in touch" date can reflect an email filed on a barred record. The date only, no content.
What we can provide in writing: a UK GDPR data processing agreement, with our list of sub-processors and our breach procedure, and written answers to the firm's security questionnaire.

People in Compliance Roles

When the firm chooses Only people with the Compliance permission for the access log, the permission is what lets anyone in. So only someone who holds it can change who holds it:

Only a holder can put someone into a role that carries the permission, or take them out of one. That includes inviting someone new. If anyone else saves a user, that person's Compliance roles stay as they were, and the rest of the save goes ahead.
Only a holder can tick or untick Access compliance on a role in Settings > Staff > Roles. Anyone else's save leaves it as it was.
Only a holder can make another holder inactive, or remove them.
Nobody can leave the firm without a holder. Taking the last active holder out of their role, making them inactive or removing them is refused, with a message naming them and asking you to give the permission to someone else first. Taking the permission off the only role that carries it is refused the same way.

Whatever the firm has chosen, ORCA always writes to the access log, as Changed who holds Compliance, when the permission is given to a role or taken from one, when someone joins or leaves a role that carries it, and when a holder is made inactive or active again.

In the Demo

The Ardlow & Penn demo has the page filled in. Gillian Moore, Head of Compliance, holds the permission and has recorded a review. The firm's choices are that only Compliance changes deal teams, a reason is asked for, ORCA support needs a grant, and Gillian gets a monthly review report. Nothing on the page saves in a demo, and no report or alert is sent.

Barriers : limit each record to the people working on it
Access Log : who opened and exported which record
Accounts & Users : roles, and giving a role the Compliance permission
Counterparty Suggestions : whose history suggestions read
Data Export : the whole account as a zip of CSVs