Flow's Commitment to Data Integrity and Privacy for the Private Markets
Private Market Data Dynamics
Private market investment firms have a unique relationship with data privacy.
The stakes are exceptionally high, regulatory pressure is growing - along with the operational challenges of remaining compliant, and the omnipotent risk of cybersecurity threats looms large over private investment firms for which investor trust and confidence is a top priority. Players in the private markets have enough to worry about, with bad actors, government oversight, and human error, without needing to concern themselves with trusted technology partners exploiting data for their own gain.
Consider for the following:
- Regulatory Compliance: Like many financial products and institutions, private investment firms are subject to stringent regulatory scrutiny due to the sensitive nature of the information they handle. Compliance with regulations is not only a legal requirement but also essential for maintaining trust with investors and stakeholders.
- Investor Trust: Limited partners (LPs) are the lifeblood of private funds, making their trust and confidence crucial for success. Investment firms prioritize building and preserving this trust by safeguarding sensitive data and ensuring transparent and ethical practices.
- Cybersecurity Risk: The increasing digitization of financial transactions has exposed private investment firms to cybersecurity threats. Data breaches not only compromise sensitive information but also erode investor confidence and undermine regulatory compliance efforts.
- Competitive Advantage: Confidentiality is a strategic asset in the private markets. Undisclosed investor identities, investment amounts, and specific vehicles provide investment firms with a competitive edge by preventing competitors from replicating successful capital strategies or investment positions.
- Market-Making Implications: Private market investments play a pivotal role in shaping the global economy. New technologies and industries are born - and entire markets are won - on the back of private capital.
Responsibilities of Service Providers in the Private Markets
“The practice of turning users into products is not uncommon in technology,” says Flow Co-founder Brendan Marshall, “but we firmly believe it is at odds with the foundational principles that underpin the private markets.”
Service providers in the private markets cannot ignore the gravity of their role in upholding the integrity and security of client data. They have an ethical imperative to respect the confidentiality and integrity of the data they handle. This includes implementing robust security measures, maintaining compliance with regulations, and fostering transparency in their operations.
Moreover, service providers must recognize the interconnected nature of their responsibilities. Any security breach can have cascading effects, leading to financial losses, regulatory penalties, and irreparable damage to client relationships. Therefore, service providers must not only prioritize their own security protocols but also conduct due diligence when engaging with subcontractors and other third-party vendors.
Perhaps even more important are the actions taken by service providers that fall outside of the bounds of regulatory scrutiny or even data security. Fostering a culture of ethical, transparent, high-integrity operations is also paramount. There are an increasing number of providers in the private markets seeking to leverage client data for their own gain. The decisions made by such vendors may have no legal implications, but the implications for their clients can still be massive.
At Flow, we firmly believe that our customers’ data belongs to our customers.
Flow’s Relationship with Client Data
Our platform exists to help private investment firms more efficiently manage their funds and better engage with their Limited Partners (LPs). Data, for us, is valuable only insofar as it advances those goals for our clients.
Data Collection, Control, and Consent:
From LP users, Flow only collects the data necessary for subscription documents, accreditation requirements, and KYC & AML compliance. This data is stored in a unique Investment Profile that is controlled by the LP; they can edit or delete the data themselves at any time.
From GP users, we collect legal documents, capital call data and notices, and self-reported data for Net Asset Value (NAV) and distribution reporting.
Data Usage:
To the extent Flow does leverage client data, we do so to deliver better products and services. Below are some examples of how we’re doing so on our platform today:
- Accelerated Onboarding: As mentioned above, Flow collects data from LPs during their onboarding process, which is then stored on their Investment Profiles. By maintaining this data in a structured format, we’re able to accelerate subsequent onboardings by giving LPs the equivalent of a “repeat shopper” experience.
- LP Updates: Flow prompts GPs to upload self-reported NAV and distribution data onto the platform so that LPs can have maximum visibility without pestering GPs to share this information on a 1:1 basis.
- Fund Reporting: At Flow, we aim to make your data easier to access and easier to leverage. Built-in reporting and status trackers ensure you can find and analyze your data however you see fit, and if you need access to more, the Flow data and analytics team will be happy to create customized exports.
- Compliant & Legally Binding Documents: Flow has the flexibility to collect any data point for any form from any LP; subscription documents, AML/KYC, and ongoing updates are all seamlessly converted into user-friendly workflows, which are then stamped directly on documents for auditability and record keeping.
- Workflow Efficiencies: By leveraging Organization, Fund, and Investment data, Flow can streamline the operational overhead of day-to-day fund management activities: from automating capital calls and reconciling wire transactions, to tracking side letters & fees, to providing fund accountants access to the data needed to maintain books & records.
Data Access:
Below are some details on the types of data different types of users can access on Flow. Access control mechanisms ensure that only authorized individuals can view specific types of data.
- General Partners: GPs can access their fund’s financial data and any information collected as part of the LP onboarding.
- Limited Partners: LPs can always access the details of their fund investments across multiple GPs. They can also grant access to GPs to manage their investment account, as well as revoke that access.
- Service Providers: GPs can invite third-party service providers into their Flow instance to manage different aspects of the fund lifecycle, from legal review to accounting. This access can be granted at the Organization level, or for a specific fund. This access can also be revoked at any time, making it seamless for GPs to adjust their service provider strategies.
- Team Access: GPs, LPs, and Service Providers can all create and manage teams, granting varying degrees of access, ensuring that the right permissions are granted to the right people needed to operate in a secure manner.
- Flow: Outside explicitly authorized client support purposes, Flow only looks at client data in an aggregate and anonymized way to better understand platform usage, similar to how any product platform seeks to understand adoption to create a stronger user experience.
Security Measures:
Flow places a strong emphasis on data security. The company is SOC-2 compliant and adheres to industry-standard security best practices. All sensitive information is securely stored within the Flow portal, protected by password authentication and Multi-Factor Authentication (MFA). What’s more, the platform is built atop leading infrastructure providers such as Cloudflare, AWS, and Heroku, all of which maintain strict security standards.
What We Don't (and Will Never) Do:
It's crucial to clarify what Flow does not do. Our ethos revolves around transparency, integrity, and the rigorous defense of our clients' data.
We don't directly contact Limited Partners (LPs) without notifying the General Partner (GP) and asking for consent. Even then - all communications are directly related to our platform and services, meant to ensure a smooth end-user experience.
Furthermore, Flow categorically refrains from engaging in any practices involving the sale or dissemination of LP contact data. We understand how important privacy is, so we never compromise on this principle, whether on our platform or anywhere else.
Similarly, we never sell or share information about investment positions represented on our platform. We understand the sensitivity and strategic value of this information to our clients, and we are committed to safeguarding it.
In an era where data is a cornerstone of decision-making, navigating the data landscape responsibly is imperative. Flow stands at the forefront. Our commitment is unwavering, ensuring our clients can trust us with their most sensitive information as they navigate the complexities of the private market landscape.