Key Takeaway: Employee exits from financial institutions pose significant data risks, from client records to proprietary algorithms, but they don’t have to. To prevent data leaks, proactive measures like role-based access controls, forensic readiness, and automated document review are essential. Proactive data protection strategies ensure compliance with FCA, SFC, ASIC, and GDPR regulations while protecting your reputation and ensuring client trust.

The decline of the broker protocol, a once-common agreement among banks that allowed financial advisors to take their book of business when moving firms, has transformed the risk landscape. Employee departures in financial institutions create significant vulnerabilities as they put sensitive client data, proprietary algorithms, and compliance records at risk of exposure. Today, client retention and data protection are increasingly critical concerns for financial firms.

Moreover, regulatory bodies such as the FCA, SFC, and ASIC require financial institutions to adopt comprehensive compliance strategies. Given the inherent risks involved with employee departure, integrating digital forensics, document review, and case insights is essential to protect data and reputation, minimising the risk of client loss.

Identifying Data Risks in Financial Services Employee Transitions

Minimising risks begins with identifying and securing sensitive data such as personal information, financial records, and intellectual property. It is crucial to establish controls to address common data exfiltration methods such as USB devices, personal email accounts, printing documents, ‘Bring Your Own Device’ scenarios, cloud storage platforms, and even taking photos of screens with smartphones. Controls must also evolve as new exfiltration methods arise.

Document review services utilise AI and expert teams to assess data defensibility, focusing on emails sent to oneself, friends or family, as well as potential solicitation activity. Name normalisation analysis and AI are key tools for identifying these vulnerabilities.

Case insights teams understand the challenge of identifying key facts or patterns in large datasets. Systematic document review protocols and integrated AI tools help to monitor employee emails for early risk detection. Determining who communicates with whom, and through which channels, is imperative. Analytics and AI surface this critical evidence and reveal trends.

Proactive Data Protection Strategies for Financial Institutions

To safeguard client data and other proprietary information upon employee departure, financial institutions should:

• Enforce NDAs, non-competes, and data handling policies.
• Implement role-based access controls for sensitive systems.
• Deploy Data Loss Prevention (DLP) tools tailored to financial workflows.
• Provide employee training on data governance and compliance.
• Maintain audit trails and forensic readiness.

Data risks span legal, technical, and human factors, making it crucial to take a cross-functional approach with collaboration across legal, data privacy, HR, and cybersecurity teams. Otherwise, gaps may result in missed regulatory reporting or unmonitored data access, exposing organisations to compliance violations and reputational damage. 

The Importance of Forensics, Document Review, and Case Insights

Different teams each perform multiple critical tasks:

• Forensics teams detect unauthorised access or data transfers, support investigations and regulatory reporting, and ensure the use of best practice methodologies and industry-standard forensic tools. Peer-reviewed reporting ensures defensibility.
• Document Review Services provide rapid, defensible review of collected data, identify and protect privileged and sensitive information, and deliver audit-ready reporting for litigation and regulatory needs.
• Case Insights teams conduct Early Case Assessment (ECA), identify key documents and communicators, and reduce data volume to minimise review costs and focus on relevant evidence.

Post-Departure Workflow: Securing Data Post Employee Departure

Immediate Actions

Upon employee departure, organisations must act quickly to secure sensitive information and maintain compliance. The first step is to secure all devices and storage media to prevent unauthorised access. Access to financial systems and databases should be revoked immediately, and audit logs along with cloud activity must be preserved for review. 

Compliance-driven exit interviews play a critical role in this process. These interviews should include a managed review of selected data, guided by AI and expert oversight. Techniques such as name normalisation help identify connections to friends, relatives, and personal domains. This enables teams to aggregate and review documents for signs of misappropriation or solicitation. 

ECA tools identify key facts and potential risks. The process typically begins with a client questionnaire, focusing on essential questions to quickly surface high-priority documents.

Investigation Process

The investigation phase involves acquiring evidence from financial systems, cloud platforms, and encrypted storage. Analysts examine file access logs, email and chat history, browser and download records, USB activity, deleted file activity, and metadata to uncover potential data exfiltration.

A scoping call is essential at this stage to define and, where possible, limit the scope of the investigation. This is followed by a detailed forensic analysis to determine what information may have been taken.

Post-Investigation Support

After the investigation concludes, organisations should implement remediation measures to address any gaps in data governance. Collaboration with legal and compliance teams ensures that corrective actions align with regulatory requirements. 

Continuous improvement of data protection protocols reduces future risks and strengthens organisational resilience.

Best Practices

Organisations should act within 24 to 48 hours of an employee’s departure to minimise exposure. Partnering with providers experienced in financial data investigations, review, and analytics accelerates the process and improves accuracy.

Structured exit interviews, device return procedures, and access revocation should be standard practice. Non-disclosure agreements must be reviewed and enforced, and all compliance steps documented. Disabling accounts, monitoring unusual activity, and implementing DLP alerts are essential safeguards. Leveraging AI review protocols enhances speed and accuracy, while analytics help detect insider threats and emerging trends early.

Remote work, cloud-based platforms, insider threat modelling, and the rise of AI introduce new risks. AI tools, whether used internally or externally, can become points of leakage for sensitive data. To mitigate these risks, companies should prohibit the use of external AI tools and ensure that employees only use approved internal AI solutions that meet organisational security and governance standards.

Safeguarding Sensitive Data

Protecting financial data during employee transitions requires both proactive and reactive strategies. By integrating forensics, document review, and case insights, financial institutions safeguard sensitive information, comply with regulations, and minimise reputational risk for clients.

Learn more about Epiq Departing Employee Risk Analysis services. 


Charlie Abbate, Director, Financial Services Practice Group
During his time at Epiq, Charlie has overseen over a thousand engagements for financial services industry clients and has helped to develop various bespoke workflows. Charlie is a Relativity Certified Administrator, AI Pro, and is Blackout Certified.


Bryant Dean, Associate Director
Bryant has extensive experience in various phases of eDiscovery, from Early Case Assessment (ECA) to review management. Bryant enjoys finding innovative solutions to unique problems, utilising a wide range of technologies.


Erwin Risher, Senior Forensic Consultant
Erwin’s background includes extensive experience in large-scale forensic projects, civil and criminal casework, and formal training for military investigators and lawyers. Erwin holds multiple industry certifications and currently serves as Chair of the Forensics Committee for the Scientific Working Group on Digital Evidence (SWGDE).