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And just who the hell is the CSSF? - The Paranoid Android
...musings of a mechanically depressed robot...
And just who the hell is the CSSF?
Nothing ever goes to plan. Sometimes the deviations are minor, and the plan "works" albeit not perfectly. Sometimes the deviations are so major it's deadly.

The project that all testing was signed off last Wednesday has hit a stumbling block. I guess if I am going to use a metaphor, it's more like hitting a train coming in the opposite direction. We're not just stumbling, we are hurtling backwards at a pace unknown to unassisted bipeds. The oncoming train is in the shape of the CSSF. I have no idea who the hell these guys are, but I'm guessing they are the Luxembourg equivalent of the FSA. As part of the project we intend on moving the data processing function from Luxembourg to the UK. To do this we need the CSSF's approval. Even though we've been planning this project for the best part of a year, perhaps more, we do not actually have said approval.

We were due to "go live" By the end of this week.

Now, when your plans go this wrong there are a couple of ways of dealing with it. The first, and most predominant way would seem to be finding someone to blame whilst running around like the proverbial headless chicken. This course of action has been in effect for most of this morning.

The second, and if I may say so, more intelligent course of action would be to find a solution that is a compromise, leaving the majority of people with a good feeling, especially the regulators because you never want to mess with them. See I had an idea. It was a good idea. It is not without it's difficulties, but it has at least a hope in hell's chance of success.

There are four groups of people with an interest in this project. There are the "users", the "regulators", the "project team", and finally the "management".

The users don't really give a shit what system they are using providing it doesn't cause any more work. The regulators want us to be using the old system until they give us permission to do otherwise. the project team just want to get the job done with the least amount of additional stress. The management want the project finished by the arbitrary date and time they set with no knowledge of either the work involved or the problems to be encountered. They like deadlines to be met, they dislike late implementations, they don't care for "reasons".

My idea: Convert as planned... (wait for it) *BUT* don't stop using the original system. The Luxembourg team continue to use their current procedures. The CSSF are happy because we are not moving the data processing out of Luxembourg without their approval. Two happy parties, just two more to go.
We mirror every entry entered into the original system in the new system. With minimal extra work I can convert each posting and the project team can load them either daily of in batches once a week. As far as the management is concerned, we have converted, and therefore met our deadline.

That just leaves the project team. We'll have extra work to do (not a great deal) but at least we will not have been tarred with the brush of failure. The months of work will not have been in vain.

My idea is currently being discussed with those people who make the decisions... but it's looking good.

Current Mood: a large weight on my shoulders

5 comments or Leave a comment
teya_uk From: teya_uk Date: September 30th, 2003 01:28 am (UTC) (Link)
I thought the processing and data was still being maintained in Lux! And that the only client data sensitivity issue was on the Cutas side, which was being fixed! Yes CSSF are the equivalent of the FSA .. but a tad more irrational! And the reason why when we were having the discussion in the moons one evening I said it would be almost impossible to transfer transactional handling to Romford rather than Lux ... ffs ... I've had to sign secrecy clauses and everyfink!
paranoidandroid From: paranoidandroid Date: September 30th, 2003 05:14 am (UTC) (Link)
The data processing is seem (by the CSSF) to be wherever the server is located. So while the same people will be doing the work, the data processing will have moved from the Lux server to one in Bournemouth.

You are right about being irrational. I am surprised they (the Lux authorities) can get away with what are effectively anti competition practices.
teya_uk From: teya_uk Date: September 30th, 2003 06:13 am (UTC) (Link)
It's the only thing that keeps the banks there - there isn't really a whole lot more to Luxembourg than the banking industry.
I thought the data was already held in servers in Bournemouth and that exception had been approved, obviously not!
paranoidandroid From: paranoidandroid Date: September 30th, 2003 08:04 am (UTC) (Link)
There was a general consensus that the data was already held in Bournemouth, but that proved to be false! The truth of the matter is they have their own box in the lux office.

We're not entirely sure who originally said that the data was already stored in Bouremouth, and no Monday there was the beginnings of a witch hunt for said person, but luckily we are now concentrating on solving the damn problems rather than finding the guilty.
teya_uk From: teya_uk Date: September 30th, 2003 08:23 am (UTC) (Link)
Ahh .. the joys of data secrecy laws
5 comments or Leave a comment