CQS Practice Standard · Section 3.2

CQS (CPMS) Information Management and Security Policy

The recent update to the Core Practice Management Standards (CPMS) requires CQS firms to have a policy in place in relation to Information management and security (s3.2).

Policy documents can be time-consuming and difficult to prepare.

Aligned to CQS CPMS Section 3.2 Last updated 2026-10-13 Maintained by Lexsure

What the policy covers

52 sections in the current version.

  • Document Properties
  • Change Control
  • Associated Policies
  • 1 Introduction
  • 2 Responsibilities
  • 3 General Data Protection Regulation (GDPR)
  • 3 1 Overview
  • 3 2 Data Protection Principles
  • 3 3 Grounds for Processing Personal Data
  • 3 3.1 General
  • 3 3.2 Client Personal Data
  • 3 3.3 Employee Personal Data
  • 3 3.4 Provision of Information to Data Subjects
  • 3 4 Sensitive Personal Data
  • 3 5 Purposes of Processing Personal Data
  • 3 6 Categories of Individuals Whose Personal Data is Processed
  • 3 7 Recipients of Personal Data
  • 3 8 Categories of Personal Data Processed
  • 4 Information Risk Management
  • 5 Information Asset Register
  • 6 Information management principles
  • 7 Collection and distribution of data
  • 7 1 Collection and use of data
  • 7 2 Distribution of data
  • 8 Storage retention and disposal of information assets
  • 9 Intellectual property of others (copyright)
  • 10 Confidentiality and the authorisation for disclosures
  • 11 Information security threats
  • 11 1. Scope
  • 11 2. Types of threats
  • 12 Information security measures
  • 12 1 Backup of Data
  • 12 2 Physical security of paper-based records
  • 12 3 Use of USB drives
  • 12 3.1 Physical security of IT equipment
  • 12 4 Procedures for detecting and removing malicious software
  • 12 5 Preventing the misdirection of emails
  • 12 6 Preventing the misdirection of paper records
  • 12 7 Dealing with enquiries
  • 12 8 Use of firewalls
  • 12 9 Management of user accounts
  • 12 10 Information security and data protection training
  • 12 11 Bank account security
  • 12 11.1 Receipt and transmission of bank details Transmission of bank details · Checking bank details of other Conveyancers and third parties
  • 12 11.2 Spoof transfer requests
  • 13 Register of software
  • 14 Data Subject Access Requests
  • 14 1 General
  • 14 2 Fees
  • 14 3 Procedure
  • 14 4 Unfounded and excessive requests
  • 15 Cybercrime prevention procedures
  • 15 1 User Level Prevention
  • 15 2 ‘Senior Personnel/Business’ Prevention
  • 15 3 Cyber Threat Report Guidance

The Information Management and Security Policy includes reference to:

  • General Data Protection Regulation (GDPR)
  • Information Risk Management
  • Information Asset Register
  • Collection and distribution of data

...as well as other formalities and general obligations as required under 3.2 of the CPMS.



Latest updates

Own an earlier version? Buy only the paragraphs that have changed. Each paragraph arrives by email as a PDF as soon as you pay.

12 October 2026

Latest Policy Paragraphs, October 2026 1 paragraph
Conveyancing Portals and Controlled Information Sharing (update)

Additional section Introduces controls for approved conveyancing portals, authorised information sharing and timely downloading of documents. It also assigns responsibility for document review and portal notifications, reflecting the proposed Conveyancing Protocol.

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16 September 2026

Latest Policy Paragraphs, September 2026 1 paragraph
Safe and Responsible Use of Artificial Intelligence

The SRA’s warning notice last month highlights inaccurate AI-generated material, inadequate supervision and the disclosure of confidential client information to systems without appropriate safeguards. Firms with existing AI governance provisions should update them to refer expressly to the warning notice and confirm that AI use does not displace individual professional responsibility or the requirement for human verification

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20 August 2026

Latest Policy Paragraphs, August 2026 1 paragraph
Wearable Recording Technology

The use or wearing of audio/video-capable smart eyewear, covert devices, or unapproved wearable technology is strictly prohibited during all client meetings, internal discussions, and on firm premises without express prior written authorisation. Any unauthorised recording produced during the course of firm business constitutes a material breach of confidentiality and data security protocols.

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13 July 2026

Latest Policy Paragraphs, July 2026 1 paragraph
Generative AI Governance (Update)

Generative AI introduces severe data security and professional conduct risks that require urgent updates to your firm's internal procedures particularly your Information Management and Security Policy

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18 February 2026

Latest Policy Paragraphs, February 2026 1 paragraph
AI-Enhanced Phishing and Voice-Cloning Defenses

To mitigate escalating AI-generated spoofing risks, these updated procedures prohibit altering bank details based solely on telephone or video calls. Mandatory three-factor verification,utilising secure portals, physical mail, and OTP-verified callbacks, is now required to ensure robust transactional security.

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14 January 2026

Latest Policy Paragraphs, January 2026 1 paragraph
Generative AI Governance

Explicit prohibition copying and pasting client data or confidential documents into public AI tools (like ChatGPT or Gemini Free.This is crucial given public tools retain data for training, which constitutes a breach of client confidentiality and a GDPR violation

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Buying 7 or more paragraphs? The full current policy costs the same or less at £475.00 + VAT.

Related CQS policies

Exclusions to note

Sample template bundles do not include a template to show the structure of the residential conveyancing department at a firm. The data protection policy template covers the requirements of CQS, however it is the responsibility of the firm to ensure it is compliant with the requirements of the General Data Protection Regulation.