The Financial Conduct Authority has issued guidance for regulated firms to consider when outsourcing to cloud service providers. Among other things, firms must consider how the FCA will have “effective access” to data stored on the cloud. The FCA also urged firms to consider international developments that are likely to have an impact on using cloud services, including – for European-based entities – reform of the European Union Data Protection legislation. However, the FCA raises no fundamental objections to cloud usage by regulated firms. Indeed, FCA acknowledged that “[t]he use of outsourcing to the cloud and other third party IT services can have a positive impact on competition in financial services.” Comments will be accepted through February 12, 2016.