The database of Designated Persons is to be maintained under reg 9A(2) after identifying all employees having access to UPSI as a DP.
Structured Digital Database is required to be maintained under reg 3(5) to record each instance of sharing of UPSI.
As such, the requirement for keeping the register of Designated Persons and that of the Structured Digital Database are entirely different.
The Designated Person database is less dynamic and is the trigger point based on which multiple other compliances are to be performed. The difficulties arise from having to collate and manage a vast amount of data with all the attendant follow-up, reports and management that this entails. These are the problems that Affinis(IDD) addresses.
Conversely, SDD is more dynamic and is a continually updated repository where all sharing of UPSI must be captured on an ongoing basis including but not limited to Designated Persons and is itself the focal point of compliance, met by Affinis(SDD).
