When creating a new insider list the permanent insiders will not be included on the event based insider list. Instead these individuals are listed separately on the permanent insider list. This is the way the Market Abuse Regulation specifies that permanent insider lists are to be managed. In the Logwise application the permanent insiders are shown below the event based list due to the fact that the permanent insider list can change over time and older lists may then have a different set of permanent insiders than those which are currently on the permanent list.
When the insider list for a specific event is exported in the format required by the NCA the event based list and the permanent insider list will be combined into a single document - one section is the event specific list with one set of information, the other section is the permanent insider list with different information requirements. This is per the requirements in MAR.
Since the permanent insiders are never actually on the event specific list they do not receive notifications of being added to or removed from that insider list. They do however receive notifications of their status on the permanent insider list.
It is important to understand that there are specific requirements for managing the permanent insider list in accordance with MAR including ensuring that those individuals on the permanent insider list are persons who through their role and the information they manage are always aware of the status of all inside information within the company. If they are not aware of the status of all inside information within the company and instead require being informed about it on a case by case basis they do not qualify as being permanent insiders. In that case they should instead be included on the event based lists, as required, when they gain access to the inside information. A person cannot be both on an event based list and the permanent insider list for the same time period. This is also a requirement of MAR, to not double list individuals.
The permanent insider list is not a mandatory list under MAR, so people who are aware of all information at all times and can still be listed as only event based insiders. It is recommended to avoid the use of the permanent insider list when possible or at least minimising the number of people included on the list. It is provided as a mechanism to avoid repetitive notifications and management of personal information and insider status for persons who always have access to all inside information. There have been several cases where companies have been fined for having too many persons on the permanent insider list or including people who do not have access to all information at all times.
With the Logwise solution management of personal information across all lists is automated so there is no reason to use permanent insiders to reduce the administrative burden of updating personal information. The permanent insider list is designed to reduce the number of notifications sent to those persons, so there are no event based notifications sent to them.