(13)An investment firm which has transaction reporting obligations, known as a ‘reporting firm’, may choose to use a third party to submit transaction reports on its behalf to an ARM, that is a ‘submitting firm’. By virtue of its role the submitting firm will have access to the confidential information that it is submitting. However, the submitting firm should not be entitled to access any other data about the reporting firm or the reporting firm's transactions which are held at the ARM. Such data may relate to transaction reports which the reporting firm has submitted itself to the ARM or which it has sent to another submitting firm to send to the ARM. This data should not be accessible to the submitting firm as it may contain confidential information such as the identity of the reporting firm's clients.