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Last updated: November 22, 2019

Refinitiv World-Check privacy statement

This privacy statement explains how Refinitiv Limited in the United Kingdom (“Refinitiv” “we”, “us” or “our”) collects, handles, discloses, stores and protects information about you in the context of our World-Check service (“World-Check”). It also provides information about your rights and about how you can contact us if you have questions about how we handle your information. You can also access more information on how World-Check works by clicking here.

What this privacy statement covers

This privacy statement only covers World-Check. Alternative privacy statements apply to other products, services and websites made available by us or our holding companies, subsidiaries or affiliated companies (together the “Refinitiv Group”).

Who Refinitiv World-Check holds information about

  • World-Check holds information that helps financial institutions, corporates, professional services firms, governments, law enforcement agencies, regulators and other WC Customers (“WC Customers”) to perform due diligence and other screening activities in accordance with their legal or regulatory obligations and risk management procedures carried out in the public interest (“Checks”).
  • It is designed and maintained to improve the speed, accuracy and transparency of Checks which are carried out on customers and counterparties, and which relate to anti-money laundering, countering terrorist financing and other unlawful acts (for example, illegal trafficking and environmental crime), ‘know your customer’, and anti-bribery and corruption requirements.
  • World-Check is not aimed at children. In the limited circumstances where we collect and use personal information about children (for example, because they are the children of a PEP (as defined below)), we comply with industry guidelines and applicable laws.
  • Your information is only included on World-Check if Public Domain Data (as defined below) suggests that there is information about you that WC Customers ought to be aware of for the purposes of Checks.

When WC Customers carry out Checks, they can also choose to carry out searches of Public Domain Data contained within media sources using media search tools available in World-Check. For example, they may conduct media searches against names of their customers or counterparties. For more information on this, click here.

The inclusion of information about you on World-Check does not prevent you from doing business with WC Customers such as financial institutions. You can find out if information about you is on World-Check here. To see our FAQs on how World-Check works, click here.

What personal information we process

As part of World-Check, we may collect and process information that is derived from Public Domain Data, where relevant for Checks.

WC Customers can also choose to carry out optional searches of Public Domain Data contained within media sources using search tools within World-Check, in order to enhance or supplement their Checks. These search tools allow WC Customers to enter names of their customers and counterparties alongside keywords used for research purposes into a search engine that searches media sources and returns results based on those names and keywords. Keywords can be selected by WC Customers, but they are aimed at discovery of the type of information listed below. If such a search is conducted about you, your name would appear alongside any articles in which your name (or a similar name) appears, alongside any relevant keywords found in that article. However, WC Customers know that this does not mean that either the person named in the article is actually you or that everything contained in Public Domain Data is true. They are obliged to take further steps to verify information and to determine how to use it.

World-Check may hold the following types of information about you.

  • Information that helps identify you (e.g. your name; alias (if any) age; date of birth; gender; country of residence; passport details; citizenship).
  • Personal identification numbers (e.g. social security numbers; national insurance numbers) that are Public Domain Data.
  • Family circumstances information (e.g. your marital status and dependents) if you are a PEP or a close associate of a PEP.
  • Employment/role and education details (for example, the organisation you work for, public roles (including political, diplomatic, religious, judicial, military and trade union roles), your job title and your education history).
  • Professional and personal affiliations (for example, organisations (including sanctioned vessels and aircraft) and individuals that you may be associated with in your professional or personal capacity).
  • Financial information relevant to understanding your income or wealth (for example, bankruptcy or insolvency filings).
  • Your inclusion (if any) on sanctions lists or on public lists of disqualified directors or other positions of responsibility.
  • Public Domain Data about actual or alleged money laundering or terrorist financing crime, or crimes that are a pre-cursor to money laundering or terrorist financing which are also known as predicate offences (e.g. financial crime, illegal trafficking, environmental offences, smuggling, membership of an organised crime group).
  • Your postings on website, blogs or social media applications.

How we use information about you

We use information to facilitate Checks by World-Check customers, to comply with regulatory requests and for other purposes connected with the proper management of World-Check and protection of our rights. More information on these purposes is contained below.

What legal grounds do we use to process your information

Some laws require us to explain our lawful reason for processing your personal information. We process standard personal information on the basis that it is in our or others’ legitimate interests. We generally process special category and criminal data for reasons of substantial public interest on the basis of applicable law.

Who we disclose your personal information to

We make World-Check information available to WC Customers, members of the Refinitiv Group that require World-Check data for products or services that they offer, third parties who provide advice and services to us, business partners that work with us to make World-Check data available for the purpose of Checks and as required by, or desirable in order to comply with, law. Our third-party service providers are not permitted to share or use personal information we make available to them for any purpose other than to provide services to us.

How we secure your personal information

We take information security seriously and use a range of physical, electronic and managerial measures to keep your personal information secure, accurate and relevant. These measures and our information security policies are closely aligned with widely accepted international standards, reviewed regularly and updated as necessary to meet our business needs and changes in technology and regulatory requirements.

Why information may be transferred abroad

World-Check is a global service and your personal information may be stored and processed outside of your home country, including in countries that may not offer the same level of protection for your personal information as your home country. We have measures in place to ensure that when your personal information is transferred internationally, it is subject to appropriate safeguards in accordance with data protection laws. Often, these include contractual safeguards. More information about these safeguards (including copies, where relevant) can be obtained by contacting us here.

How long we keep your information

How long your data is held in World-Check will depend on type of information we hold about you, details of which can be found here. You can find more information on the criteria used to determine retention periods below.

Your rights

You may have rights under European and other laws to have access to your information and to ask us to rectify, erase and restrict use of, your information. You may also have rights to object to your information being used and to withdraw consent to the use of your information. Further information on how to exercise your rights is set out below.

How to contact us

If you have any questions, comments, complaints or suggestions in relation to data protection or this World-Check Privacy Statement, or any other concerns about the way in which we process information about you, please contact our Privacy Team at contact@world-check.com or at Attn: Data Protection Officer, Refinitiv Limited, 30 South Colonnade-Canary Wharf, London E14 5EP, United Kingdom. You can also find out if information about you is on World-Check here.

Changes to this privacy statement

We may modify or amend this privacy statement from time to time.

Any future changes or additions to the processing of personal information as described in this privacy statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

Your Questions Answered

Does Refinitiv make my personal data on World-Check available to the general public?

No, Refinitiv does not distribute personal data on World-Check to the general public. Only authorised World-Check subscribers have access to that personal data.

What steps does Refinitiv take to inform users about appropriate use of World-Check?

Refinitiv includes usage restrictions in its client contracts.

Why have I not been told that my personal data is on World-Check?

Your personal data has been collected from sources available to the general public and those sources generally do not provide reliable contact details such as email or postal addresses. In addition, even if we were able to find that information, we do not process detailed contact details such as this. If, however, one of our World-Check clients wants to conduct a search against you on World-Check they are required to inform you of this.

Why have you not obtained my consent to your processing of my sensitive personal data?

First, as mentioned above we do not have any reliable contact details for you and second, because of the limited reasons for which we make World-Check available to our subscribers, we are able to lawfully process your personal data without relying on your consent.

By including my personal data in World-Check are you advising your subscribers that I should be viewed negatively?

On the contrary, we make it clear that the inclusion of an individual on World-Check should not automatically be taken to draw any particular inference (negative or otherwise) about them, and this is enshrined in our client contracts. The personal data of many individuals is included in World-Check solely because they hold prominent political or other positions or are connected to such individuals. Furthermore, if, for example, your personal data on World-Check includes allegations about unlawful acts, we advise our users to assume that such allegations are denied by you.

Does the fact that my personal data is on World-Check automatically mean that your clients cannot or will not do business with me?

No. We advise our users that they cannot rely solely upon personal data found on World-Check when making any decision to deal with any individual. Instead, they must make independent checks of such individual to verify the accuracy of the personal data we process and decide for themselves whether to conduct business with that individual.

Is the personal data in World-Check accurate?

We maintain research standards designed to ensure the accuracy and relevance of the personal data on World-Check. However, because of the nature of Public Domain Data , we cannot discount that data we process may contain some errors or become outdated. Therefore, if you find an error in any personal data that we process or you or believe it to be irrelevant or excessive, please send an email message to contact@world-check.com

Please be assured that we will fully consider any communications that you send to us but it may not in every instance result in changes or deletions to the information about you on World-Check, if we conclude that the information remains accurate and relevant and/or there are other lawful grounds available to us which permit us to refrain from changing or deleting your personal data.

Can I find out what information Refinitiv has about me in World-Check?

Yes, you may request a copy of the personal data that we hold on you in World-Check. To ensure your privacy, we'll ask for information verifying your identity. To request a copy please send an email message to contact@world-check.com

We make no charge for supplying you with your personal data.

Any identification evidence that you provide will only be used to verify your identity for this purpose and for no other. We reserve the right to deny unreasonable or unwarranted requests for access.

If you have questions about requesting a copy of your personal data, please send an email message to contact@world-check.com

Can I have my personal data in World-Check updated or removed?

An individual may, request that his/her personal data be updated or removed from World-Check. However, it is important to note that any right you may have to request updates or deletions to your personal data on World-Check is not absolute and we may be lawfully permitted to refrain from making any update or deletion to your personal data on World-Check. In such circumstances, we will explain to you why this is the case.

Rest assured that we do, however, make extensive efforts to prevent inaccurate, outdated, irrelevant or excessive Personal Data being processed on World-Check.

Where you do wish to proceed with a request to update or remove your personal data from World-Check, we will need a written explanation of your request in order to assess it against applicable laws. Depending on the nature of the request and the personal data involved, we may also ask you to provide supporting information and/or documentation.

Additional questions about updating or removing your personal data or the kind of supporting documentation that may be required should be directed to contact@world-check.com

Once a decision has been made on a request to update or remove personal data on World-Check, that decision will be communicated to you in writing.

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Definitions

"Public Domain Data” means personal information originally available to the public and typically over the internet. Examples include personal information found on: (i) sanction or watch lists; (ii) law enforcement, court, regulatory or other government websites; (iii) political websites and publications such as parliamentary, local government or individual politician websites; (iv) reputable news media and publications; and (v) information sources made public by an individual themselves, for example on their website, blog or any social media application.