Data Retention Policy

Introduction

This document sets out the data retention policies of Verifi Identity Service Limited (“Verifi”) in respect of information received from a Reporting Entity (“Reporting Entity”), customers (“Customers”) of a Reporting Entity and from third party data vendors and service providers (“Third Party Vendor”) in order to electronically verify the identity of the customer.

Third Party Vendors

Verifi will obtain information from Third Party Vendors in accordance with Verifi’s agreement with a Third Party Vendor. Verifi will use this data to verify the information provided by a Customer. Subsequent to the verification process, Verifi will not retain any data provided by the Third Party Vendor unless authorised to do so by the Third Party Vendor. Note that each Third Party Vendor retains data in accordance with its own Data Retention Policy.

Information received from Customers

Verifi will collect information from Customers on behalf of Reporting Entities. Verifi may use this information to query Third Party Vendors and verify the information against data provided by Third Party Vendors. The comparison may be done by Verifi or a Third Party Vendor.

Verifi will provide a copy of the information obtained from a Customer on behalf of a Reporting Entity to the Reporting Entity as part of the identity verification report.

Verifi will retain information collected from Customers for a period of 7 days for auditing and error checking purposes. Following this 7-day period, Verifi will automatically and securely remove the data from its systems.

Information received from Reporting Entities

Verifi will collect Customer information from Reporting Entities. Verifi may use this information to query Third Party Vendor and verify the information against data provided by Third Party Vendor. The comparison may be done by Verifi or the Third Party Vendor.

Verifi will retain information collected from the Reporting Entity for a period of 7 days for auditing and error checking purposes. Following this 7-day period, Verifi will automatically and securely remove the data from its systems.

Pending Verifications

For certain Verifi services, including where we use Third Party Vendors, the service may take several days or weeks to complete (for instance where a Customer is required to provide information) and as a result the verification will remain pending during this time. Verifi may have access to information while a verification is pending completion. The 7-day data retention period starts upon the completion of the verification.

Ongoing Monitoring

Where a Reporting Entity is using an ongoing monitoring service, Customer information provided by the Reporting Entity will be retained for the period of time that the Reporting Entity uses the ongoing monitoring service in respect of a Customer. Following notification from the Reporting Entity that it no longer will be using ongoing monitoring in respect of any Customer, the data will be removed in accordance with this policy.

This Data Retention Policy is dated 24 January 2024.

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