GB Group Plc Products and Services Privacy Notice

GBG is a global organisation who create technology. Typically, customers use our technology so they can verify the information that you give to them about yourself. We do this by matching third party reference data (which we receive from data suppliers) against the data you give about yourself to our customers. This still sounds complex, so an example is often the easiest way to explain;

• You are going to open a bank account
• In order to open the bank account, the bank (our customer) needs to verify you are who you say you are. This is for a number of reasons, such as for the bank to comply with anti-money laundering regulations or combatting fraud purposes.
• The bank collects personal data from you and passes this to GBG’s technology to process (via our products and services).
• As part of this processing, we may match the data you provided against third-party data (from our data suppliers), such as data belonging to Credit Reference Agencies or public sources, such as the voters' register.
• We pass a result back to the bank (our customer) on whether we could match your input data against the third party data.
• Our customer then decides how they will respond to you, e.g. open your bank account, decline your request etc.

More examples are included in the table below describing why we collect your personal data.

The personal information that we may collect about you broadly falls into the following categories:

Category	Examples
Basic information	Name/Address
Attribute	Telephone/Email/Date of Birth
Device	IP, Geocode, DeviceID
Criminal	Convictions data
Financial	Home Ownership, County Court Judgments, Insolvency
Social	Social Networks
Image	Photo on a passport or driving licence

 

Why we collect your personal data depends on the services we provide.

GBG Service	Description of services / why we collect this personal data
Location Intelligence	Address Capture & Verification – we can capture and verify your address globally. Our service aims to create the best, quickest experience when you order online, whilst ensuring the company you are engaging with have everything they need to fulfil your request. For example, it is much quicker for you to enter a postcode and be presented with a list of addresses to select from, as opposed to entering the full address. There is also the option where the company you are engaging with can verify if you have provided a valid email address or phone number so they can get in touch with you if needed. Some of our customers also take Geocodes, which is a unique identifier for your address, so the delivery company can easily find you to deliver the item you have ordered. Data Cleansing – we are all busy people and it’s often difficult to remember and very time consuming to contact all businesses we engage with if any of our details or preferences change. These organisations also have a legal requirement to keep your data up-to-date, which is where we come in. We can help them identify if your details are no longer valid, such as if you have moved address or if someone in your household has died, for the purposes of reducing the risk of fraud or being contacted at what we know will be an upsetting time. GBG is also able to provide our customers with additional information about you if they have the right to do so. For clarity, our data cannot be used by us or our customers to contact you for marketing purposes. An example of where this could be used is if you had a pension at an old address, we could provide our customer with a new address so they can contact you. It is a legal requirement for an organisation to try to reunify you with your assets, which is why they are entitled to use your personal data in this way. It would not be ok if they then tried to sell you a new pension unless they’d gained your agreement to further process your personal data in this way.
Identity	Identity & Age Verification – we can capture and verify your identity globally, making it easier for you to transact online. What this includes depends on the organisation you are engaging with. For example, we can verify the authenticity of your identity documents or check if you are over a particular age if you want to access a service which has age restrictions. Our customers do this because many of them must meet regulatory requirements and prevent fraud, so we help them to meet their requirements, with you in our mind, to make things as simple and easy as possible. Employee Onboarding – if you are trying to get a job or volunteer, organisations must complete checks on you to ensure they meet their regulatory or moral obligations. For example, we can offer criminal record checks helping to ensure known criminals cannot interact with your child, or checking a delivery driver has a valid driving licence so they are safe to be on the road. Identity Intelligence & Tracing – used is for law enforcement, asset reunification and debt collection to identify and locate individuals. Where a company has minimal or old information on you, there may be a need to contact you. To give you an example, our product has helped assist police in locating a domestic abuse victim who needed help. A woman made a 999 call as she was being physically and verbally assaulted at a domestic address. The police used GBG’s product to identify three possible addresses. Patrols attended each address and the operator was able to hear the officers knocking on the door, confirming they were in the right place. A man was arrested and the woman treated for her injuries.
Fraud & Compliance Management	We help our Customers reduce fraud which benefits you by ensuring you get the best price, your identity is protected, and you receive goods and services you order. With each online order companies must make a decision whether to ship or decline it. To give you an example, Mary Christmas placed a large food order on the last shipping day before Christmas. Her name triggered fraud indicators: due to her name and timing, the retailer would have normally declined the order. However, the retailer used our service to determine that Mary Christmas was a legitimate customer. Mary Christmas's goods were dispatched and she/her family got to enjoy a lovely Christmas lunch.

We will collect personal information where the processing is in our or our customer’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. These include legitimate business interests which provide a societal benefit, such as preventing fraud, crime prevention and detection and ensuring only individuals who should have access to services or perform in a particular role are able to do so.

The table below identifies the legitimate interest that we rely on pursuant to the GDPR for each of our activities.

Activity/Purpose	GBG's Lawful basis
Location Intelligence (Address Capture & Verification)	Legitimate Interests of a third party: Our customers will have their own lawful basis for processing your data and will have communicated this with you. We have given a description of the types of services our customers provide in the table above, but in a nutshell, they help to ensure you receive the goods/services you have ordered and prevent fraud by ensuring your data is accurate and up-to-date.
Identity	Legitimate Interests of a third party: Our customers will have their own lawful basis for processing your data and will have communicated this with you. We have given a description of the types of services our customers provide in the table above, but in a nutshell, they help to prevent fraud by ensuring you are who you say you are, so you can access goods and services compliantly. Many of our customers must also meet a legal obligation when processing your personal data, such as ensuring you are old enough, verifying your identity or that you have a right to work in that industry.
Fraud & Compliance Management	Legitimate Interests of a third party: Our customers will have their own lawful basis for processing your data and will have communicated this with you. We have given a description of the types of services our customers provide in the table above, but in a nutshell, these services help to prevent fraud and allow our customer to meet their compliance obligations.

 

Pursuant to our obligations under Article 30 GDPR, we maintain an up-to-date record of processing activities under our responsibility, which details for each of our processing activities the legitimate interest relied on as a lawful basis for processing the personal data.

You are entitled to more information on the balancing test we have carried out when determining we are able to rely on legitimate interest as our lawful basis for processing your personal data. If you have questions about this or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.

As explained above under What do we do, we receive personal data about you from our customers and data suppliers. We also send your personal data to our customers and data suppliers, where there is a lawful reason, to do so in order to provide our products and services.

GBG Customers

We offer our products services to public and private organisations worldwide. These include:

Sector	Examples
Financial Services	Banks, insurance providers
eCommerce	Retail (online shopping), online commerce platforms
Gaming	Online gaming
Consumer Directories	Travel and leisure, media
Public Sector	Law enforcement, local government, education bodies
Utilities	Gas, electricity, water suppliers and switching/price comparison sites

 

GBG Data Suppliers

We work with a number of trusted data suppliers. These include:

Data Supplier	Further information
Government / Public Authorities	These bodies include authorities that provide driving licence information, passport information, citizen identification number, social security number, criminal record information, insolvency records (also in publicly available) or sanctions lists (also in publicly available). Examples of this include: The Electoral Roll collected by local electoral offices and distributed by Credit Reference Agencies Insolvency data is provided by 3 Government Sources: The Insolvency Service – England & Wales, Department for the Economy – Northern Ireland, AIB – Scotland Land Registry who provide Price Paid Data and Home Ownership searches. DVLA – driving licence checks DBS - Disclosure & Barring Service, Disclosure Scotland offer criminal record checks.
Regulated Financial Services Organisations / Firms	These entities collect information about your financial status, but this data can also be used to help organisations like us verify your identity by confirming you are who you say you are, and you live, or have lived at an address. Credit reference agencies (CRAs) play a key role in the UK’s financial ecosystem. There are 3 CRAs in the UK: Equifax, Experian and TransUnion. They each provide a copy of the “CRAIN”, Credit Reference Agency Information Notice.
Other Regulated Organisations / Firms	These entities provide personal data which can help to verify or contact you, for example, you have made a choice whether or not your landline is included in the public telephone directory. In the UK, BT Wholesale Directory Services deliver this. It is known as “OSIS”, which is the abbreviation for Operator Services Information System. Data is collected from multiple providers to create this central database of publicly available phone numbers.
Commercial Organisations	These entities provide your contact details, such as name, address, telephone number or email address, which we can then use to meet the request you have made to one of our Customers.
Publicly available, collected by a third party organisation or GBG	These entities provide information about insolvency records, property information, sanction lists, PEPs information, social media/convention online information / deep web / dark web, income index or family situation. Examples of this include County Court Judgements (CCJs) from the Registry Trust.
Non-personal / address data	These entities provide information about deceased records, geocodes, co-ordinates, postcodes or zipcodes.

 

We may also disclose your personal data to the following categories of recipients:

• to our group companies, third party services providers and partners who provide data processing services to us, or who otherwise process personal information for purposes that are described in this privacy notice;
• to any competent law enforcement body, regulatory, government agency, court or other third parties where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger, acquisition, restructuring or insolvency of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this privacy notice.

We retain personal information we collect from our customers and data suppliers for the length of time necessary to fulfil the specific purpose or purposes for which it has been collected (for example, to provide our customers with a service you have requested or for our customers to comply with applicable legal requirements, such as anti-money laundering). We may also keep it to comply with our legal obligations, resolve any disputes and enforce our rights.

Once the respective purpose ceases to apply, we will either delete or anonymise the personal information or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

As explained above in the section “What do we do”, GBG access personal data in 2 ways. When we access personal data via a web service, our data suppliers hold the database therefore GBG does not see or have any control over this, other than via our GBG Audit Trail which we explain below.

We also receive personal data which we host a copy of. At the point of collection, you will have been advised how long your personal data will be held for, which will be different to the retention period GBG state below.

A ‘data refresh’ is how often GBG get a copy of the personal data. The data supplier may provide GBG with a complete refresh, which is a new copy of the entire file. Some data suppliers only provide updates to a file (e.g. new records, updates to existing records or a request to delete records). GBG then apply these updates to a master file we hold. What this means is whilst GBG gets a new copy of the data, this database may contain much of the same data we have previously received. This explains why the data refresh is different to GBG’s data retention period.

 

As an individual, you have rights under the GDPR regarding the use of your personal data, these are:

• The right to withdraw consent – you can withdraw consent at any time.
• The right to erasure – you can request that GBG remove your personal data from our systems.
• The right to restrict processing – you can request that GBG only process your personal data for the purposes you specify.
• The right to data portability – you can request that the personal data you have provided to GBG be ported to another organisation.
• The right to access your personal data – You have a right to know what personal data GBG hold on you and for what purpose we are processing your personal data. This is known as a Subject Access Request (SAR).
• The right to rectification – you have the right to ask us to rectify any information you believe is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• The right to object to processing – you have the right to object to processing if we are able to process your information because the processing is in our legitimate interests.
• The right to obtain information upon request on the balancing test we have carried out when determining we are able to rely on legitimate interest as our lawful basis for processing your personal data.

Please keep in mind that some of these rights are subject to an internal assessment that one of the grounds under the GDPR is satisfied.

You can make a request to us directly by completing this form or by post to:

Privacy & Data Compliance Team
GB Group Plc
The Foundation
Herons Way
Chester Business Park
Chester
CH4 9GB
United Kingdom

Or you can make a request in person or call +44 (0) 1244 657277.

You are not required to pay any charge for exercising your rights. We have one calendar month to respond to you. If GBG are unable to comply with your request, we will provide you with an explanation.

We appreciate that at GBG we may not always get things right and it is regrettable for us as an organisation when we receive a complaint. We take all complaints seriously and can assure you we will do our best to deliver a satisfactory outcome. If you do wish to complain about how your personal data is used by GBG then please write to us at:

Privacy & Data Compliance Team
GB Group Plc
The Foundation
Herons Way
Chester Business Park
Chester
CH4 9GB
United Kingdom

Alternatively, you can email us at compliance@gbgplc.com.

GBG will investigate and aim to respond within 10 working days. This allows us time to investigate your complaint thoroughly.

Where you believe that GBG have not taken our responsibilities with your personal data seriously, you have the right to complain to the UK Supervisory Authority. Its details are:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone number: 0303 123 113 or +44 (0)1625 545 745

Email: casework@ico.org.uk