Last updated: 19 September 2017
This privacy statement explains how Reuters Ltd in the United Kingdom and Thomson Reuters Global Resources (TRGR) Switzerland (“Thomson Reuters” “we”, “us” or “our”)may collect, handle, store and protect information about you in the context of our World-Check product. 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.
Click on the links below to take you to the more detailed sections of this privacy statement:
- What this privacy statement covers
- Who World-Check holds information about
- What personal information we collect
- How we use information about you
- Who we disclose your personal information to
- How we secure your personal information
- Why information may be transferred abroad
- Your rights
- How to contact us
- Changes to this privacy statement
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 “Thomson Reuters Group”).
Who World-Check holds information about
- World-Check holds information that helps financial institutions, corporates, professional services firms, governments, law enforcement agencies, regulators and other World-Check 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, ‘know your customer’ and anti-bribery and corruption requirements.
- 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.
The inclusion of information about you on World-Check does not prevent you from doing business with WC Customers such as financial institutions.To see our FAQs on how World-Check works, click here.
Your information may be included on World-Check if Public Domain Data indicates that:
- you are a “politically exposed person” (“PEP”) as defined by the FATF Recommendations or fall into a similar category of persons under national laws or regulations against money-laundering, terrorist financing, bribery or corruption. The FATF Recommendations are global standards against money laundering and terrorist financing issued by the Financial Action Task Force (“FATF”), an inter-governmental body originally established by the G7 in 1989 and now with approximately 40 members;
- you are a close associate of a PEP, again as defined in the FATF Recommendations. Close associates may include children (for example, the children of a PEP and other minor dependents of a PEP). Where we do collect information about children we will comply with applicable laws.
- you are listed on the website of a regulator, law enforcement authority or governmental body in connection with money-laundering, terrorist financing, bribery, corruption or similar activities;
- you are included on a government or international body’s sanctions list (such as the sanctions lists issued by the European Union);
- you are linked to terrorist or financial crime-related activities;
- you have been convicted of crimes which are a possible pre-cursor to money laundering or terrorist financing (e.g. arms trafficking, smuggling or fraud), which are also known as a predicate offence, or you are suspected of involvement in these activities; or
- you have been disqualified or are prohibited from holding positions of responsibility (such as company directorships).
Inclusion of information about you in World-Check does not suggest that you are involved in, or linked to, financial crime, terrorism or any other criminality. For example, being identified as a PEP simply tells a WC Customer that you perform a prominent political or related function.
WC Customers make their own decisions about how to use the World-Check data they receive in order to conduct their Checks. If you have any questions about these decisions, please refer them to the relevant WC Customer. For further information on how World-Check works, click here.
For the purpose of this privacy statement, “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.
What personal information we collect
As part of World-Check, we may collect information that is:
- Derived from Public Domain Data, where relevant for Checks.
- Provided by a WC Customer to TR in the course of carrying out a Check (e.g. passport details) and which the WC Customer confirms is already Public Domain Data.
World-Check may hold the following types of information about you.
- Information that helps identify you (e.g. your name; age; date of birth; gender; country of residence; passport details).
- 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, religious and trade union roles), your job title and your education history).
- Professional and personal affiliations (for example, organisations 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 financial crime or crimes that are a pre-cursor to financial crime.
- Your postings on website, blogs or social media applications.
We have in place robust controls designed to ensure that information about you on World-Check is accurate, relevant and not excessive. We comply with detailed research and screening processes for sourcing World-Check information and we monitor compliance with these processes.
How we use information about you
If your information is included on World-Check, it is collected, used, shared and retained for the purposes of:
- facilitating Checks by World-Check customers;
- if you contact us, dealing with your requests and enquiries;
- complying with applicable legal or regulatory requirements;
- dealing with requests and communications from competent authorities;
- services we receive from our professional advisors, such as lawyers, accountants or consultants;
- protecting our rights;
- technical support and maintenance connected to World-Check; and
- administering and applying record keeping and deletion procedures.
Who we disclose your personal information to
We may make World-Check information available to WC Customers, members of the Thomson Reuters Group that require World-Check data for products or services that they offer, third parties who provide advice and services to us, credible business partners that work with us to make World-Check available for the purpose of Checks and as required by, or desirable in order to comply with, law. Where we do so, we put in place robust contractual protections to safeguard your personal data.
If information about you is included on World-Check, it may be made available to the following parties.
- WC Customers. We only make World-Check information available to credible WC Customers that have a legitimate need to access information on World-Check. We also require that they only use it for the purposes of carrying out Checks or to otherwise comply with law. If any World-Check subscriber uses information on World-Check beyond the limited purposes permitted by us, we may act to terminate the subscriber’s access to World-Check.
- The Thomson Reuters Group. We may disclose information about you to other members of the Thomson Reuters Group that require World-Check data for products or services that they offer, subject to compliance with robust procedures designed to protect your information.
- Third Party Service Providers, Professional Advisors and Business Partners. In order to assist us in supplying and maintaining World-Check, we may allow a limited number of third party service providers and business partners to access information held by World-Check (e.g. providers of technical support and business partners whose Checking products use World-Check). We may also disclose information about you to our professional advisors in connection with one or more of the purposes outlined in the “How we use information about you” section.
- Authorities, Courts and Tribunals. We may also disclose information about you to competent authorities, courts and tribunals in connection with one or more of the purposes outlined in the “How we use information about you” above.
- Business Transfers. As we continue to develop our business we may sell assets that currently form part of our business. In those circumstances, we may include information collected about you, or control of that personal information, as a business asset in any such sale. Also, in the unlikely event that we, or substantially all of our assets, are acquired, information about you, or control of such information, may be one of the transferred assets.
You have various rights in relation to your personal information and we respect those rights. In particular, you have a right to:
- request a copy of personal information we hold about you;
- ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete; and
- object to our processing of your personal information.
We do not levy a charge where you wish to exercise any of your rights but will ask for information to verify your identity. This is to safeguard your own privacy. Any identification evidence that you provide will only be used to verify your identity for the purpose of your requests.
There are limits to the rights that you have in relation to your personal data and in certain circumstances we may not be required or able to meet your request, or we may meet your request in part only. Where this occurs, we will provide you with an explanation of the legitimate basis on which we are unable to meet your request. You can also find further information on our approach towards any requests you make in the World-Check FAQ which is available here.
See also the “How to contact us” section below for details of how to contact us to exercise these rights and data protection regulators if you disagree with a decision we have reached.
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.
These policies and measures include:
- robust controls around the inclusion and maintenance of information on World-Check which are designed to ensure that information about you on World-Check is accurate and relevant;
- education and training to relevant staff to ensure that they are aware of and comply with our policies, procedures and controls designed to keep World-Check information (including any information about you) secure, accurate and relevant;
- administrative and technical controls to restrict staff access to World-Check information (including any information about you);
- a business continuity and disaster recovery strategy that applies to World-Check and which is designed to safeguard the continuity of access to, and security of, World-Check;
- physical security measures, such as staff security passes and strict controls on access to locations of World-Check servers;
- monitoring compliance with our policies, procedures and controls.
We also impose contractual restrictions on WC Customers and business partners requiring them to only use information on World-Check (including any information about you) in connection with Checks.
Why information may be transferred abroad
World-Check is a global service and the Thomson Reuters Group is a global organisation. In some cases, the disclosures of your personal information outlined above may result in your personal information being transferred outside of your home country.
When we transfer personal information from the European Union to other countries whose laws do not offer the same level of data protection, we will ensure that there are adequate safeguards in place to protect your personal information that comply with our legal obligations. For example, the adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal data to third countries. If you would like to know more about the safeguards we put in place for transfers of personal information outside the European Union, please contact us.
How to contact us
We understand that you may have questions or concerns about this privacy statement or our privacy practices. You may also wish to submit a request to exercise any of your rights.
If so, please e-mail us at firstname.lastname@example.org or write to us at the address below:
Attn: Data Protection Officer
30 South Colonnade
You may also use the contact details above if you wish to make a complaint to us or a data protection regulator in relation to the way we have handled your personal information or any privacy query or request that you have raised with us. A list of national data protection regulators can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Changes to this privacy statement
We may modify or amend this privacy statement from time to time.
To let you know when we make changes to this privacy statement, we will amend the revision date at the top of this page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.
Your Questions Answered
Does Thomson Reuters make my Personal Data in World-Check available to the general public?
No, Thomson Reuters 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 Thomson Reuters take to inform users about appropriate use of World-Check?
Thomson Reuters 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.
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 do not need to seek that 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. 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. In addition, while every reasonable attempt is taken to ensure that your Personal Data is accurate, because it is gathered from sources available to the general public, we do not guarantee that such Personal Data will not have changed or be correct. If your Personal Data includes negative allegations about you, 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 should not rely solely upon Personal Data found on World-Check when making any decision to deal with any individual. Instead they are advised to make independent checks of such individual to verify the accuracy of the Personal Data we process before making any such decision.
Is the Personal Data in World-Check accurate?
We maintain research standards designed to ensure the accuracy of the Personal Data we process. However, because of the nature of Public Domain Data, the data that we process may contain errors or become outdated. Therefore, if you find an error in any Personal Data that we process on you or believe it to be irrelevant or excessive, please send an email message to email@example.com
We will notify you of any information or documentation that you may need to submit in order for us to consider making the changes being requested. Please be aware that any request may lead to no changes to your Personal Data being made or to them being updated or deleted.
Can I find out what information Thomson Reuters 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 firstname.lastname@example.org
We make no charge for supplying you with this.
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 email@example.com
Can I have my Personal Data in World-Check updated or removed?
An individual may, for substantiated reasons, request that his/her Personal Data be updated or removed from World-Check. However, it is important to note that casual updating or removal of Personal Data from World-Check could compromise its integrity. Therefore, each request will be evaluated on its merits.
Thomson Reuters will act to prevent inaccurate, outdated, irrelevant or excessive Personal Data being processed in World-Check.
In order to consider such requests, we require a written explanation substantiating the request. Depending on the nature of the request and the Personal Data, the person may be required 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 may be directed to firstname.lastname@example.org
Once a request to update or remove personal data has either been granted or denied, that decision will be communicated to the requestor in writing, as appropriate.