World-Check Privacy Statement

Who we are
What this privacy statement covers
Who World-Check holds information about
What personal information we process
How we use information about you
What legal grounds do we use to process your information
Who we disclose your personal information to
How we secure your personal information
Why information may be transferred abroad
How long we keep your information
Your rights
California privacy rights
How to contact us
Changes to this privacy statement
Your questions answered

(LAST UPDATED: SEPTEMBER 27, 2024)

This privacy statement explains how Refinitiv Limited (“Refinitiv”, “we”, “us” or “our”) collects, handles, discloses, stores and protects information about you in the context of the World-Check service (“World-Check”).

It also explains who we are, your rights that may be available to you depending on applicable law, and 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.

Refinitiv Limited, registered in the United Kingdom, is a member of the London Stock Exchange Group of companies (“LSEG Group”) and the entity responsible as controller for processing personal information within World-Check.

This privacy statement only covers World-Check. For our general LSEG Privacy Statement, applicable to information the LSEG Group collects from and about users in connection with its products, services, websites, platforms, software, applications and events, please click here.

We hold information within World-Check that helps financial institutions, corporates, professional services firms, governments, law enforcement agencies, regulators and other World-Check customers and companies within the LSEG Group (“World-Check Users”) 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, including but not limited to the purposes of anti-money-laundering or ‘know your customer’, anti-bribery or anti-corruption or other regulatory compliance checks, or for preventing, investigating, detecting or prosecuting financial crime, fraud and serious misconduct or dishonesty, or other criminal or unlawful activity (for example, modern slavery, illegal trafficking, environmental crime, etc.) and any unethical conduct (“Checks”).
It is designed and maintained to improve the speed, accuracy and transparency of Checks which are carried out by World-Check Users on customers, vendors, business partners and other counterparties.
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 World-Check Users ought to be aware of for the purposes of Checks.

When World-Check Users 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, vendors, business partners, or other 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 World-Check Users 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.

Your information is typically 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 (for example, you are a senior diplomat, member of the judiciary, religious leader, military figure or trade unionist) 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 and industry guidelines.
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 accused, investigated, arrested, charged, or convicted of crimes which are a possible pre-cursor to money laundering or terrorist financing (e.g. arms trafficking, smuggling, fraud, membership of an organised crime group, environmental offences, war crimes), 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 or unlawful act or unethical conduct. For example, being identified as a PEP simply tells a World-Check User that you perform, or performed, a prominent political or related function or are connected to someone who holds or held such a position.

World-Check Users 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 World-Check User. For further information on how World-Check works, click here.

For the purpose of this privacy statement, "Public Domain Data” means personal information (1) originally available to the public and typically over the internet; (2) that Refinitiv has a reasonable basis to believe is lawfully made available to the general public by or from: (i) the data subject (or consumer or individual to whom the personal information relates), (ii) widely distributed media, or (iii) from a person to whom the data subject has disclosed the personal information (provided that Refinitiv does not have knowledge that the data subject has restricted the information to a specific audience); or (3) lawfully made available from records, databases, and/or systems of government agencies, departments, divisions or other operating units, in electronic, paper or any other format. 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.

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

World-Check Users 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 World-Check Users to enter names of their customers, vendors, business partners and other 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 World-Check Users, 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, World-Check Users 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.

In some cases, the personal information on World-Check includes, depending on specific jurisdictions and their applicable data protection laws, so-called ‘sensitive’ or ‘special categories’ of personal information such as: information relating to your political opinions (for example, if you are a PEP holding a position in a political party); information relating to your sexual orientation (for example, if World-Check records that you are the spouse or partner of a PEP); information relating to your religious beliefs (for example, if you are a senior religious leader that qualifies as a PEP); information relating to your racial or ethnic origin (for example, if this can be reasonably inferred from other information about you on World-Check, such as your name, location and citizenship); information on your trade union membership (for example, if you are a senior trade unionist that qualifies as a PEP); information relating to any criminal offences actually or allegedly committed by you (for example, if these are money-laundering or terrorist financing offences, or pre-cursor crimes to such offences).

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.

We use information to facilitate Checks by World-Check Users, 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.

If your information is included on World-Check, it is processed (e.g. collected, used, shared and retained) for the purposes of:

facilitating Checks by World-Check Users;
if you contact us, dealing with your requests and enquiries;
complying with requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, including where they are outside your country of residence;
exercising our rights, and to defend ourselves from claims and to comply with laws and regulations that apply to the LSEG Group or third parties with whom we work;
services we receive from our professional advisors, such as lawyers, accountants, consultants or information security professionals;
protecting our rights; and
supporting the operation of World-Check.

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.

We are required by laws in Europe to set out in this privacy statement the legal grounds on which we rely in order to process your information.

We process your standard personal information on the basis that it is in World-Check Users’ legitimate interests to carry out Checks to ensure that they can comply with their legal and regulatory obligations and protect the public from financial crime, fraud and serious misconduct or dishonesty. In addition, it is also in our legitimate interests to carry on a business to facilitate those Checks. We and the public also have a legitimate interest in ensuring that financial crime, fraud and serious misconduct or dishonesty are prevented and detected. It is reasonable for you to expect that your information may be used for the carrying out of Checks in the public interest. You may feel that your interests differ from our and World-Check Users’ interests, as inclusion of your personal information on World-Check results in further Checks being carried out by World-Check Users prior to a decision being made about whether to enter into an arrangement with you. However, the legitimate interests in carrying out Checks would not be overridden by your interests, given the significant public interest in the carrying out of Checks.

We process your special category information on the basis that:

you have made the information manifestly public; and
in all other cases, the processing is necessary for reasons of substantial public interest, on the basis of applicable law (including laws designed to combat money-laundering, bribery and corruption and avoidance of sanctions).

We process information about actual or alleged criminal offences on the basis that it is authorised by applicable law.

We make World-Check information available to World-Check Users, companies within the LSEG Group that require World-Check data for products or services that they offer, third parties who provide advice and services to us (including professional advisors), 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.

If information about you is included on World-Check, it is made available to the following parties:

World-Check Users. We only make World-Check information available to World-Check Users 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 User uses information on World-Check beyond the limited purposes permitted by us, we may act to terminate the World-Check User’s access to World-Check.
The LSEG Group. We disclose information about you to other companies within the LSEG 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 allow a limited number of third-party service providers to access information held by World-Check (e.g. IT systems providers, hosting providers, providers of technical support). We also allow a limited number of business partners with whom we deliver co-branded services or provide content to access World-Check data. In some cases, we also disclose information about you to our professional advisors (including lawyers, accountants, consultants and information security professionals) in connection with one or more of the purposes outlined in the “How we use information about you” section.
Authorities, Courts and Tribunals. We also disclose information about you to competent authorities (including any national and/or international regulatory or enforcement body or court or other form of tribunal) in connection with one or more of the purposes outlined in the “How we use information about you” above where we are required to do so or at their request.
Business Transfers. In order to participate in, or be the subject of, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we share information about you with prospective buyers, sellers, advisers or partners and your information may be a transferred asset in a business sale.

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.

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 World-Check information 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 restrictions on World-Check Users and business partners requiring them to only use information on World-Check (including any information about you) in connection with Checks.

World-Check is a global service and the LSEG Group is a global organization. Your personal information may be transferred to recipients in multiple jurisdictions, and 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 and which do not benefit from an adequacy determination or decision by the applicable governing bodies (e.g., the EU Commission, data protection regulator, supervisory authority, etc.). 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 (e.g. including Articles 44 to 50 of the GDPR). Often, these include contractual safeguards. More information about these safeguards (including copies, where relevant) can be obtained by contacting us here.

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.

We calculate retention periods for your personal information in accordance with the following criteria:

the length of time your personal information remains relevant to Checks;
the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations;
any limitation periods within which claims might be made;
any retention periods prescribed by law or recommended by regulators, professional bodies or associations or inter-governmental bodies (for example, the Financial Action Task Force);
the existence of any relevant proceedings.

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.

Subject to certain exceptions, we will honour any rights you have under applicable data protection laws. You have the following rights under European laws in respect of personal information on World-Check, and you may have similar rights under the laws of other countries:

Right of subject access: The right to make a written request for details of your personal information and a copy of personal information we hold about you
Right to rectification: The right to have inaccurate information about you corrected or removed
Right to erasure ('right to be forgotten'): The right to have certain personal information about you erased
Right to restriction of processing: The right to request that your personal information is only used for restricted purposes
Right to object: The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests

We do not levy a charge where you wish to exercise any of your rights, but we 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 information 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 or not required 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.

The California Consumer Privacy Notice supplements this Privacy Statement and applies solely to California consumers.

We have established processes and procedures to allow appropriate data subjects to exercise their rights under South Africa’s Protection of Personal Information Act. If you wish to exercise your rights, please visit here. For more information on our processes and procedures, and your rights, you can visit our Promotion of Access to Information Manual.

For information and disclosures applicable to data subjects covered under the Lei Geral de Proteção de Dados, please visit here.

If you have any questions, comments, complaints or suggestions in relation to how we process your personal information, or wish to exercise your rights referred to above, please contact our Privacy Office at contact@world-check.com, or you may write to:

Attention: Data Protection Officer
Refinitiv Limited
10 Paternoster Square
London, EC4M 7LS
United Kingdom

If you are an EU citizen or data protection regulator, for the purposes of the GDPR, our appointed European representative is Refinitiv Ireland Limited. Our appointed representative can be contacted at contact@world-check.com, or you may write to:

Refinitiv Ireland Limited
12-13 Exchange Place
IFSC
Dublin, D01 P8H1
Ireland

You can also find out if information about you is on World-Check here.

You also have a right to complain to a data protection regulator in the place where you live or work, or in the place where you think an issue in relation to your personal information has arisen. A list of national data protection regulators in the European Union can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. For the Information Commissioner’s Office in the United Kingdom, please visit https://ico.org.uk/.

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.

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

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

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

Refinitiv imposes usage restrictions on World-Check Users.

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

Your personal information 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 the World-Check Users want 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 information?

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 World-Check Users, we are able to lawfully process your personal information without relying on your consent.

By including my personal information 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 usage restrictions. The personal information 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 information 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 information is on World-Check automatically mean that World-Check Users cannot or will not do business with me?

No. We advise World-Check Users that they cannot rely solely upon personal information 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 information we process and decide for themselves whether to conduct business with that individual.

Is the personal information in World-Check accurate?

We maintain research standards designed to ensure the accuracy and relevance of the personal information 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 information 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 information.

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

Yes, you may request a copy of the personal information 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 information.

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 information, please send an email message to contact@world-check.com

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

An individual may, request that his/her personal information 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 information on World-Check is not absolute and we may be lawfully permitted to refrain from making any update or deletion to your personal information 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 information being processed on World-Check.

Where you do wish to proceed with a request to update or remove your personal information 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 information involved, we may also ask you to provide supporting information and/or documentation.

Additional questions about updating or removing your personal information 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 information on World-Check, that decision will be communicated to you in writing.

"Public Domain Data” means personal information (1) originally available to the public and typically over the internet; (2) that Refinitiv has a reasonable basis to believe is lawfully made available to the general public by or from: (i) the data subject (or consumer or individual to whom the personal information relates), (ii) widely distributed media, or (iii) from a person to whom the data subject has disclosed the personal information (provided that Refinitiv does not have knowledge that the data subject has restricted the information to a specific audience); or (3) lawfully made available from records, databases, and/or systems of government agencies, departments, divisions or other operating units, in electronic, paper or any other format. 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.

World-Check Privacy Statement

Who we are

What this privacy statement covers

Who we hold information about in World-Check

What personal information we process

How we use information about you

What legal grounds do we use to process your information

Who we disclose your personal information to

How we secure your personal information

Why information may be transferred abroad

How long we keep your information

Your rights

California privacy rights

South Africa - Access to information

Brazil privacy rights

How to contact us

Changes to this privacy statement

Your Questions Answered

Definitions