Complying with any requirement of law, regulation or a professional body of which we are a member
As with any provider of professional services, we are subject to legal, regulatory and professional obligations. We keep records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data. For example, when conducting customer due diligence measures to comply with anti-money laundering regulations we carry out searches to identify politically exposed persons and heightened risk individuals and organisations, and to check that there are no issues that would prevent us from working with a particular customer, such as sanctions, criminal convictions (including in respect of company directors and beneficial owners), conduct or other reputational issues. Where we do not have a legal obligation, we have a legitimate interest in processing personal data as necessary to meet our regulatory obligations.
If you wish to become our customer (and periodically thereafter), we have a legal obligation to verify your identity. We do not need to obtain your consent to do this because it is a legal obligation imposed upon us. However, we are obliged to inform you that this will take place. We may achieve this by:
- performing a search with a credit reference agency. This will leave a footprint on your credit file as evidence that the check has taken place. This footprint is not the same as a credit check footprint and has no impact at all on your credit rating. It just leaves a footprint that proves we have satisfied the legal obligation to verify your identity. Even when these identity checks are performed periodically their repetition has no impact on your credit rating; and/or
- evaluation of traditional ID-check documents (passport, driver’s licence etc) and the use of an electronic signature complying with the European Union Trusted Lists (EUTL).