Register Privacy Notice
It serves to inform data subjects about the uses of their personal information and their data protection rights in circumstances where providing privacy information directly to the data subjects is disproportionate to the processing of this information.
We obtain beneficial ownership information from official sources of corporate information. These sources include, but are not limited to:
- The UK’s Persons of Significant Control (PSC) Register
- Denmark Central Business Register (CVR)
- Slovakia Public Sector Partners Register
- Ukraine Unified States Register (EDR)
For a full list of our sources see our FAQ.
The information that we collect will vary from territory to territory depending on the information contained on the official public record for that territory. In addition to an individual’s name, it is common for the official public record to contain:
- an official address for that individual (not least to ensure that legal redress can be obtained); and
- other information about that individual, including nationality, date of birth and occasionally occupation..
As reflected above, we aim to be completely open and transparent about the source of information we collect and wherever possible we publish a link to the source of the data we have collected.
Reasons we can collect and use your personal information
We collect, store, use and make personal information available in order to further our journalistic mission - namely, making information about the ownership of corporations available to the public.
Publishing for journalistic purposes
In the vast majority of cases, the personal information we collect has been made public by the data subject themselves through the submission of such information to a public register.
For onward processing, we rely on the exemptions which derive from Article 85 (2) of the General Data Protection Regulation , which covers processing for journalistic purposes and exempts us from the need to specify a lawful basis for that processing.
The processing of beneficial ownership data and related personal information in the Open Ownership Register is vital to reducing corruption and tax evasion, giving fairer development opportunities, building societal trust, and enhancing corporate transparency.
How we use your personal information and who can access it
We publish your information on our website under the name of the company or companies with which you are associated in our database. Anyone who has access to the web may be able to access that website and obtain copies of the information about you.
How long your personal information will be kept
The information we collect forms part of our historical beneficial ownership information register.
Maintaining this on an on-going basis is fundamental to our information mission, and is particularly important for those using our services for journalistic purposes. Matters requiring the availability of beneficial ownership data may arise for many years after a company has ceased to exist.
We keep information about the beneficial owners for the lifetime of the company, and 20 years after its dissolution. This includes details of historical beneficial owners and also applies to dormant companies.
Article 85 of the General Data Protection Regulation related to processing for journalistic purposes provides an exception to most rights listed under Chapter 3 (Rights of the data subject). For the beneficial ownership information we hold, your rights include:
- The right to fair processing of your information and transparency over how we use your personal information; and
- The right to lodge a complaint with a supervisory authority (see How to complain below).
To ensure that our collection and processing of your information is fair, we also give you the right to:
- obtain any information as to the source(s) of information that we hold about you;
- access personal information that we hold about you; and
- require us to correct any mistakes in information we hold about you;
Note that our journalistic mission related to beneficial ownership information means that an individual's request to have information about them erased will be subject to the application of the journalistic exemption (see Redacting information below).
How to contact us
If you would like to exercise any of those rights, please:
- send a request to firstname.lastname@example.org with the subject line: Privacy Request
- let us have enough information to identify you; if there is any ambiguity about which person you are – for example where several people have the same name – please supply enough information for us to understand who you are.
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know the information to which your request relates (for example: which page on our website displays it?)
If we are informed that a public company register has removed (or limited access to) certain information about a person concerned with a company due to exceptional circumstances (for example, because of a serious risk to personal safety), we will take steps to promptly:
- update the Open Ownership records in a timely manner; and
- institute a procedure for temporarily removing the relevant information from the OpenOwnership records while this is being carried out.
In keeping with our public mission to support freedom of information, we will normally only redact information when a company register has redacted it due to exceptional circumstances (such as a serious risk to personal safety).
You can inform us of any application made to a public company register to remove or limit access to your information by contacting us (see above, How to contact us). Your request should contain full details of the reasons for requesting such removal or limitation. Note that requests for redaction of personal information must be made by the individual concerned or their legal representatives (including in the case of minors, their parents or guardians) and we will require proof of ID.
Transfer of your information out of the EEA
The nature of a web-based service means that information will be available to persons all over the world. Whilst OpenOwnership does not routinely transfer the information it holds outside the EEA, it is possible for the information contained in the OpenOwnership database to be accessed from anywhere in the world. Making such information available to all without restriction is consistent with our journalistic mission.
How to complain
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk) or your national EU Data Protection Authority. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or relevant Data Protection Authority, so please contact us in the first instance.Last updated December 2022