Register Privacy Notice
Who we are
OpenOwnership is project of the Fund For The City Of New York Inc., registered at 121 Avenue of the Americas, 6th Floor, New York, NY 10013-1590, with operations in the UK.
If you are a beneficial owner of a company, we may collect and use personal information about you. We do so in order to assist transparency about the ownership of companies. We believe that this activity falls into the broad definition of “journalistic purposes” under Chapter 9, Art. 85 General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom). As a consequence we are responsible as ‘controller’ of that personal information for the purposes of those laws, but the fact that we are processing your personal information for the purposes of journalism limits the duties we owe you considerably.
The personal information we collect and use as part of the Open Ownership dataset
We obtain beneficial ownership information from official sources of corporate information.
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..
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. For a full list of our sources see our FAQ.
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. We rely on Article 85 of the General Data Protection Regulation , which covers processing for journalistic purposes and exempts us from finding a lawful basis for that processing.
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.
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 investigative 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 we do not give individuals the right to have information about them erased other than as set out below (see Redacting information below).
If you would like to exercise any of those rights, please:
- send a request to email@example.com 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:
- update the OpenOwnership 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 below, 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.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone +44 0303 123 1113.
Changes to this privacy notice
This privacy notice was published on April 1, 2019 and last updated on April 1, 2019.
We may change this privacy notice from time to time by posting an updated version of this privacy notice at this address.
How to contact us
Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us. please send an email to firstname.lastname@example.org.