Entrust Identity Verification Services Product Privacy Notice (incorporated PDF)

Affirm · agreement dated May 29, 2024 · Official agreement

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17 of 36 cards in Use & Processing

Use & Processing · Company practice

Identity Record Check confirms User details against third-party databases

Part 3 lists the data Entrust processes to provide each service together with a description of the service. The Identity Record Check searches third-party databases to identify whether a User is included in the relevant databases and confirms the personal data the User provided. Its categories are full name, date of birth, address and postcode (Customer optional), national identifiers where applicable (the notice gives a U.S. Social Security Number as an example), and telephone number.

Details
What it does
searches third-party databases and confirms supplied details
What it covers
name, date of birth, optional address, applicable national identifiers and telephone number

Supporting quotations

| 3. Entrust processes the data collected in (1) and (2) above and the following data on behalf of Customer in order to provide the Onfido Identity Services
| Personal Data Type | Name of Onfido Identity Service and Description
| Categories of Personal Data: ● Full name ● Date of birth ● Address and postcode (Customer optional) ● National identifiers where applicable (e.g., Social Security Number for U.S Users) | Identity Record Check Searches third party database(s) to identify whether a User is included in the relevant database(s) and confirms the personal data provided by the User
● Telephone number

Qualifications & exceptions

  • Address and postcode are Customer-optional.
  • National identifiers apply only where applicable; the example given is a U.S. Social Security Number.

Not stated here

  • The third-party databases searched are not named.

Use & Processing · Company practice

Document Check assesses whether an ID document is genuine

The Document Check assesses the likelihood that the identity document provided is genuine. It processes images of the identity document and information describing it, plus information extracted from the document electronically where applicable.

Details
What it does
assesses the likelihood the document is genuine
What it covers
document image, describing information and extracted data

Supporting quotations

| Categories of Personal Data: ● Image(s) of the identity document and information describing the identity document ● Information extracted from the identity document electronically, where applicable | Document Check Assesses the likelihood the identity document provided is genuine.

Not stated here

  • The notice does not describe the check's accuracy or what a low-likelihood result means for the User.

Use & Processing · Company practice

Document Check–Video stores a 1.5-second video of the ID document

Document Check – Video assesses the likelihood that the identity document is genuine and enhances verification by synchronously capturing a 1.5-second video of the document alongside its image. The notice says the video itself is not used for checks but is stored for customer access, providing an additional security layer. The data includes images of the document and describing information, information extracted electronically where applicable, and the document video with describing information.

Details
What it does
captures a 1.5-second document video and assesses genuineness
When
1.5-second video captured synchronously

Supporting quotations

| Categories of Personal Data: ● Image(s) of the identity document and information describing the identity document ● Information extracted from the identity document electronically, where applicable ● Video of the identity document and information describing the identity document | Document Check – Video Assesses the likelihood that the identity document provided is genuine and enhances the identity verification process by synchronously capturing a 1.5-second video of the identity document alongside the image. While the video itself is not used for checks, it is stored for customer access, providing an additional layer of security.

Qualifications & exceptions

  • The video is captured synchronously with the document image.
  • The notice says the video is stored for Customer access although it is not used for checks.

Not stated here

  • The notice does not describe access controls, retention or deletion for the stored video beyond the general retention section.

Use & Processing · Company practice

Driver Verification reads driving licence data from the document

Document Check - Driver Verification assesses the likelihood that the identity document is genuine and extracts driving licence information. It processes images of the identity document, information describing it, and information extracted from it electronically where applicable.

Details
What it does
assesses genuineness and extracts driving licence information

Supporting quotations

| Categories of Personal Data: ● Image(s) of the identity document and information describing the identity document ● Information extracted from the identity document electronically, where applicable | Document Check - Driver Verification Assesses the likelihood the identity document provided is genuine and extracts driving licence information.

Use & Processing · Company practice

Facial Similarity compares the ID face with a selfie, automatically in one variant

The Facial Similarity Check - Selfie compares the face displayed on an identity document with a facial image captured of the User to verify that they are the same. The Selfie Auto variant performs that comparison automatically and without any human review, comparing the face on the document with any other image of a face. Both variants process an image of the User's face, the face image in the identity document, and scans of face geometry.

Details
What it does
compares document face with a captured face
Condition
Selfie Auto is automatic and without human review

Supporting quotations

| Categories of Personal Data: ● Image of the User’s face ● Image of the face in the identity document ● Scans of face geometry | Facial Similarity Check - Selfie Compares the face displayed on an identity document with a facial image captured of the User, to verify that they are the same.
| Categories of Personal Data: ● Image of the User’s face ● Image of the face in the identity document ● Scans of face geometry | Facial Similarity Check - Selfie Auto Automatically (and without any human review) compares the face displayed on an identity document with any other image of a face, to verify that they are the same.

Qualifications & exceptions

  • Selfie Auto is described as automatic and without human review.
  • The Selfie variant compares a captured facial image; the Auto variant compares with any other image of a face.

Not stated here

  • The notice does not state a match threshold, the consequences of a failed comparison, or whether contested Auto results are reviewed by a person.

Cross-references

Use & Processing · Company practice

Facial Similarity–Video adds liveness and may capture a voiceprint

Facial Similarity Check - Video compares the face on the identity document with a facial image captured from a video of the User, while requiring the User to undergo liveness detection. Its data categories are video of the User including audio recordings, the face image from the document, transcribed text from the video clip where applicable, scans of face geometry, and data that may be construed as a voiceprint.

Details
What it does
compares document face with a video face and requires liveness
What it covers
video with audio, document face, transcript, face geometry and possible voiceprint

Supporting quotations

| Categories of Personal Data: | Facial Similarity Check - Video
| ● Video of the User (including audio recordings) ● Image of the face in the identity document ● Transcribed text data from the video clip (if applicable) ● Scans of face geometry ● Data that may be construed as a voiceprint | Compares the face displayed on an identity document with a facial image captured from a video of the User, to verify that they are the same, while requiring the User to undergo liveness detection.

Qualifications & exceptions

  • Liveness detection is required for this variant.
  • Audio is included in the video category, and the notice flags data that may be a voiceprint.

Not stated here

  • The notice does not say how voiceprint data is used or whether it is separated from the video; retention is addressed only generally.

Cross-references

Use & Processing · Company practice

Watchlist reports search sanctions, PEP and adverse-media databases

Watchlist Report – Enhanced searches third-party watchlist and sanctions databases. Watchlist Report - Standard searches watchlist, politically exposed persons and sanctions databases. Watchlist Report - AML also searches adverse media databases. Each report processes full name, date of birth (Customer optional) and address/post/zip code (Customer optional).

Details
What it does
searches watchlist, PEP, sanctions and adverse-media databases
What it covers
name and optional date of birth and address

Supporting quotations

| Categories of Personal Data: ● Full name ● Date of birth (Customer optional) ● Address and post/zip code (Customer optional) | Watchlist Report – Enhanced Searches third party watchlist and sanctions databases to identify whether a User is included in that database.
| Categories of Personal Data: ● Full name ● Date of birth (Customer optional) ● Address and post/zip code (Customer optional) | Watchlist Report - Standard Searches third party watchlist, politically exposed persons and sanctions databases to identify whether a User is included in that database
| Categories of Personal Data: ● Full name ● Date of birth (Customer optional) ● Address and post/zip code (Customer optional) | Watchlist Report - AML Searches third party watchlist, politically exposed persons, sanctions, and adverse media databases to identify whether a User is included in that database

Qualifications & exceptions

  • Date of birth and address/post/zip code are Customer-optional for these reports.
  • Each variant searches a different database set; AML adds adverse media.

Not stated here

  • The notice does not name the databases, the matching method or the consequences of a hit.

Use & Processing · Company practice

Ongoing watchlist screening repeats every 24 hours

Watchlist AML Ongoing searches third-party watchlist, politically exposed persons, sanctions and adverse media databases every 24 hours to identify whether a User is included. Watchlist Standard Ongoing uses the same database description and the same 24-hour frequency. Both process full name, date of birth and address and post/zip code (Customer optional).

Details
When
every 24 hours
What it does
recurring database screening

Supporting quotations

| Categories of Personal Data: ● Full name
| ● Date of birth ● Address and post/zip code (Customer optional) | Searches third party watchlist, politically exposed persons, sanctions, and adverse media databases every 24 hours to identify whether a User is included in that database
| Categories of Personal Data: ● Full name ● Date of birth ● Address and post/zip code (Customer optional) | Watchlist Standard Ongoing Searches third party watchlist, politically exposed persons, sanctions, and adverse media databases every 24 hours to identify whether a User is included in that database

Qualifications & exceptions

  • Screening recurs every 24 hours.
  • Address and post/zip code are Customer-optional; date of birth is not marked optional in these rows.

Not stated here

  • The notice does not say how ongoing screening is stopped, how long it continues, or what happens on a match.

Use & Processing · Company practice

Proof of Address Check validates a non-ID address document

The Proof of Address Check checks that a non-ID document is a suitable proof of address. It processes full name, address and postcode, an image of the proof-of-address document and information describing that document.

Details
What it does
checks that a non-ID document proves address

Supporting quotations

| Categories of Personal Data: ● Full name ● Address and postcode ● Image of proof of address document and information describing the document | Proof of Address Check Checks that a non-ID document is a suitable proof of address

Not stated here

  • The notice does not list which document types are accepted.

Use & Processing · Company practice

Autofill extracts document data with optical character recognition

Autofill classifies identity documents and, using optical character recognition technology, returns automatically extracted human-readable data from the identity document. It processes an image of the identity document and information describing it.

Details
What it does
classifies documents and returns OCR-extracted data

Supporting quotations

| Categories of Personal Data: Image of the identity document and information describing the identity document | Autofill Classifies identity documents and using optical character recognition technology, returns automatically extracted human-readable data from the identity document

Qualifications & exceptions

  • Extraction uses optical character recognition.

Use & Processing · Company practice

AAMVA check matches details against US state DMV records

The American Association of Motor Vehicle Administrators (AAMVA) Check uses the AAMVA Driver's License Data Verification (DLDV) service, via a third-party sub-processor, to search participating US state DMV databases and match a User's personal details. It processes full name, document ID number, US state code and optional data fields from the identity document at the Customer's option.

Details
Where
United States (participating state DMV databases)
What it does
searches DMV databases through the AAMVA DLDV service

Supporting quotations

| Categories of Personal Data: ● Full name ● Document ID number ● US state code ● Optional data fields from the identity Document (at Customer’s option) | American Association of Motor Vehicle Administrators (AAMVA) Check Uses the AAMVA Driver’s License Data Verification (DLDV) service (via a third party sub-processor) to search participating US state DMV databases to match a User’s personal details

Qualifications & exceptions

  • The search runs through a third-party sub-processor.
  • Only participating state DMV databases are searched.
  • Optional document fields are included at the Customer's option.

Not stated here

  • The notice does not identify the sub-processor or the participating states.

Use & Processing · Company practice

India Tax ID check confirms a PAN against the income-tax database

The India Tax ID service verifies that the Personal Account Number (PAN) provided by the User or the Customer matches the PAN found on the database held by the Income Tax Department of the Government of India. It processes full name, date of birth and PAN.

Details
Where
India
What it does
matches the PAN against the income-tax database

Supporting quotations

| Categories of Personal Data: ● Full name ● Date of birth ● Personal Account Number (PAN) | India Tax ID Verifies that the PAN provided by the User or Customer matches the PAN number found on the database held by the Income Tax Department of the Government of India

Qualifications & exceptions

  • Scope is the Government of India income-tax PAN database.

Not stated here

  • The notice does not describe consent or any additional legal basis for this check.

Use & Processing · Company practice

Phone Verification Report checks phone activity and fraud risk

The Phone Verification Report (1) searches a range of mobile network operator databases, via a third party, to verify whether a phone number a User provided is active and reachable, and (2) considers additional phone intelligence attributes to help the Customer assess the fraud risk associated with the number. The data categories are full name, address, mobile number, mobile number network history details, mobile account details and a mobile risk score.

Details
What it does
searches mobile operator databases and assesses phone fraud risk
What it covers
name, address, mobile number, network history, account details and risk score

Supporting quotations

| Categories of Personal Data: | Phone Verification Report
| ● Full name ● Address ● Mobile number ● Mobile number network history details ● Mobile account details ● Mobile risk score | (1) Searches a range of mobile network operator databases (via a third party) to verify if a phone number provided by a User is active and reachable; and (2) Considers additional phone intelligence attributes to help the Customer to assess the fraud risk associated with the phone number

Qualifications & exceptions

  • The operator databases are searched via a third party.
  • The risk information is provided to help the Customer assess the number; the notice does not say Entrust makes the decision.

Not stated here

  • The third-party provider, the databases and the scoring method are not described.

Use & Processing · Company practice

Motion checks liveness and compares the video face with the ID

Motion compares the face displayed on an identity document with a facial image captured from a video of the User to verify that they are the same, while assessing whether the person in the video is a real person or a presentation attack/spoof. It processes video of the User, the face image from the document, a background audio recording at the Customer's option, and scans of face geometry.

Details
What it does
compares faces and assesses liveness/spoof
Condition
background audio only at the Customer's option

Supporting quotations

| Categories of Personal Data: ● Video of the User ● Image of the face in the identity document ● Background audio recording (at Customer’s option) ● Scans of face geometry | Motion Compares the face displayed on an identity document with a facial image captured from a video of the User, to verify that they are the same, while assessing whether the User in the video is a real person or a presentation attack/spoof.

Qualifications & exceptions

  • Background audio is recorded only at the Customer's option.
  • Includes an assessment whether the video shows a real person or a spoof.

Not stated here

  • The notice does not describe how the spoof assessment works or its error rates.

Use & Processing · Company practice

QES package verifies identity for a qualified electronic signature

The Qualified Electronic Signature (“QES”) Package provides ETSI-certified identity verification and issuance of a qualified electronic signature, as set out in the product guide. It processes full name, email address, telephone number, and information extracted from or describing the identity document.

Details
What it does
ETSI-certified identity verification and QES issuance

Supporting quotations

| Categories of Personal Data: ● Full name ● Email address ● Telephone number; and ● Information extracted from, or describing, the identity document | Qualified Electronic Signature (“QES”) Package ETSI certified identity verification and issuance of a qualified electronic signature, as set out in the product guide

Qualifications & exceptions

  • The notice ties the package to a separate product guide.
  • ETSI certification is stated for the package.

Not stated here

  • The QES product guide is referred to but not supplied, so its detailed terms are outside this source.

Use & Processing · Context

The notice covers Onfido identity checks run as a processor

Onfido Ltd., a subsidiary of Entrust Corporation and called “Entrust” in this notice, explains here how it collects and processes personal data as a service provider/processor under applicable data privacy laws in order to provide the Onfido Identity Services. The notice is written to help business Customers understand that processing and to explain it to their Users. It expressly excludes the processing Entrust conducts as a controller for the same services: those details are said to be in the separate Onfido Privacy Policy.

Details
Who
Onfido Ltd. (referred to as Entrust)
What it does
collect and process personal data
What it covers
personal data about a Customer's Users
Why
provide the Onfido Identity Services
Condition
as a service provider/processor under applicable data privacy laws
Exception
controller-side processing is excluded and covered by the Onfido Privacy Policy

Supporting quotations

This product privacy notice describes how Onfido Ltd. (who, being a subsidiary of Entrust Corporation, is referred to in this notice as “Entrust”) will collect and process personal data as a service provider/processor pursuant to applicable data privacy laws in order to provide the Onfido Identity Services.
This notice does not provide details of the processing that Entrust conducts in relation to the Onfido Identity Services as a controller. Details of such processing are in the Onfido Privacy Policy.

Qualifications & exceptions

  • The role described is service provider/processor for the processing this notice covers.
  • Audience: Entrust's business Customers and, through them, the individuals whose identities are checked.

Not stated here

  • The Onfido Privacy Policy is referred to but not supplied, so Entrust's controller-side processing is outside this source.
  • The notice does not name the applicable data privacy laws.

Cross-references

Use & Processing · Company commitment

Identity verification helps Customers admit Users quickly and securely

The notice states that the Onfido Identity Services help Customers verify their Users so they can access their services quickly, easily and securely. When Entrust verifies an identity, carries out checks related to an identity, or provides user authentication services, the notice says Entrust is committed to protecting the privacy and security of that identity.

Details
Why
help Customers verify their Users
What it does
commitment to protect the privacy and security of the identity

Supporting quotations

The Onfido Identity Services help our Customers to verify their Users so they can access their services quickly, easily, and securely. When Entrust verifies an identity, carries out checks related to an identity, or provides user authentication services, Entrust is committed to protecting the privacy and security of that identity.

Qualifications & exceptions

  • Covers identity verification, identity-related checks and user authentication.

Not stated here

  • The source sentence does not make clear whether “they” and “their services” refer to the Customer or the User, so this card leaves that reference open.