Onfido Privacy Policy

Linking & Identification · Company practice

Document Checks compare identity documents with leaked or public compromised-identity data

Entrust also compares the image or video of the identity document with information about compromised identities that have been leaked or otherwise made publicly available. The notice does not describe what happens when the comparison produces a match.

Supporting quotations

We will also compare the image or video of the identity document with information about compromised identities that have been leaked or otherwise made publicly available.

Qualifications & exceptions

• The comparison uses information about compromised identities that has been leaked or is otherwise publicly available.

Not stated here

• The notice does not state what happens when the comparison produces a match, or how long the comparison data is retained.

Cross-references

• qualified by (model-proposed): Document Checks analyze identity documents to assess authenticity and signs of tampering — The compromised-identity comparison is an additional step in the Document Checks process, alongside the authenticity and tampering analysis.

Linking & Identification · Company practice

Data Verification checks compare User data with Data Provider records and internal checks

Entrust provides data verification checks through a network of trusted Data Providers and its own internal checks. The checks let Customers verify Users, detect fraud and comply with anti-money laundering (AML) and Know Your Client (KYC) requirements. Entrust compares personal data provided by the Customer or User with information held by Data Providers or extracted from documents, such as a utility bill for an address check. The available network varies by the User's location and includes voter and driving licence registers, other government databases, police databases, consumer credit agencies, sanctions and politically exposed persons (PEP) lists, adverse media, utility companies, mobile network providers and other trusted commercial or authoritative sources. In certain jurisdictions, and where selected by the Customer, authoritative-source verification may compare document-derived data, identity information and, where applicable, biometric data against a government or other authoritative database; authorized service providers may facilitate this and consent indicators and request/response data may be processed. At a Customer's request, checks may run on an ongoing basis, for example for regulatory monitoring against sanctions and PEP lists.

Supporting quotations

Entrust provides Customers with data verification checks via a network of trusted Data Providers (defined above) and our own internal checks. These checks enable Customers to verify their Users, detect fraud, and comply with anti-money laundering (AML) and Know Your Client (KYC) requirements.

We conduct these checks by comparing personal data provided by the Customer or the User with information held by Data Providers or information extracted from documents, e.g. a utility bill for proof of address checks.

Our global network of data verification services varies depending on a User's location and includes voter and driving license registers and other government databases, police databases, consumer credit agencies, sanctions and Politically Exposed Persons (PEP) lists, adverse media sources, utility companies, mobile network providers and other trusted commercial or authoritative sources.

In certain jurisdictions, and where selected by the Customer, data verification services may include authoritative-source verification that compares document-derived data, identity information, and where applicable, biometric data against a government or other authoritative database.

At the request of a Customer, these services may be provided on an ongoing basis, for example where a Customer’s regulatory obligations require ongoing monitoring against sanction and PEP lists.

Qualifications & exceptions

• The available checks and information vary by the User's location and the Services selected.
• Authoritative-source verification applies only in certain jurisdictions and where selected by the Customer.
• Ongoing checks are provided at the Customer's request.
• The information collected may include contact details, national identity numbers, utility-bill information, media-search information and sanctions/PEP information.

Not stated here

• The notice does not name every Data Provider or authoritative source used in each jurisdiction.

Linking & Identification · Company practice

Identity Record Check queries authoritative databases and may compare biometric data where supported

The Identity Record Check group (including DVS Database Check, Known Fraud Query, Country Database Query, INE Database Query, Mexico CURP by RENAPO and Mexico RFC by SAT) searches third-party, government, public-authority or other authoritative databases. It identifies whether a User is included, confirms personal data provided by the User or Customer and, where the selected Service supports it, compares document-derived data and biometric data against an authoritative source. The listed data includes full name, date of birth, address and postcode, government-issued identifiers such as Social Security Number, tax ID, voter credential number or population registry number where applicable, telephone number, information extracted from an identity document, and a face image or biometric data where required for the selected database verification service.

Supporting quotations

| Categories of Personal Data: ● Full name ● Date of birth ● Address and postcode ● National o r g o v e r n m e n t - i s s u e d identifiers where applicable, such as Social Security Number, tax ID number, voter credential number, unique population registry number, or similar identifier) ● Telephone number ● Information extracted from an identity document ● Image of the User’s face and data that may be considered biometric identifiers or biometric information, where required for the selected database verification service.

Searches third party, government, public authority, or other authoritative database(s) to identify whether a User is included in the relevant database(s), confirm personal data provided by the User or Customer, and where supported for the selected Service, compare document-derived data and biometric data against an authoritative source.

Qualifications & exceptions

• Government-issued identifiers apply only 'where applicable'.
• Face image or biometric data is collected only where required for the selected database verification service.
• Biometric comparison against an authoritative source applies only where supported for the selected Service.

Not stated here

• The notice does not identify which databases are available in each country or which support biometric comparison.

Linking & Identification · Company practice

Watchlist Reports search watchlist, sanctions, PEP and adverse-media databases

Watchlist Report products search third-party databases to identify whether a User is included. Enhanced searches watchlist and sanctions databases; Standard searches watchlist, politically exposed persons and sanctions databases; AML searches watchlist, politically exposed persons, sanctions and adverse media databases. For each, the listed data is full name, date of birth and address/post/zip code, with date of birth and address marked as Customer optional.

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 three reports.
• The databases searched differ by report: Enhanced omits PEP and adverse media; Standard omits adverse media; AML includes all listed sources.

Linking & Identification · Company practice

Ongoing Watchlist checks repeat every 24 hours

Watchlist AML Ongoing and Watchlist Standard Ongoing search third-party watchlist, politically exposed persons, sanctions and adverse media databases every 24 hours to identify whether a User is included. Both list full name, date of birth and address/post/zip code, with address optional. The notice describes the two products with the same data and search scope.

Supporting quotations

| Categories of Personal Data: ● Full name ● Date of birth ● Address and post/zip code (Customer optional) | 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 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

• The checks repeat every 24 hours.
• Address/post/zip code is Customer-optional; date of birth is not marked optional in these rows.
• The notice describes the AML Ongoing and Standard Ongoing rows with the same databases and data fields.

Not stated here

• The notice does not state when ongoing monitoring stops or how the Customer configures its duration.

Linking & Identification · Company practice

AAMVA Check searches participating US state DMV databases via a third-party sub-processor

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

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

• Only participating US state DMV databases are searched.
• The service is provided via a third-party sub-processor.
• Optional identity-document fields are included at the Customer's option.

Not stated here

• The notice does not list which states participate.

Linking & Identification · Company practice

India Tax ID verifies a PAN against the Income Tax Department of India database

The India Tax ID service verifies that the Personal Account Number (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. The listed data is full name, date of birth and PAN.

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

• The check is limited to matching the PAN against the Indian Income Tax Department database.

Linking & Identification · Company practice

UK eVisa uses a User-generated sharecode to search the UK Home Office visa record database

The UK eVisa service uses an eVisa sharecode generated by the User to search the UK Home Office's electronic visa record database and verify the identity of individuals in the UK. The listed data is a photo, first and last name, date of birth, eVisa share code and eVisa expiration date.

Supporting quotations

| Categories of Personal Data: • Photo • First and last name • Date of birth • eVisa share code • eVisa expiration date | UK eVisa Uses an eVisa sharecode generated by the User to search the UK Home Office’s electronic visa record database to verify the identity of individuals in the UK. |

Qualifications & exceptions

• The sharecode is generated by the User.
• The search is limited to the UK Home Office's electronic visa record database.

Linking & Identification · Context

Customer-Issued Entra Verified Credential integrates Microsoft Entra with Entrust verification

The Customer-Issued Entra Verified Credential row states that the Customer procures Microsoft's Entra Technology in its own environment and integrates it with Entrust's Identity Verification Services. The listed data is a photo, first and last name, email address, mobile number and date of birth. The notice does not describe the verification steps or outputs for this integration.

Supporting quotations

| Categories of Personal Data: • Photo • First and last name • Email address • Mobile number • Date of birth | Customer-Issued Entra Verified Credential Customer procures Microsoft’s Entra Technology in their environment and integrates with Entrust’s Identity Verification Services. |

Qualifications & exceptions

• The integration is configured in the Customer's environment; the Customer procures Microsoft Entra.

Not stated here

• The notice does not describe what Entrust verifies in this integration, how the credential is issued, or what data is returned to the Customer.

Linking & Identification · Company practice

Repeat Attempts and Known Faces compare new checks with information previously verified for the same Customer

At a Customer's request, Entrust can check whether it has previously verified a User on behalf of that Customer by comparing information submitted as part of a new Document Check and/or Biometric Check with information previously verified for that Customer. More specifically, at the Customer's request Entrust will retain information extracted from a User's identity document or Selfie, which may include a scan of face geometry depending on the service chosen, and compare it with newly submitted information. The notice says this helps verify identities and protects against fraud by helping Customers understand when a User may be generating multiple identities, editing or tampering with documents, or manipulating device or network information. The maximum period a Customer may instruct Entrust to store and use face scans for these services is 365 days after the Company or User submitted the image/video used to generate the scan.

Supporting quotations

Repeat Attempts, Known Faces and Document Known Faces. At a Customer’s request, we can check whether we have previously verified a User on behalf of that Customer by comparing the information submitted as part of a new Document Check and/or Biometric Check, to information we have previously verified for that Customer.

More specifically, at a Customer’s request we will retain information (which may include a scan of a User’s face geometry depending on the service the Customer has chosen to use) extracted from a User’s identity document or Selfie, and compare this retained information to the newly submitted information.

This helps our Customer not only verify Users’ identities but further protects them and their Users from fraud by helping Customers understand when a User may be generating multiple identities, editing and tampering with documents or manipulating device or network information.

The maximum period of time for which a Customer may instruct Entrust to store and use face scans for the purpose of these services is three-hundred and sixty-five (365) days after the Company or the User submitted to Entrust the image / video used to generate the face scan.

Qualifications & exceptions

• The comparison is performed only at the Customer's request and only for that Customer's previously verified Users.
• Retained information may include face-geometry scans depending on the service the Customer chose.
• The 365-day maximum applies to Known Faces and Document Known Faces among the listed services.

Not stated here

• The notice does not describe how matches are reviewed or what a Customer does with a match result.

Linking & Identification · Company practice

Repeat Attempts stores document data and flags anomalous cross-matches with other Users' documents

Personal data extracted from a User's identity document during a Document Check is stored in the Repeat Attempts Database and compared with the same data points from other documents submitted by the Customer's new Users for detecting and preventing fraud. Abnormal or inconsistent matches are flagged as a possible indicator that the new User's document is not genuine. The listed data is a User unique identifier, image of the identity document, information extracted from the document, a document image hash number, and information about anomalous cross-matches with other documents.

Supporting quotations

| Categories of Personal Data: ● User unique identifier ● Image of the identity document ● Information extracted from the document ● Document image hash number ● Information about anomalous cross-matches with other documents | Repeat Attempts Personal Data extracted from the User’s identity document during a Document Check are stored in the Repeat Attempts Database and are compared to the same data points from other documents submitted by the Customer’s new Users for the purposes of detecting and preventing fraud. Abnormal/inconsistent matches will be flagged as a possible indicator that the document presented by the new User is not genuine. |

Qualifications & exceptions

• The comparison is with documents submitted by the Customer's new Users, not all Entrust customers.
• A flagged abnormal match is a 'possible indicator' that the document is not genuine, not a conclusive finding.

Not stated here

• The notice does not state how long Repeat Attempts data is retained.

Linking & Identification · Company practice

Known Faces compares a new biometric check with prior checks and adds the new face scan to the database

Known Faces compares the face on the image or video provided for a new Biometric Check with a database of faces supplied for previous Biometric Checks performed on the Customer's behalf, and alerts if there is a match. It then adds the face-geometry scan extracted from the newly provided image or video to that database. The listed data is a User unique identifier, image or video of the User's face, check status/outcome and related tracking information, and scans of face geometry. The maximum period a Customer may instruct Entrust to store and use face scans for these services is 365 days after the Company or User submitted the image/video used to generate the scan.

Supporting quotations

| Categories of Personal Data • User unique identifier • Image or video of the User’s face • Check status/outcome and related tracking information • Scans of face geometry | Known Faces (1) Compares the face on the image / video of the User provided for the purposes of a new Biometric Check against a database of faces supplied for previous Biometric Checks performed on the Customer’s behalf and alerts if there is a match, and (2) adds the scan of face g e o m e t r y e x t r a c t e d f r o m t h e n e w l y provided image/video to the database in (1). |

The maximum period of time for which a Customer may instruct Entrust to store and use face scans for the purpose of these services is three-hundred and sixty-five (365) days after the Company or the User submitted to Entrust the image / video used to generate the face scan.

Qualifications & exceptions

• The comparison database contains faces from previous Biometric Checks performed on the Customer's behalf.
• A match produces an alert; the notice does not state the Customer's resulting action.
• The 365-day maximum applies to Known Faces, Document Known Faces, Authentication: Motion, Face Authentication, Biometric Passkey and Liveness Verification.

Not stated here

• The notice does not describe how a match alert is reviewed or what decision the Customer makes.

Cross-references

• exception to (model-proposed): Extracted face scans are not kept after a check, except for fraud checks — Known Faces is one of the fraud-check services that operates as an exception to the general no-storage rule for extracted face scans: it adds the new scan to a comparison database and can retain it up to the stated maximum.

Linking & Identification · Company practice

Document Known Faces compares a new document check with prior document checks and adds the new scan

Document Known Faces compares the face on an image or video of the User's identity document provided for a new Document Check with a database of faces supplied for previous Document Checks performed on the Customer's behalf, and alerts if there is a match. It then adds the face-geometry scan extracted from the newly provided image or video to that database. The listed data is a User unique identifier, image of the identity document, check status/outcome and related tracking information, and scans of face geometry.

Supporting quotations

| Categories of Personal Data • User unique identifier • Image of the identity document • Check status/outcome and related tracking information • Scans of face geometry | Document Known Faces (1) Compares the face on an image / video of the User’s identity document provided for the purposes of a new Document Check against a database of faces supplied for previous Document Checks performed on the Customer’s behalf and alerts if there is a match, and (2) adds the scan of face geometry extracted from the newly provided image/video to the database in (1). |

Qualifications & exceptions

• The comparison database contains faces from previous Document Checks performed on the Customer's behalf.
• A match produces an alert; the notice does not state the Customer's resulting action.
• The 365-day face-scan storage maximum stated for these services applies.

Not stated here

• The notice does not describe how a match alert is reviewed or what decision the Customer makes.