Public Records Privacy Notice relating to personal data
Our privacy notice contains important information on who Doorda are, along with:
- how and why we collect, store, use and make personal information available;
- details of an individual’s rights in relation to the personal data we may hold;
- how to contact us if you have a question or complaint regarding the way we process personal information.
This Privacy Notice governs the information that forms part of the Doorda data product sets (i.e. the database of information about companies, including their ownership and connected directors).
Doorda exists to make data more accessible, discoverable and easier to consume.
This is achieved by maintaining a database of information about companies, including ownership, connected directors and associated trading locations that we collect from a variety of public sources.
We present this information in such a way that it can be used for the broader public benefit, by:
- increasing corporate transparency,
- creating a more trusted business environment and assisting in tackling the use of companies for criminal or anti-social purposes (for example for identifying and exposing corruption, money laundering and organised crime).
Who we are
Doorda is a trading name of Doorda Ltd, which is a company incorporated in England and Wales (Company Registration Number 8397038).
In order to provide our service, we collect, use and make available certain personal information. We do this in accordance with the principles set out in this Privacy Notice, and in compliance with the General Data Protection Regulation (“GDPR”) which applies across the European Union (including the United Kingdom).
For the purposes of the GDPR, we are a “data controller” of personal information and as such are registered with the Information Commissioners Office (Registration number: ZA256403).
The personal information we collect and how we use it
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data includes, registered directors address, email address and telephone numbers.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes [information about how you use our website, products and services].
- Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How is your personal data collected?
Most countries publish some information about companies as part of the official public record. This often includes information about the ownership of a company, along with details of certain individuals and officers associated with a company. As the owners and officers of a company are often (though not always) individuals, this means that much of this information will consist of personal information.
The information that we collect will vary from country to country depending on the information contained on the official public record for the relevant country. 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, occupation, or even occasionally date of birth.
Doorda aim to be completely open and transparent about the source of information we collect and wherever possible provide a link to the source of the data we have collected on request.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- purchase our services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources. Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(c) search information providers;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
- Identity and Contact Data from publicly available sources such as Companies House and third party providers based inside the EU.
How we use your personal data
Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us via email: email@example.com. Upon receiving a request not to be marketed to, we will update our Hosted solution and API updating the data that we hold. This will ensure that moving forward you will not receive any further marketing material or correspondence from us or our partners.
Who can access the information collected by Doorda
Our mission is that that responsible organisations and individuals should have easy access to the information we collect and maintain. In delivering this we make the data we hold available to individuals and organisations via the following:
- the Doorda API, Authorisation required
- the Doorda Host, Account required
- bulk download to user and customers on a case-by-case basis, supplied securely by Doorda
We will also share information with law enforcement or other authorities if required by applicable law.
How long does Doorda keep personal information
The information we collect forms part of our historical archive of company information.
Maintaining this on an on-going basis is fundamental to our stated mission, and is particularly important for those using our services for investigative purposes.
Accordingly, we do not automatically delete or remove information after a certain period of time (as the European Court of Justice has ruled, “matters requiring the availability of personal data in the companies register may arise for many years after a company has ceased to exist”).
Our grounds for processing personal information
We collect, store, use and make personal information available in order to further our mission – namely to maintain an accessible record of company data. We rely on Article 89 of the GDPR which covers archiving purposes in the public interest.
In the vast majority of cases, the personal information we collect will also have been made public by the data subject themselves through the submission of such information to a public register.
We do not provide any automated decision making services.
Under the General Data Protection Regulations, you have a number of important rights. For the corporate database we hold, these 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). You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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 legitimate interest in providing a comprehensive and accessible record of information about companies means that we do not give individuals the right to have information about them erased other than as set out below (see Redacting information).
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Transfer of your information out of the EEA
The nature of our web-based service means that information may be available to persons outside the EEA. Doorda does not routinely transfer the information it holds outside the EEA, it is possible for the information contained in our database to be accessed from anywhere in the world. Making such information available is consistent with our mission.
If we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Keeping personal information secure
We have extensive security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We also have procedures in place to deal with any suspected data security breach and will issue a public notification of any security breaches in accordance with our obligations under applicable law (including under the GDPR).
If we are informed that a public company register has removed (or restricted access to) certain information about a person concerned with a company we will:
- update the Doorda records in a timely manner; and
- inform any third parties using our service that the records have changed
In keeping with our mission to maintain a historical archive of public information, we will normally only redact information when a public register has redacted or requested suppression of the data.
Other Specific Issues
Public interest – Free speech v Privacy
As stated above, most countries publish information about the ownership of companies together with details of the directors and officers of such companies. This will result in personal data about individuals forming part of the public record which can, in certain cases, lead to a conflict between the right to know, the right to free speech and the right to privacy. Particular sensitivities can be felt where, for example, directors or companies choose to submit a residential address to the relevant public register. Where the balance is drawn between these potential conflicts is not always clear and varies from country to country.
Our approach is that Doorda shouldn’t seek to be an arbiter in this regard. We strive to accurately reflect the information that is published in the public records and we will defer to the official company register on what information is published about the individuals connected with companies, especially the owners, officers and directors.
How to complain
Our data team should be able to resolve any query or concern you raise about our use of your information (see Contact us).
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
If you have any questions about this Public Records Privacy Notice, or the information we hold about you, please contact our data team via email at firstname.lastname@example.org
If you wish to contact us for any other reason, we can be contacted: By Email: email@example.com
Changes to this privacy notice
This privacy notice was published on 30 January 2019 and last updated on 30th January 2019.
We may change this privacy notice from time to time by posting an updated version of this privacy notice at this address.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us via email at firstname.lastname@example.org.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
– If you want us to establish the data’s accuracy.
– Where our use of the data is unlawful but you do not want us to erase it.
– Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
– You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.