Who this notice concerns
This notice addresses personal information relevant to ICC Group’s corporate due diligence, third-party risk management, business intelligence and investigative assignments.
Individuals concerned may include directors, shareholders, beneficial owners, business principals, representatives, relevant associates, sources and witnesses. Depending on the assignment, other people may be included where their information is legitimately relevant.
People undergoing employment screening commissioned by a client should read our Candidate Privacy Notice. Website visitors and general business contacts should read our Privacy Policy.
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Services and responsibilities
ICC’s DD360 work can involve corporate ownership, business affiliations, regulatory history, public records, relevant media and source enquiries. Other engagements can concern commercial risk, suspected fraud, insurance claims or intellectual property matters.
The purpose, scope and responsibilities depend on the assignment. The commissioning client and relevant ICC entity must determine their respective roles under the applicable law.
A client instruction is not a universal authorisation to collect any information about any person.
Information relevant to an assignment
Depending on the lawful scope, information may include:
- Names, identifying details and business contact information.
- Directorships, ownership interests and corporate affiliations.
- Relevant professional history and qualifications.
- Public corporate, property, litigation, insolvency and regulatory records.
- Relevant sanctions, political exposure and adverse-media information.
- Business relationships and records relevant to the instructed question.
- Accounts provided by sources, witnesses or relevant individuals.
- Correspondence, analytical findings and supporting evidence.
Not every category is relevant to every assignment. Information about corporate organisations can still identify individuals and require privacy protection.
Information sources
Sources can include the commissioning client, individuals concerned, corporate registries, courts, regulators, public records, relevant media, professional databases and appropriate source enquiries.
Availability and reliability differ across jurisdictions and sources. Information from an interview or media report must be assessed in context.
Public accessibility does not remove the need for a lawful purpose or make every further use permissible.
Purposes and processing grounds
Assignment information is used to investigate the authorised question, verify relevant details, assess identified risks and prepare findings for an entitled recipient.
Related records may also be needed to explain work, address an accuracy concern, meet legal obligations or establish, exercise or defend a claim.
Where processing requires a legal basis, the relevant controller must identify one appropriate to the particular purpose. Legitimate interests require an assessment of necessity and the interests and rights of affected individuals. Consent must not be assumed simply because a client requested the work.
A separate commercial agreement does not automatically create contractual necessity for processing information about an investigation subject.
Sensitive and criminal-offence information
Some assignments may encounter sensitive information or records about allegations, proceedings or convictions.
Such information must be relevant to the authorised purpose and satisfy any additional legal conditions. Criminal-offence records must not be treated as legally equivalent to every other category of personal information.
An allegation, an unresolved proceeding or a possible name match must not be reported as an established conviction.
Fairness and accuracy
Findings should distinguish verified facts, source statements, analysis and unresolved issues.
Information should be assessed for relevance, age, context and identity matching. A limitation should not be concealed merely because a client would prefer a definitive answer.
Where information cannot be confirmed, that uncertainty should be reflected appropriately.
Reporting and other recipients
Reports are intended for the commissioning client and other recipients authorised and legally entitled to receive them.
Completing work may involve limited disclosures to relevant sources, providers, advisers or authorities. Each disclosure requires an appropriate purpose and legal justification.
Confidentiality does not mean information can never be disclosed, and it does not permit unrestricted circulation of a report.
International work
Assignments may concern activities and records in several countries. Verification may involve local sources or providers.
Cross-border collection, overseas access, storage and onward disclosure require separate consideration under applicable restrictions.
Country registrations do not establish that information is stored in each registration country or that every destination has the same legal protections.
Retention
Assignment records should be retained only for justified purposes, taking account of legal requirements, engagement terms and the need to resolve complaints or claims.
Working material, source correspondence, final reports and dispute records may require different treatment. Legal holds and lawful client instructions may affect disposal.
Notification and lawful restrictions
Individuals may be entitled to information about the processing even where records were obtained indirectly.
Confidentiality, an investigative purpose or a client’s preference does not automatically remove notification duties.
Any exception or restriction must have a specific legal basis and be applied only to the extent justified. This notice does not claim a blanket exemption for ICC investigations.
Technology
ICC’s public service information describes technology-assisted research alongside professional expertise.
Any profiling or significant decision-making based solely on automated processing requires assessment and, where applicable, further disclosures and safeguards.
A technology-generated result is not, by itself, a verified finding.
Questions, accuracy concerns and rights
Depending on applicable law and circumstances, rights may include access, correction, erasure, restriction, objection, portability and withdrawal of consent.
Requests may be subject to lawful conditions and restrictions, including protections for other individuals, legally privileged information or a specific statutory exemption. Confidentiality alone is not a universal reason to refuse a request.
Email gcc@iccverify.com with the subject “Investigative services privacy enquiry”. Explain the issue and provide a relevant reference if available. Avoid sending unnecessary sensitive evidence until an appropriate channel is arranged.
A request may require identity verification and involvement of the commissioning organisation. Applicable complaint rights remain available through the competent regulator or authority.
Related information
Read our Privacy Policy, Candidate Privacy Notice and Information Security Policy Statement for the separate activities they address.