Our Privacy Policies
This Privacy Policy explains how Onfido, an Entrust company, (“we”, “us”, “our”) uses personal information about our clients’ users, and others, to provide our Identity Services on behalf of our clients. Users located in the US should also refer to Onfido’s Facial Scan and Voice Recording Policy which takes priority over the information below to the extent there is any inconsistency or ambiguity.
If you are looking for details of the personal information we collect in other circumstances, please see the relevant policy listed below:
- Our Website and B2B Privacy Policy explains how we collect, use, and otherwise process personal information of people who visit our websites or otherwise interact with Onfido in a business to business capacity.
- Our Cookie and SDK Policy contains information about the cookies we use, why we use them, and your privacy choices regarding cookies.
- If you are a candidate applying for a role at Onfido, please see the Candidate Privacy Policy displayed in our Application Portal.
Please note that if you are a resident of California, Onfido’s California Privacy Notice does not apply to our use of your personal information as described in this Privacy Policy because when we use information to provide our Identity Services, we use this information as a service provider on behalf of a client. The client, as the business, may have additional obligations under California law, including the California Consumer Privacy Act, and we suggest you review their privacy policy for further details.
1. This Privacy Policy
At Onfido, we’re simplifying digital identity for everyone. We help our clients to verify their users so they can access their services quickly, easily and - most important of all - securely. When we verify an identity, carry out checks related to an identity, or provide user authentication services (our “Identity Services”), we’re committed to protecting the privacy and security of that identity.
When we process your personal information so we can provide Identity Services to a client, we are acting on the client’s behalf as their service provider and processor. The section below headed “The Information We Collect and How We Use It On Behalf Of Our Clients” explains what we do with this information, but if you are a user of an Onfido client you should review the client’s privacy policy for full information about how your personal information is collected and used.
As well as handling your personal information on behalf of a client in order to provide Identity Services to them, we may also handle your personal information on our own behalf as a controller. For example, we may use the personal information that we collect when providing our Identity Services, and personal information that is publicly available, to develop and improve our Identity Services. For information about how we use personal information as a controller, please see the section of this Privacy Policy headed “Using Information As Controller.”
We may need to update this Privacy Policy from time to time. If we make material changes, we will publish those changes before they come into effect and notify our clients so they can consider whether to update their own policies and notify their users.
2. The Information We Collect and How We Use It On Behalf Of Our Clients
To provide our Identity Services to a client, we collect certain personal information about the client’s users.
- Our clients are organizations that have asked Onfido to verify someone’s identity, or to carry out checks related to their identity.
- Our clients’ users are the individuals whose identities a client has asked us to verify or otherwise check.
We may collect personal information about a user from the client, from the user, or from third party data providers (“Data Providers”). Data Providers are trusted third party service providers or public authorities who provide additional information depending on the Identity Service a client has chosen to use.
The following paragraphs provide details of the personal information we collect on behalf of a client depending on which of our Identity Services the client chooses to use. If you are in the EEA or UK, our client is responsible for identifying a legal basis which permits your personal information to be used for the purposes described below; you should review their privacy policy for further details.
Document Checks
Onfido’s document checks verify identity documents from across the globe by analyzing an image or video of the document. Our system extracts information from the image/video or, if possible, from the security chip embedded in the document. Our models analyze the authenticity of the document, which may include machine-readable zones, barcodes, QR codes, and security chips, to verify whether the document is genuine or shows signs of tampering. 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.
Information collected: personal information extracted from a user’s identity document, for example name, document number, date of birth, nationality, type of document, issuing country, expiration date, information embedded in barcodes, QR codes, security chips and features (which will vary depending on the type of document), and the image metadata associated with the image or video of the document.
Important: If you are a user living in the Netherlands, please be advised that Onfido may automatically mask your BSN number on your identity document in our back-end systems when required under Dutch law, and particularly the Dutch Prevention of Money Laundering and Terrorist Financing Act.
Biometric Checks and Authentication
When providing biometric checks as part of our Identity Services, we’ll ask for an image or video (including an audio recording) of a user’s face (a “Selfie”), as well as an image or video to use as a reference image (for example, an image of their identity document). We generate two scans of the user’s face (one from the Selfie, and one from the reference image) and we compare those two scans to assess whether the person in the Selfie is likely to be the same person pictured in the reference image. Additionally, as part of our Identity Services, we will also evaluate the authenticity of the images and videos (including audio recordings) and identity documents, including detecting whether there is a genuine human or physical document in your photos/videos, and identifying signs of tampering, coercion or social engineering.
Except as described in this Privacy Policy under the section below headed “Fraud checks, including device integrity and fraud signals”, when performing biometric checks we do not store the extracted face scans once the check is complete. Where a client has asked us to provide an authentication service, the client may ask Onfido to store a reference image chosen by the client for each relevant user. (This image is retained in accordance with retention periods set by the client and subject to any maximum retention periods specified by Onfido or in applicable laws.) When Onfido is asked to authenticate a user, we will generate two face scans - one using a new image of the user and one using the reference image we have stored. If the two images match, the authentication is confirmed. Clients who wish to use an authentication service without the need for Onfido to store a reference image can choose to store an encrypted version of the face scan relating to a reference image themselves (including on the user’s device). When Onfido is asked to authenticate a user, we will be given access to the stored face scan and we will compare it to a new face scan that we generate using a new image of the user. If the two images match, the authentication is confirmed.
Information collected: images or videos (including audio recordings) of a user and/or of their identity document, metadata extracted from those images or videos, and data extracted from those images or videos that may be construed as a scan of face geometry or a voiceprint and which may be considered to be biometric identifiers or biometric information by applicable US biometric privacy laws. Users located in the US should refer to Onfido’s Facial Scan and Voice Recording Policy for details.
Data Verification
Onfido provides clients with data verification checks via a network of trusted Data Providers (defined above) and our own internal checks. These checks enable clients 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 information provided by the client 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 sources. At the request of a client, these services may be provided on an ongoing basis, for example where a client’s regulatory obligations require ongoing monitoring against sanction and PEP lists.
Information collected: the information collected will vary depending on the availability of checks in the user’s location and the Identity Services selected by Onfido’s clients. It may include contact details such as postal address, email address, telephone number, social security number or other national identity number, information extracted from a utility bill a user uploads or other information provided by the Data Provider e.g. a user’s mobile network operator, publicly available information from media searches, sanctions and PEP lists.
Fraud checks, including device integrity and fraud signals
Onfido leverages a number of different fraud detection capabilities. Some of these depend on the scope of the Identity Services selected by Onfido’s clients, whereas other fraud checks are applied across all of the above services. For example, Onfido will analyze the metadata associated with the user’s Selfie and the image or video of their identity document (to identify whether any editing software can be detected) to assess the likelihood that the user is genuine.
Onfido can also help clients to determine whether a device, email address or phone number has previously been used in relation to suspected fraudulent activity, shows unusual usage patterns, has been manipulated or otherwise indicates that the user may not be genuine. At a client’s request, Onfido and our Data Providers may collect ‘passive signals’ from the client (for example mobile number or email address) or a user’s device as they engage with the client’s website or app or Onfido’s Identity Services. Such information may include device identifiers, IP address, information about the device (for example the operating system used, whether the device is providing false randomized device and network information or has otherwise been compromised) and how the user interacts with it. Together this information helps Onfido and our Data Providers assess the likelihood of you being a genuine user, assign a risk score and infer certain information such as your broad geographical location from your IP address.
At a client’s request, we can also check whether we have previously verified a user on behalf of that client by comparing the information submitted as part of a new Document Check and/or Biometric Check, to information we have previously verified for that client. (More specifically, at a client’s request we will retain information (including face scans depending on the service the client has chosen to use) extracted from a user’s identity document or Selfie, and compare this retained information to the newly submitted information. As explained further below, clients determine how long we retain the extracted information). This helps our client not only verify users’ identities but further protects them and their users from fraud by helping clients understand when a user may be generating multiple identities, editing and tampering with documents or manipulating device or network information.
Information collected: the information collected will vary depending on the availability of checks in the user’s location and the Identity Services selected by Onfido’s clients. It may include: the information listed in the Document Check and/or Biometric Check sections above; data extracted from images or videos of identity documents that may be construed as a scan of face geometry and which may be considered to be biometric identifiers or biometric information by applicable US biometric privacy laws (users located in the US should refer to Onfido’s Facial Scan and Voice Recording Policy for details); mobile number, email address, IP address, device details including device identifiers and other information about the user’s device and how they are interacting with our Identity Services (for example we may collect information about the upload time, which version of our software was used, the camera name and model used to capture any images and whether there are any indicators that the device has been tampered with or emulated). We may also analyze how the user is interacting with their device to assess the likelihood of of the user being a genuine user and who they say they are, for example fraudsters will cut and paste large volumes of information from their clipboard, use this functionality multiple times and otherwise navigate between applications on their device very differently from a genuine user. Onfido and our Data Providers may also use such information to infer other information about the user, for example their broad geographical location from their IP address, or to calculate an identity risk score to assist clients in determining whether the user is a genuine user.
Onfido Reports and Automated Decision Making
Once we have verified an identity or run a check, we share the results with the client in a report (“Onfido Report”). Below, we have provided a graphical representation of an Onfido Report:
Each Onfido Report contains an overall result of ‘Clear’ or ‘Consider’:
- If we’re able to verify the identity of a user, and the requested checks do not show signs of fraud or other anomalies, we notify the client that the checks are Clear.
- If we’re unable to verify the identity of a user, or the user isn’t able to pass all requested checks or the checks show signs of fraud or other anomalies, we return a Consider result.
If we return a Consider result, we will also provide a detailed breakdown of the reasons why. (The reasons are generated from the different machine learning models and/or human powered processes that are used to verify an identity or perform a check.)
Onfido Reports contain recommendations only and the reasons behind them. It is then for the client to decide how to proceed with a user - based on the content of the Onfido Report, but also on the basis of other information available to them (including additional information they may have or decide to request from their users).
By providing our clients with these detailed Onfido Reports, our aim is to empower our clients to make informed decisions about their users and to provide help to users that are having difficulty in passing an Onfido check.
3. Using Information As Controller
As explained above, when we use personal information to provide Identity Services to our clients, we are acting on their behalf as their service provider and processor. However, we also process the personal information of users, and others, on our own behalf (as a “controller”) for the purposes described in this section. If you are in the EEA or UK, we will only use your personal information for a particular purpose where we have a “legal basis” for this. We have set out below the legal bases we rely upon for each purpose.
To develop and improve our Identity Services (including machine learning technologies)
At Onfido, our vision is to simplify digital identity. To do this, provided we have the permission of our clients and it is not prohibited by applicable law, we use the personal information we collect about our clients’ users (as described above) to improve and develop our Identity Services. For the same purpose, we may also use personal information that has been made publicly available or that we have obtained from a third party provided this is not prohibited by applicable law.
Developing and improving our Identity Services includes building and improving our technology (such as our machine learning technologies and algorithms) and developing and testing new checks, products and services to better verify a user’s identity and/or detect fraud. For example, we may need to train our models to recognise a novel fraud attack, a new version of an ID document or to minimize bias and improve performance. As part of this work, we train our technology to recognize specific patterns in information and make predictions about new sets of information based on those patterns. This is known as machine learning. We also train our human analysts to perform those tasks so they can assist when our machine learning models aren’t best suited for the task or are still learning. Sometimes, we’ll also re-run and re-submit checks to ensure our Identity Services are working properly, particularly when testing a new feature or service for quality checks. Together, these developments help make Onfido’s Identity Services stronger and safer for all clients and users.
We process personal information for these purposes on the basis that it is necessary for the legitimate interest of our clients and Onfido. Financial crime, fraud, and corruption are serious issues that affect not only the law enforcement community but financial institutions, the private sector, and other major corporations – as well as individuals themselves. As such, Onfido considers there is a clear legitimate interest in improving and developing our Identity Services for the purpose of continuing to effectively tackle and reduce fraud.
Where we use sensitive personal information for these purposes (for example, information which could potentially reveal information about someone’s racial or ethnic origin), we primarily process this information on the basis that it is necessary for reasons of substantial public interest. Such public interests include ensuring equality of treatment across all types of users by measuring and mitigating algorithmic bias with a view to providing fair and inclusive Identity Services, which effectively detect fraud, and are balanced against the rights and freedoms of users. When developing our services, Onfido implements specific measures to safeguard the rights and freedoms of those individuals whose data is used for this purpose, including pseudonymisation (where possible), impact assessments and strict security controls to safeguard their fundamental rights and their interests.
To compile statistics, benchmarking and analytics
We use personal information (such as check results, identity document type, and device metadata) to create statistics regarding the use and performance of our Identity Services. We provide these statistics to our clients so that they and we may use them to, for example, conduct benchmarking and analytics (for example, to compare a client’s missed fraud rates to the general missed fraud rate for an industry, or to analyze fraud trends). We also use these statistics to gain market insights (for example, to enhance understanding of missed fraud trends and identify fraud patterns) and to inform our decision making on product improvements. An individual cannot be identified from these statistics and where possible, we pseudonymise, aggregate and/or de-identify (and where feasible anonymise) personal information which is used for these purposes.
We process personal information for these purposes on the basis that it is necessary for Onfido’s and our clients’ legitimate interests in understanding (at the aggregate level) how people are using our Identity Services.
For compliance with applicable law/regulation, to exercise, establish or defend legal rights or claims, or to protect someone’s vital interests
Onfido may process the personal information we collect about our clients’ users (as described above) where this is necessary for compliance with a legal obligation, to exercise, establish or defend legal rights or claims, or to protect someone’s vital interests. For example, we may be required by law to:
- disclose information in response to a request from a government or law enforcement body as described in the section below headed “Government and Law Enforcement Requests”;
- collect a user’s broad geographic location (e.g. country or city-level location), either directly from them or the client or by approximating this based on the user’s device’s IP address, to enable Onfido and our clients to comply with global sanctions requirements and the increasing number of biometric and privacy laws that apply to our Identity Services. We use this broad geographic location to determine a user’s location to display the relevant consent screen and collect any necessary biometric consents or identify if a user is located in a sanctioned country where we are prohibited by law from providing services.
In connection with a business transaction or to obtain professional advice
Onfido may need to process your personal information in connection with an actual or proposed divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding, or to obtain professional advice. We process personal information for these purposes on the basis that it is necessary for Onfido’s legitimate interest in running its business in a commercial and compliant manner.
4. Data Sharing
In addition to sharing personal information with clients and Data Providers (as described above), Onfido also shares personal information:
- With third parties who help us provide our Identity Services and perform tasks on our behalf. This includes: information technology and related infrastructure providers (who provide us with a place to store your personal information); data analytics providers (who help us to analyze trends and provide market insights); and our business process outsourcing partners (whose staff perform human review and quality checks);
- With other companies in the Onfido group of companies who help us to provide our services (for example, by providing ancillary engineering, technical or customer support);
- With an actual or potential buyer, investor or partner (and its agents and advisers) in relation to a business transaction;
- With parties that provide Onfido with professional (e.g. advisory and auditing) advice and services;
- With a competent law enforcement body, regulatory, government agency, or court;
- With any other person where instructed to do so by a client. For example, if a client has configured the Identity Services to check whether an identity document has been previously identified as lost, stolen, fraudulent, or otherwise compromised by a government or other external party, Onfido may share that compromised identity document on behalf of that client, and the government or other external party may retain a copy to the extent they consider it necessary, proportionate, and lawful. Under the instruction of clients and as permitted by applicable law, Onfido currently shares identity documents with the UK Metropolitan Police as part of their Amberhill Database for such purposes; and
- To any other person where we have a legitimate legal reason for doing so.
Whenever legally possible, we seek to protect the personal information we share by imposing contractual privacy and security safeguards on the recipient of that information. In some cases, however, it’s not possible for us to do so — for example, when we have a legal obligation to disclose information to a government authority and that government authority is not willing to enter into such contractual safeguards.
If the sharing of personal information involves cross border international transfers of data, we make such transfers in accordance with relevant privacy law requirements. For example, if personal information that is processed subject to the GDPR is transferred outside of the EEA/UK to a country that the European Commission does not consider provides an adequate level of protection for your personal information, we will require the receiving party to enter into the European Commission approved Standard Contractual Clauses (and/or their UK and Switzerland equivalents). You can request a copy of these clauses by contacting us using the details in the section below headed “Contact Onfido or our Data Protection Officer.”
5. Information Security
Where possible, we pseudonymize, de-identify and/or aggregate personal information to protect privacy and minimize security risks. Pseudonymized data is where we replace, transform or remove information so that it no longer identifies an individual without additional information. Onfido also takes appropriate administrative, physical, technical and organizational measures designed to help protect the information it holds from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. For more information about information security at Onfido, please visit the Guide to Security at Onfido.
If you think you have identified a security vulnerability or bug in our Identity Services, please report it to the Onfido security team at security@onfido.com and as described in the Onfido Responsible Security Bug Disclosure Policy.
6. Data Storage
We provide our Identity Services on behalf of our clients for a variety of different reasons. Those reasons are identified by our clients, and we rely on them to tell us when they no longer need us to store the personal information we’ve collected on their behalf, subject to maximum retention periods imposed by applicable laws or defined by Data Providers or by Onfido.
Where we use personal information that has been made publicly available or that we have obtained from a third party to develop and improve our Identity Services (including machine learning technologies), we retain the information for as long as is necessary to complete the purpose for which the information was collected, subject to applicable laws and any retention periods.
Where we have a legitimate legal reason, we may store personal information for longer than described above – for example, where we are under a binding legal order not to destroy information.
7. Your Rights
Depending on where you live and subject to applicable privacy law, you may have the following rights in respect of the personal information we process about you as described in this Privacy Policy:
- the right to request access to and disclosure of information that we hold.
- the right to change and/or correct inaccurate information.
- the right to block or suppress our processing of your information. This enables you to request that Onfido suspends the processing of your information in certain circumstances.
- the right to object to our processing of your information where we are relying on a legitimate interest (or those of a third party) and you feel such processing impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- the right to request that we delete your information, subject to certain exceptions.
- the right to request portability of your information. We will provide to you, or a third party you have chosen, with your information in a structured, commonly used, machine-readable format.
- the right to withdraw your consent, if applicable. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.
- the right to lodge a complaint with your local data protection authority or regulator.
If you wish to exercise your rights in relation to how we use your personal information as described under the section headed "The Information We Collect and How We Use It On Behalf Of Our Clients”, please contact the client so they may respond to your request directly. (If you contact us instead of our client, we will notify the relevant client so they may fulfill your request.)
If you wish to exercise your rights in relation to how we use your personal information as described under the section headed “Using Information As Controller”, please contact us at privacyrequests@onfido.com or at the postal address below. If you exercise any of your data protection rights detailed in this section, we will not discriminate against you.
8. Government and Law Enforcement Requests
If you are a government or law enforcement body that wishes to request personal or confidential information related to a check that we may have conducted on a particular user, please contact the client on whose behalf the check was carried out. Since we provide our Identity Services on behalf of our clients, we are not able to disclose any information related to a specific check unless the relevant client directs us to do so, or we are subject to a legal requirement (such as a court order or statutory power mandating disclosure) to do so. If you wish to request the disclosure of information in respect of which there is such a legal requirement, please contact us at privacyrequests@onfido.com providing clear details of the legal requirement in your message.
9. Contact Onfido or our Data Protection Officer
If you would like more information about how Onfido collects and uses personal information, please contact Onfido at privacyrequests@onfido.com, or at: Attention: Privacy Office, Onfido Ltd, 14-18 Finsbury Square, 3rd Floor, London, EC2A 1AH, United Kingdom.
If you would like to raise a concern or otherwise communicate with our Data Protection Officer, you may contact them at onfido@hewardmills.com or at: Attention: Onfido Data Protection Officer, Heward Mills, 77 Farringdon Road, London, EC1M 3JU, United Kingdom.
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