- The Information We Collect and the Onfido Identity Lifecycle
- Using Information for our Identity Services
- Facial Biometric Comparison
- Automated Decision Making and Onfido Reports
- Sharing Information Outside Onfido
- Information Security
- Data Storage
- Your Rights
- Government and Law Enforcement Requests
- Contact Onfido, our Data Protection Officer or a Privacy Supervisory Authority
LAST UPDATED: 27 MAY 2021
Where the laws of Illinois, Texas, or Washington apply, reference should also be made to Onfido’s Facial Scan Policy & Release. Where the laws of Illinois, Texas, or Washington apply, Onfido’s Facial Scan Policy & Release prevails over the information below to the extent there is any inconsistency or ambiguity.
The Information We Collect and the Onfido Identity Lifecycle
To provide our Identity Services, we need to collect certain information about our clients’ users. The exact information needed depends on the check that’s being carried out or the service being provided on behalf of our client. For example, when verifying the identity of a user, we’ll ask for an image or images of their identity document as well as a picture or video of their face. We’ll then seek to verify whether the identity document is likely to be genuine and whether the person in the photo or video is likely the same person pictured in the identity document. We will also look to identify signs of fraud (for example, someone wearing a mask to impersonate another person or to conceal their own real identity). If the user is successful on both the document and facial verification checks, Onfido’s client will likely consider the user to have proven their identity.
In some cases, we may also further check whether we have previously verified a user on behalf of a specific client by comparing the picture of their face to the pictures previously provided by that client. This helps our client not only verify identity but further protects them and their users by helping them understand when a user may be generating multiple identities.
To do all of this, we closely examine the information contained in the images, including the machine-readable data (such as an identity document’s barcode) and the image metadata (such as the name of the camera model used to take the image).
The Onfido Identity Lifecycle below shows the different sources of the information that we collect.
1. The Client
Clients are organizations that have asked Onfido to verify an identity or carry out checks related to that identity. Once we have verified an identity or run a check, we share the results with the client in an Onfido Report, as described further below. The client then decides how they want to proceed with the user based on the results. In some cases, the client might ask for additional information before making a decision. Also, some clients only ask us to carry out a check if an earlier check was passed or not passed. This ensures we only do the minimum number of checks needed.
2. The User
Users are individuals whose identities we verify or otherwise check on behalf of our clients. We collect users’ information from clients or directly from the users themselves. This information might include an image or images of an identity document (e.g. a passport or a driver's license), photos (at times, taken in quick succession for anti-fraud purposes) or a video of the user, and the biometric facial identifiers extracted by Onfido from those images. This enables us to help the client verify that the user is the true owner of the identity document and that the document does not show signs of fraud. In some circumstances, we may also collect device identifiers to help us understand whether a device has previously been used in relation to suspected fraudulent activity. Similarly, we also collect information about compromised identities that have been leaked or otherwise made available on the internet to further combat fraud. Lastly, we will collect IP addresses to determine the city and country in which a user is located so that we may provide them with a localised service, where required to meet our legal obligations. We may also consider whether the IP address has been manipulated or shows unusual usage patterns.
3. Data Providers
Data providers are used to provide additional information when our clients require specific checks about users. For example, if we need to verify a user’s right to drive, we might ask for additional information from the appropriate governmental agency.
We also keep logs of how our clients, users, and data providers interact with our Identity Services. This might include timestamps of when the information was submitted to Onfido, and information about the device used to submit that information.
Sometimes, we receive information we don’t need to provide our Identity Services. For example, instead of a picture of their identity document, a user might upload a completely unrelated image. When this happens, we seek to delete this data.
Using Information for our Identity Services
At Onfido, our mission is to create a more open world, where identity is the key to access. To do this, we use the information we collect for our own internal use to improve and develop our services.
Passing an Onfido Check
If we’re able to verify the identity of a user and the user is able to pass all requested checks, we notify the client who can then continue with their onboarding process.
Not Passing an Onfido Check
If we’re unable to verify the identity of a user or the user isn’t able to pass all requested checks, we recommend to the client that they conduct additional checks before continuing with the onboarding process. We sometimes help with those additional checks too.
Developing our Identity Services
To further develop our Identity Services, we train our computers 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’ve gathered a substantial and unique set of images from around the world, from which we can train our machine learning models to locate and extract the information in documents, to detect fraudulent documents, and to engage in facial verification.
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 assurance. Together, these developments help make Onfido’s Identity Services stronger and safer for all clients and users.
We use information to provide and maintain our Identity Services on behalf of clients on the basis that the user has consented to the processing or otherwise requested Identity Services, the client has a legitimate or lawful reason for requesting Identity Services, or the processing is necessary to carry out a task in the public interest or for reasons of substantial public interest.
We also use information to further develop our Identity Services on the basis that the processing is necessary in the legitimate interest of the client or Onfido, the processing is necessary to carry out a task in the public interest or for reasons of substantial public interest, the processing is necessary for scientific research purposes, or the user has provided their consent.
Facial Biometric Comparison
When providing our Identity Services, we will frequently extract and compare numerical biometric data from facial images to understand whether two faces are likely to be a match. We do this on behalf of our clients for several reasons. Primarily, we will check whether a user owns their identity document by comparing an image of their face to the facial image contained in the identity document. We will also check whether those facial images show signs of fraud - for example, by comparing a person’s numerical biometric data to those of known masks. When we do this, we do not retain the extracted numerical biometric data for any length of time beyond this comparison.
In addition, we may also check whether we have previously verified a user on behalf of a specific client to help that client understand when a user may be generating multiple identities. To find out if the user is known to a specific client, we compare the facial image of the user to the facial images of other users previously verified on behalf of that specific client. To provide this check quickly, we store the numerical biometric data extracted from the previously collected facial images until the client deletes those original images.
Lastly, for our authentication service, we maintain a facial image for each of our client’s users. For each authentication attempt, we will capture a new facial image from the user and compare this to the one we hold for them. If the two images match, the authentication is confirmed. The facial image we retain for each user is in the form of numerical biometric data and we store this numerical biometric data for as long as our client directs.
Automated Decision Making and Onfido Reports
Below, we have provided a graphical representation of an Onfido Report:
By providing our clients with these detailed Onfido Reports, our aim is to empower our clients to make informed decisions about users and to provide specific help to users that are having difficulty in passing an Onfido check.
Sharing Information Outside Onfido
As well as sharing information with clients, users, and data providers (as described above), Onfido also shares information with external parties that are performing tasks on our behalf (including sub-contractors or our affiliates) and with other companies, organizations, government bodies, and individuals outside Onfido where we have a legitimate legal reason for doing so (for example, in connection with any merger or acquisition or to comply with a court order) or where we have been instructed to share the information on behalf of our clients.
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.
Whenever legally possible, we seek to protect the information we share by imposing contractual privacy and security safeguards on the recipient of the information. This is particularly important in cases where the recipient is located in a country that has different or lesser privacy laws than those of the country where the information was originally collected. 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 isn’t willing to enter into such contractual safeguards.
Onfido takes appropriate administrative, physical, technical and organizational measures designed to help protect information about users 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 email@example.com and as described in the Onfido Responsible Security Bug Disclosure Policy.
We perform 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 information we’ve collected on their behalf. Once instructed, either through our agreement with the client or through an ad hoc request, we delete the information we have collected about users when performing the requested Identity Services.
If you, as a user, would like to make a specific request to have your information deleted, please make that request directly to the client that carried out your related check. For more information about how to do this, please see below under “Your Rights”.
Where we have a legitimate legal reason, we may also store information for longer than described above – for example, where we are under a binding legal order not to destroy information.
If you would like to access a copy of, delete, or otherwise exercise control over your personal information, please contact Onfido at firstname.lastname@example.org, or the postal address below. Please be aware, for most requests Onfido may need to notify the relevant client (as described above in the Onfido Identity Lifecycle) so the client (and not Onfido) may fulfill the request. This is necessary where Onfido is acting on the client’s behalf.
Government and Law Enforcement Requests
As Onfido provides its Identity Services on behalf of its clients, Onfido will not disclose any information related to a specific check pursuant to a government or law enforcement request unless at the direction of a client or if there is a binding legal order to do so. This is necessary for us to comply with our legal obligations. Any government or law enforcement body requesting information related to a specific check may contact us at email@example.com, and we will seek to put you in contact with the relevant client.
Contact Onfido, our Data Protection Officer or a Privacy Supervisory Authority
If you would like more information about how Onfido collects and uses information, please contact Onfido at firstname.lastname@example.org, or at:
Attention: Privacy Office Onfido Limited 3 Finsbury Avenue London EC2M 2PA United Kingdom
If you would like to raise a concern with or otherwise communicate with our Data Protection Officer, you may contact them at email@example.com, or at:
Attention: Onfido Data Protection Officer Heward Mills 77 Farringdon Rd London EC1M 3JU UK