We don’t know where you live
Jinfo Blog

31st August 2009

By Tim Buckley Owen

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Directors of United Kingdom companies engaged in animal research or other controversial activities may be able to breathe more easily from this October following the introduction of new Companies House guidelines restricting access to information on directors’ home addresses. Although the information will continue to be required as part of director registration it will not normally be made public. However, the new rules will only automatically affect new directors. Existing ones will have to apply if they want their home addresses removed from the public record, and must pay £140 for the privilege (http://digbig.com/5bafwm). Both the new Companies House guidelines and the associated briefing from the Department for Business, Enterprise & Regulatory Reform (http://digbig.com/5bafwn) say that existing directors may wish to apply to have their address details withheld if they are ‘at serious risk of violence or intimidation’ as a result of the activities of a company of which they are a director, or if they have previously been employed by the security or secret intelligence services or the police. Fair enough – but in these specific circumstances, the details are withheld not just from individual researchers but from credit reference agencies as well – and that requires rather more justification. Of course there are plenty of other ways to establish the identity of a company director with reasonable certainty; try Penny Crossland’s review of Know Your Customer products at http://www.vivavip.com/go/e16222 for instance, or Donna Fryer’s VIP article on using the Big Three – Factiva, Dialog and LexisNexis – to find people information (http://web.vivavip.com/go/shop/magazine/62). But it’s with smaller companies unlikely to attract the attention of the mainstream or trade media that this sort of unequivocal individual identification really matters. In those circumstances it is to services like, for example, Experian’s Universal ID Check that due diligence researchers may need to turn (http://www.vivavip.com/go/e11261). And Experian was among a number of interested parties that commented on the revised draft regulations that will now implement the change. Respondents asked that credit reference agencies be able to supply protected information to their own clients, perhaps conditionally on the consent of the data subject; that agencies be able to use protected information for statistical analysis where no individual could be identified; and that protected information could be processed and used in the UK only but not elsewhere in the European Union (http://digbig.com/5bafwp). To each of these suggestions, the government said no. Although well intentioned, this new UK restriction is hardly likely to make the job of the credit reference agencies as trusted third parties any easier. Due diligence researchers will want to be watchful for any signs of its misuse.

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