What is Personal Data

Personal Data means any piece of information that can be used to identify you. Obvious examples of personal data might include your name and postal address, an email address or date of birth.

However, even 'online identifiers' such as IP addresses and cookie IDs could be personal data. In a world where our lives are increasingly lived 'online', we are all creating digital identifiers - when you're exercising, listening to music online, messaging friends or doing anything that involves a smartphone or connected device. Your fridge, car or washing machine can now be hooked up to the internet - all of these could be personal data when linked to other data about you.

Personal data may also include special categories of personal data, such as ethnic origin, religion or sexual orientation. These are considered to be more sensitive and organisations may only process them in more limited circumstances, and with additional protections for you.

Where do we obtain personal data from?

Third party partners

We do not collect personal data directly from you but obtain it from several sources. To help our clients send you marketing communications, our marketing database brings these sources of data together, ensuring that the data is cleaned, names and addresses properly formatted and validated as being current and relevant industry, third party commercial and internal suppression files applied to screen out individuals who do not wish to be subject to marketing or can't respond.

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Third party partners for marketing data

We work with a small number of partners who actively collect personal data from consumers (and who, therefore, have direct contact with you already) and where appropriate notice has been given to you for them to pass your information to Experian for use in our marketing products and services. These partners collect data through channels such as lifestyle surveys and clubs, competition and money saving / offer websites.

We obtain relatively little actual personal data from our data partners and this consists of:

  • Contact data - name, postal address, email address and mobile phone number. We only take contact data from these partners where permission exists for contact for marketing purposes through the relevant channel(s) e.g. by post or email (see the section on our Prospect Services on our How we use Your Personal Data page). Note that Experian does not provide landline or mobile numbers to organisations to be used for telemarketing or SMS marketing for prospecting for new customers, as we recognise the intrusiveness of telephone and mobile channels when used for this marketing activity.
  • Date of birth - this is your self-reported data and will have been shared by some of our data suppliers who collect this information and where appropriate permissions exist to pass this on to third parties like Experian.
  • Home and motor insurance renewal dates - this is your self-reported data and will have been shared by some of our data suppliers who collect this information and where appropriate permissions exist to pass this on to third parties like Experian.
  • Internet Protocol (IP) address - IP address records are shared with us by some of our data suppliers who collect this information where appropriate permission exists to pass this on to third parties like Experian.

Experian Marketing Services’ current list of data partners are listed below. Click here to view a full list of the data partner and source websites.

Blue Volt Marketing Ltd

King William Walk, Greenwich, London SE10 9HU


Data Locator Group (DLG / PDV)

Sunningdale, The Belfry Business Park, 13 Colonial Way, Watford, WD24 4WH


MyOffers 2019 Ltd

Sunningdale, The Belfry Business Park, 13 Colonial Way, Watford, WD24 4WH


Omnis Data Ltd

Courtwood House, Silver Street Head, Sheffield, S1 2DD


Data Mixx Ltd (DML Connect)

The Stables, Peper Harrow Park, Godalming, Surrey, GU8 6BQ


Mdeg Ltd

The Core Business Centre, Milton Hill, Steventon, Abingdon, Oxfordshire OX13 6AB


Newscore Media LLC

The Preference Centre Ltd, 13th Floor, City Tower, Piccadilly Plaza, Manchester M1 4BT


Marketing Punch

Kestrel Court, Waterwells Drive, Quedgeley, Gloucester GL2 2AT


AffilyAds

Kropaarstraat 1A, 1032 LA, Amsterdam, Netherlands

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Third party digital identification partners

We work with third-party partners who collect digital identifiers (IDs) via websites and mobile apps when people interact with them. These partners provide us with these IDs, including IP addresses, where permission has been obtained for this data to be shared with us.

We use this data to:

  • Check the accuracy of data we obtain from other third-party sources (see “Third party partners for marketing data”) to ensure the IP addresses that we hold are up to date.
  • Connect advertisers and publishers together to enable relevant advertisements to be displayed across digital marketing channels, such as websites, social media platforms, mobile apps, and on other web connected devices such as Smart TVs (see the section on our “Powering consistent marketing” for more information).

Digital Envoy / Digital Element

6525 The Corners Parkway NW Suite 400, Peachtree Corners, GA 30092


ID5

15 Bishopsgate, London, EC2N 3AR


Unacast

Karl Johans gt. 21, 0159 Oslo, Norway

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Third party partners for suppression data

Suppression data has several purposes but is essentially personal information about individuals (such as the name, address and/or telephone number) whose details should be removed from a contact database, for example from a database of names and addresses intended for a postal marketing campaign.

These records may need to be removed because:

  • they are no longer accurate, for example where it is known that an individual no longer lives at that address.
  • an individual has passed away.
  • an individual has expressed a preference to be excluded from marketing.

Our clients use suppression data to either remove records from their files, or to flag their data where a match has occurred, so this can be imported back into their marketing database and acted upon. We also use suppression data when building our own products and services.

Responsible use of suppression files by organisations:

  • ensures that our records and those of our clients are fully up-to-date and accurate, ensuring that consumers receive the communication intended for them; and avoids mis-directing communications that are sent by our clients.
  • prevents further distress for families of deceased individuals by minimising further marketing communications to that individual.
  • ensures that any marketing preferences expressed by an individual, for example to not receive direct mail or telephone marketing, are respected by organisations who are sending marketing campaigns.

Our third-party suppression data sets have a number of purposes:

  • Identifying individuals who have moved. Often referred to as "goneaways", these files are used to accurately identify and validate where individuals have left an address. Our third-party sources of this data include: the National Change of Address (NCOA) - Suppress File from the Royal Mail; Re-mover from The Ark; and the GoneAway Suppression (GAS) file from Sagacity Solutions Ltd.
  • Identifying where individuals have moved to. The Royal Mail's National Change of Address (NCOA) - Update file contains the forwarding addresses of individuals who have registered with the service, enabling organisations to suppress the old address from marketing communications for that customer, and for their records to be updated with their current address in order to maintain, or regain, contact with individuals when they move to a new house.
  • Identifying individuals who are deceased. To prevent further distress to the families of deceased persons, there are several commercial files available to help organisations identify deceased and suppress these individuals from any marketing campaigns or communications. Our third-party sources of this data include: Mortascreen from Wilmington Millennium; The Bereavement Register (TBR) from Sagacity Solutions Ltd; and the National Deceased Register (NDR) from The Ark.
  • Identifying individuals who do not wish to be contacted for marketing. Often known as "preference" data, this identifies records where a consumer has joined an 'opt-out' list to indicate that they do not want to be contacted via a particular marketing channel. Matched records would be removed from contact files to ensure consumers do not receive unwanted marketing communications via the channels they have specified. These data sets are used by our clients and by Experian. Use of these files by organisations is either recommended best practice or a legal requirement.
    • The Mailing Preference Service (MPS) is run by The Direct Marketing Association and is the official 'do not mail' register in the UK. It enables individuals to opt out of unsolicited, personally addressed advertising mail (Consumers can register with the MPS for free). Screening mailing lists against MPS and other mailing suppression files is a condition of DMA membership (to which Experian belong) and is regarded as best practise across the marketing industry.
    • A version of MPS called BabyMPS is also run by The Data & Marketing Association, which enables parents who have suffered a miscarriage or bereavement of a baby in the first weeks of life to register their wish not to receive baby related mailings.
    • The Telephone Preference Service (TPS) is a free service run by The Data & Marketing Association on behalf of The Information Commissioners Office (ICO). It is the official central opt out register on which you can record your preference not to receive unsolicited sales or marketing calls. It is a legal requirement that all organisations (including charities, voluntary organisations and political parties) do not make such calls to numbers registered on the TPS unless they have your consent to do so.

Public Information

We also obtain personal data from publicly available sources, which can often be freely used, reused and redistributed by anyone with no legal restrictions on access or usage.

Within our Marketing Services business we use several sources of public personal data:

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The Edited Electoral Roll (EER), often called the 'Open Register'

This is a subset of the full Electoral Register or Electoral Roll (ER) which lists the names and addresses of everyone eligible to vote in each Local Authority in the UK.

Being included in this 'Open Register' means that your name and address is publicly available for anyone to purchase from the Local Authority for any purpose, such as direct marketing.

Along with data from our data partners, we use the EER - this subset of the ER - within our marketing database for several purposes:

  • For address and age validation.
  • As a source of marketing contact details.
  • For matching, linking and insight.

The Edited Electoral Roll (EER), often called the 'Open Register' is a subset of the full Electoral Register or Electoral Roll (ER) which lists the names and addresses of everyone eligible to vote in each Local Authority in the UK.

Being included in this ‘Open Register’ means that your name and address is publicly available for anyone to purchase from the Local Authority for any purpose, such as direct marketing

Your name, address and date of birth will be included in the EER unless you ask your local Electoral Registration Office for them to be removed. Note that your date of birth is only required on the electoral forms when the individual is a “young attainer”, and date of birth is declared to show that they will turn 18 in the upcoming year(s).

When you first register to vote, you can decide to be on the EER, which means that your name and address is publicly available for anyone to purchase from the Local Authority for any purpose, such as direct marketing. Each Local Authority has their own registration form for the ER and the wording used to explain about the Open Register/EER may vary by Local Authority.

Along with data from our data partners, we use the EER - this subset of the ER - within our marketing database for several purposes:

  • For address and age validation - to check that the marketing names and addresses that come from our data partners are valid and to remove any individuals who show as under 18 in the EER.
  • As a source of marketing contact details - to provide additional names, addresses and date of birth (where this exists on EER) to organisations for postal marketing purposes, to help them find potential new customers.
  • To enable matching, linking and insight - names and address in the EER that we don’t see from any other sources are used for matching and linking our segmentations and modelled data to a client’s existing customer base to provide insight. We also use names and addresses from the EER to provide insight into the ‘make-up’ of the UK population across: age (from date of birth); composition of the household (based on who lives at that address); and length of residency (based on when we first see a record in EER). These pieces of information inform our models and segments which our clients use to create more relevant marketing communications for you.

You can opt out of your information being held on the EER at any time by contacting your local Electoral Registration Office and are given the opportunity to opt out annually as part of your Local Authority's Canvass of all households. Your details will then not be included in the Open Register. Removing your details from the Open Register does not affect your right to vote.

Experian processes the latest version of the EER, including any monthly updates supplied by the Local Authorities. If you choose to opt out directly with us processing your data for our clients' direct marketing purposes, this opt out will always be applied to our marketing database even if your details continue to appear on the EER.

The Government’s website provides further information on the Electoral Register and the "Open Register".

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The Register of Judgements, Orders and Fines

Sometimes referred to as 'the County Court Judgment (CCJ) Register', this is a public register maintained by The Registry Trust, on behalf of the Ministry of Justice, and is available online to be accessed by anyone. It includes England and Wales county and high court judgments, tribunal awards, administration orders, child support agency orders and magistrates courts defaulted fines. Judgments are also held from courts in Northern Ireland, Jersey, Isle of Man, the Republic of Ireland and decrees from Scottish sheriffs courts. Being public data, these registers can be searched by anyone through TrustOnline.

We use the data in Experian Marketing Services for matching, linking and insight.

The Register of Judgments, Orders and Fines contains the name and address of the individual concerned, their date of birth (if supplied to the court), the case, court number and date of the particular order and the amount that the court has ordered be paid. Once the case has been resolved, the Register will be updated to also include this fact.

We use the data in for matching, linking and insight:

  • Names and address in the file that we don't see from any other sources are used for supplementing our view of the identities of the UK Adult population.
  • We append our segmentations and modelled data to this view, which can then be used to match to a client's existing customer base to provide insight.
  • We use names and addresses from the data, alongside other sources of names and addresses, to help provide insight into the 'make-up' of the UK population across: composition of the household (based on who lives at that address); and length of residency (based on when we first see a record in the CCJ file). These variables inform our models and segments so that what we build for our clients can drive more relevant marketing communications for you.
  • It informs our credit marketing suppression product which enables us to uphold responsible lending by screening out marketing contact details from any marketing activity where the financial services being offered are inappropriate to the circumstances of the individual.
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Register of Directors

Publicly available, the Register of Directors is an official list of the directors of a company that is by law sent to Companies House, where details of all companies are kept.

We use this data to identify names on our marketing file where the individual is a director of an organisation (where the director has provided their home address to Companies House).

While the Companies Act requires company directors to provide their usual residential address, it is not shown on the public record and only made available to credit reference agencies and specified public authorities. Should a Director choose to register their residential address as their service address, registered office or subscriber address then it will always appear as a part of the public record even if changed at a later date.

We use this data to:

  • Flag names on our marketing file to identify where the individual is a director of an organisation (where the director has provided their home address to Companies House). Additional insight into the size of the company (either > or < than 50 employees) is also appended from the Experian's business marketing file.
  • Names and address in the file that we don’t see from any other sources are used for supplementing our view of the identities of the UK Adult population and used for matching and linking purposes.
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BT "Phone Book"

Ofcom, the UK's communications regulator, have an obligation to ensure that UK consumers have access to telephone directory and directory information services and have the right to be listed in directories. Centrally administered by BT Wholesale, BT's OSIS (Operator Services Information System) database is the principal database for telephone directory information (and is effectively an electronic version of the "Phone Book"). Customers of the Communication Providers provide their consent for their telephone number details to be included in the directory.

Customers of the Communication Providers provide their consent for their telephone number details to be included in the directory.

The OSIS data is licensed by Experian so that the file can be used by our clients to validate phone numbers that they already hold against an individual. We do not change the nature of the BT OSIS file, only matching it to client data as instructed by the client. It is not used in the build of any of our products.

Credit Activity Data

We do use some information from our credit reference business for the following purposes

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  1. Address and age validation and ensuring data accuracy.
  2. Insight and modelling to help our clients drive more relevant marketing communications for you.
  3. Matching and linking our modelled data and segments to a client's existing customer base to help them communicate with you more relevantly.
  4. Responsible and relevant marketing by screening out contact details from any financial marketing activity which might be inappropriate to the circumstances of the individual.

In detail, the information from our credit reference business is used in our Marketing Services business for the following purposes:

  • Validation and ensuring accuracy - validating marketing names and addresses we see from our data partners to ensure that, as far as possible, these contact names and addresses belong to an individual aged 18+. This reference data also helps to keep our clients’ data accurate, for example by helping to ensure communications are not sent to people at incorrect addresses or to individuals who have passed away; and that we have accurate Titles and Forenames for individuals. This all helps to protect you against fraud by ensuring that communications intended for you, reach you.
  • Insight and modelling - into the 'make-up' of the UK population for characteristics across age, gender, number of adults in a household, composition of the household and length of residency. These variables inform our models and segments so that what we build for our clients can drive more relevant marketing communications for you.
  • Matching and linking - matching our modelled data and segments to a client's existing customer base to help them communicate with you more relevantly (where they have appropriate permissions to do so) and linking together separate address records which an organisation might hold on you and removing duplicated to create a more accurate record for you. This helps our clients to create a better and more consistent marketing communication experience for their customers.
  • Responsible and relevant marketing - through an understanding of a person’s financial history, we enable our clients to uphold responsible lending by screening out marketing contact details from any marketing activity where the financial services being offered are inappropriate to the circumstances of the individual.

For avoidance of doubt, outside of confirming an individual is over 18 or resident at the provided address through the presence of a recent active account at the address (1. above), an individual's financial data is only used for creating credit marketing suppressions (screening out) to enable responsible marketing (4. above). The only data from the credit activity data used across the other uses are identities (names and addresses) and date of birth. Names and addresses from the credit files are never used to identify or send marketing materials to potential new customers.

The Credit Reference Agency Information Notice (CRAIN) is a processing notice which Experian has developed with the other UK credit reference agencies, with input from the Information Commissioner's Office and several financial services trade associations. CRAIN (in conjunction with the Information Pages provided on this website) helps to explain these purposes.

Experian’s Consumer Services business

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Some information including your IP address, time and date stamp, cookie ID and consent string is collected when you engage with Experian’s consumer website where you give consent for that information to be captured and shared with our Marketing Services business. We use this information in our products and services that help other advertising brands to improve the relevancy of online experiences and marketing messages that these brands and public sector organisations display across the internet and other marketing channels such as TV and social media.

Special category data and data relating to children

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Special Category Data

Special category data is personal data which the law says is more sensitive, and so needs more protection.

This refers to data about:

  • Racial or ethnic origin
  • Religious or philosophical beliefs
  • Trade union membership
  • Health or sex life
  • Sexual orientation
  • Genetic data
  • Biometric data
  • Political opinions

No "special category" personal data is obtained or processed by Experian Marketing Services in the creation of our own products and services.

We do, however, work with responsible organisations including those in the public sector and political organisations who use our marketing products and services to improve the relevancy of the messages they send you. These organisations may have collected special category data that they ask us to process on their behalf.

We host customer marketing databases on behalf of some of our clients, so we could process special category data provided to us by our clients (if they have it on their database) and they have instructed us to do so. For example, we do host campaign databases for political organisations, which contain political opinions of individuals collected by the political organisations. In all cases, any special category data processed on behalf of any political organisation client is done so under contract only for that client, on their instruction, and is not processed or used in any of Experian Marketing Services' marketing products and services. It is protected by strict Experian data security controls.

Whilst not personal data, we use aggregated and anonymised information from public data sources and market research surveys on some special category themes as part of the many measures we use to inform how segmentation clusters like Mosaic are described. For example, the UK Census is accessible to anyone through the Office of National Statistics (ONS) website and contains information on topics such as ethnicity, religious beliefs and health (to name a few). However, this data is available from the ONS website only for geographic areas, for example for Census Output Areas, which contain an average of 150 households.

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Data relating to children

In data protection regulation (the GDPR), the age of consent, i.e. when a child is required or able to give their consent for the processing of their own personal data, is 16 years of age, although EU member states are allowed to allocate their own age of consent, provided that this does not fall below the age of 13. In the UK, the age at which individuals are considered capable of giving consent is 13.

In our Marketing Services business, when we obtain personal data obtained from our third-party commercial data partners, we do not knowingly obtain or process data about individuals under the age of 18. While we insist that the personal data we receive from our data partners should only relate to individuals aged 18+, through our internal verification processes we take additional steps when this data comes into Experian to check that any personal data we handle relates only to UK adults aged 18+.

Whilst we do not knowingly process data that identifies any child under 13, we do process data from the Edited Electoral register that relates to "young attainers" – 17-year olds who are approaching the legal voting age.

The electoral register of voters contains information about several hundred thousand seventeen year olds (known as "attainers"), and personal data on these data subjects is processed by us.

For our marketing services, we only use an extract of the full Electoral Roll, called the Edited Electoral Roll. Your name and address will be included in the edited version unless you ask for it to be removed and any organisation is permitted to use the edited electoral roll for marketing activities. We use the data to provide the name and addresses to clients for postal direct marketing and only those aged 18 or over are included within our prospect marketing database.

 

We do obtain and process data about the presence and age of children in a household.

Whilst we do not process personal data that can identify a child, we do obtain and process data about the presence and age of children in a household. Sources of this data are:

  • Market research surveys which we use to build models of the likelihood that a household has children and, if so, the likely age of children in the household, which is always banded into broad age ranges e.g. 0 to 5 years. These models help our clients, where appropriate, to ensure that more relevant products and offers are marketed to adults - for example that a 2 for 1 entrance to a theme park is offered to parents / carers who are likely to have children.