Network Northwest

Security · Data

A region is chosen once, and data does not leave it.

Processing happens in the United Kingdom or in the European Union, decided per operator at the start and not per request. Everything below follows from that choice.

  • 2regions
  • Operator-setretention
  • Discardedbiometric template

What is held

Four categories, three fates

Where data sits and how long it staysUnited KingdomLondon regionEuropean UnionFrankfurt regionPROCESSING REGION — CHOSEN PER OPERATORDocument imagesencrypted at restretained to the operator's policyExtracted fieldsname, date of birthkept for the audit trailDecision recordsigned, immutablekept for the audit trailBiometric templatenever storeddiscarded at decisionWHAT IS HELDA region is chosen once, per operator, and data does not leave it.
Region on the left, category on the right.
  1. 1

    Images

    Encrypted at rest and retained to the operator's own policy, because the retention obligation is the operator's licence condition rather than our preference.

  2. 2

    Extracted fields and decisions

    The audit trail. These are what make a verdict explainable in year three, so they outlive the images in most configurations.

  3. 3

    Biometric template

    Discarded at the decision. It exists to produce a match score and has no use after that score is recorded.

Subject rights

What happens when a player asks

RequestWho answersWhat we do
AccessThe operatorSupply the bundle to you in machine-readable form, within your own response window
RectificationThe operatorCorrect the field and record the correction; the original stays in the audit trail
ErasureThe operatorDelete on instruction, except what a retention obligation requires you to keep
PortabilityThe operatorExport the bundle and the extracted fields

The operator is the controller and we are the processor, so a request reaches us through you. The division is set out in the data processing terms rather than assumed here.