• Supplier hosts the Supplier Data
• The EDD Report service is supplied directly by the Supplier
• Supplier is a Processor of Client Information
• Supplier receives and processes Client Information
• Client Information includes Personal Data
• The Supplier is located in the United Kingdom
• The Supplier is based within the EEA
• The Supplier may on occasion use staff or Sub-processors based outside of the EEA to provide EDD Reports

The EDD Report service is supplied directly to the End User by the Supplier. The Supplier Data used to provide this Enhanced Due Diligence service and EDD Report is supplied by GBG’s Data Supplier. GBG is obliged under the terms of its agreement with GBG’s Data Supplier to ensure that all End Users agree to comply with the following provisions:

1. DEFINITIONS
1.1. In these Additional Terms, the following definitions shall apply, in addition to the definitions set out in the General Terms:
“Data” means information stored on an individual Data Subject (including: full name, address, date of birth).
“Data Template” means the template form made up of Unique Records which must be completed by the End User and provided to the Data Supplier in order to access the EDD Services.
“Enhanced Due Diligence Services” / “EDD Services” - means the provision of enhanced due diligence services including the delivery of an EDD Report as may be amended by the Data Supplier from time to time.
“EDD Report” means the report document that contains information related to a company, corporation or business or to an individual’s identity, address, occupation, business and occupational background, associated individuals and entities as well as a summary of potential risk factors as at the time of reporting. The content and level of detail in each EDD Report will depend on the type of report purchased as detailed in the Order Form and the date on which the EDD Report is created.
“EDD Request” means the submission of a Data Template requesting an EDD Report.
“Identity Verification” means validating that the claimed identity of an individual or company actually exists and verifying that the person or company who lays claim to said identity is actually who they claim to be.
“PEP Screening” means screening for political risk of any nature.
“Permitted Purpose” means the use of this element of the Service for the purposes of Identity Verification, Sanctions Checking and/or PEP Screening
“Sanctions Check” means screening for any sanctions against any party imposed by any governmental of official body.
“Unique Record” means each unique Data record identified by its Unique Reference Number specified in Data Template.
“Unique Reference Number” means the End User generated alphanumeric code allocated to each Unique Record in the Data Template.

2. USE OF THE SERVICE
2.1. The End User may only use the Sanctions & PEPs Investigation check for the Permitted Purpose.
2.2. In order to access the Enhanced Due Diligence Services the End User must complete the Data Template specified by the Data Supplier. The End User shall be solely responsible for the completion of the Data Template.
2.3. The information provided to the End User as part of the Enhanced Due Diligence Services has been extrapolated by the Data Supplier from multiple publicly available sources across a variety jurisdictions. This information is presented in the EDD Report which is shared with the End User via a secure electronic file transfer.

3. TIMESCALES AND EXCLUSION OF WARRANTIES
3.1. All EDD Reports are manually produced by the Data Supplier. On receipt of an EDD Request, the Data Supplier shall use its reasonable endeavours to create an EDD Report within a reasonable timescale. The average length of time required to create each type of EDD Report is identified in the table below. However, the End User acknowledges and accepts that this is an indication of the work required to create the EDD Report only and is not an estimation of turnaround time which will depend on a number of factors including the volume of reports requested and the capacity of the Data Supplier’s research staff. Accordingly, time is not of the essence in relation to the delivery of any EDD Report.

EDD Report Type      Work Required
Standard                 3 Business Days
Executive                7 Business Days
Bespoke                  10 Business Days

3.2. All research carried out as part of the EDD Services is ‘desktop-based’ and consequently the End User acknowledges and accepts that information contained in an EDD Report may not be sufficient for its purposes. The End User further acknowledges and accepts that in some instances it may also be appropriate to conduct local investigations.
3.3. As the information and Data used by the Data Supplier to provide the EDD Services and EDD Report is supplied by third parties, the Data Supplier does not have direct control over the quality and accuracy of such information. Whilst the Data Supplier has used its reasonable endeavours to ensure the accuracy of the EDD Report, the End User acknowledges and accepts that the information and Data obtained by the Data Supplier may contain errors or omissions and that the EDD Report is provided without any warranties regarding the quality or accuracy of any information or Data contained within it.
3.4. Nothing within the EDD Report should be taken as a recommendation on the suitability of the EDD Report for any commercial transaction, and the End User accepts full responsibility for any business decisions made using this EDD Report
3.5. All individuals and businesses having negative media and/or allegations of any criminal activity must be deemed to be innocent until proven guilty in a court of law. GBG and the Data Supplier accept no responsibility to the End User or to the individual or business who are the subject of an EDD Report for any decision made as a result of the End User’s use of the EDD Report.

4. DATA PROTECTION AND COMPLIANCE WITH RELEVANT LAWS
4.1. The Supplier Data used to provide the End User with this element of the Service is hosted by the Data Supplier. In order to perform the Services, the Data Supplier shall act as Processor of the Client Information (including any Personal Data supplied) for the sole purpose of delivering this element of the Service. The End User authorises GBG to appoint the Data Supplier as Processor for the purposes specified in this clause 4.1.
4.2. The Data Supplier is based in the United Kingdom which is located within the EEA. Therefore, save as set out in clause 4.3, Personal Data is not transferred outside of the EEA in order to provide End Users with access to this element of the Service.
4.3. The Data Supplier may on occasion use staff or Sub-processors based outside of the EEA to provide the Services in circumstances where the End User has selected to purchase an EDD Report on a business or individual located outside of the EEA. In such circumstances and where GDPR applies to the End User, the End User acknowledges that prior to submitting Client Information to the Data Supplier for processing it shall determine, and is solely liable for ensuring that it can rely on a derogation to transfer Client Information to the Data Supplier in accordance with Article 49 GDPR.