Atlas: Data Subject Notice

About this notice

This notice is for individuals whose personal data appears in Atlas, the Briefed corporate entity registry and ownership intelligence database. It is published in accordance with Article 14 of the UK General Data Protection Regulation (UK GDPR), which requires us to inform people about our processing of personal data obtained from sources other than the individual themselves.

If you are a Briefed account holder and want to understand how we process your account data, please read our Privacy Policy instead.

Who we are

Briefed Media Limited (“Briefed”, “we”, “us”) is registered in England and Wales under company number 17255283. We are the data controller for the personal data described in this notice.

Registered office: 66 Paul Street, London, EC2A 4NA. Operating office: Ground Floor, 1 Spinningfields Square, Manchester, M3 3AP.

What data we hold

Atlas may hold the following categories of personal data about individuals in their capacity as company officers, persons with significant control (PSCs), or ultimate beneficial owners (UBOs):

• Full name
• Registered correspondence address (as filed with the relevant registry)
• Nationality
• Month and year of birth (we do not hold full dates of birth)
• Nature of control or ownership interest (for example, percentage shareholding band or type of significant control)
• Date of appointment or registration as an officer or PSC
• Date of cessation, where recorded by the registry
• Country of residence, where disclosed in the source filing

We do not hold passport numbers, national insurance numbers, tax identifiers, bank details, or any other sensitive personal data about individuals in Atlas.

Where it comes from

All personal data in Atlas is obtained from official public government registries. We do not obtain personal data from data brokers, social media, or any private or proprietary source. The primary source registries we use include:

• United Kingdom: Companies House (including PSC register)
• United States: State business registries (varies by state)
• Australia: Australian Securities and Investments Commission (ASIC)
• Finland: Finnish Patent and Registration Office (PRH)
• Brazil: Receita Federal (CNPJ registry)
• Additional jurisdictions where equivalent public registries are available

The personal data in Atlas was disclosed to the relevant registry as part of a statutory filing obligation. Its inclusion in Atlas reflects the fact that it has been placed on a public record by a competent authority.

Why we process it

We process this data to operate Atlas, a corporate entity registry and ownership intelligence database. Atlas is used to:

• Map corporate structures and ownership chains, including parent, subsidiary, and affiliated entities
• Support business research, competitive intelligence, and supply chain analysis
• Enable search and lookup of company and officer information for professional and institutional users
• Power features within Briefed Research and Briefed Intelligence products

We do not use Atlas data to make automated decisions with legal or similarly significant effects about individuals, to conduct credit assessments, or for advertising or marketing purposes.

Lawful basis

Our lawful basis for processing personal data in Atlas is legitimate interests under Article 6(1)(f) of the UK GDPR.

Our legitimate interests are: providing a corporate intelligence and entity research service to professional and institutional users; supporting transparency of corporate ownership and control, which is a matter of recognised public interest and the basis on which the underlying registries were established; and enabling business users to conduct due diligence, competitive analysis, and supply chain research efficiently.

In balancing these interests against your rights and freedoms as a data subject, we note that:

• The data we hold was made public through a statutory disclosure obligation, indicating a legal and public interest in its availability
• We hold only the data categories published in official filings; we do not supplement or enrich public registry data with private information
• Access to Atlas is restricted to professional and institutional users for legitimate business purposes
• The data relates to your role as an officer or beneficial owner of a legal entity, not to your private life

Who can see it

Personal data in Atlas is accessible to professional and institutional subscribers of Briefed Research and Briefed Intelligence products. Access is not available to the general public without a Briefed account.

We share Atlas data with our infrastructure providers (principally Cloudflare) in the course of operating the service. We do not sell personal data from Atlas to third parties or share it with data brokers or advertising networks.

How long we keep it

We retain personal data in Atlas for as long as we operate the Atlas database and for as long as the data remains present in the source public registry. We periodically re-ingest and refresh data from source registries to keep Atlas current.

Where a source registry records that an individual has ceased to be an officer or PSC, we update the relevant record in Atlas accordingly. Ceased records are retained to support historical corporate structure research.

Your rights

As a data subject under the UK GDPR, you have the following rights in relation to your personal data in Atlas:

• Right of access (Article 15). You may request confirmation of whether Atlas holds personal data about you, and a copy of that data.
• Right to rectification (Article 16). If data in Atlas is factually inaccurate, you may ask us to correct it. Where the inaccuracy originates in a source registry, you will also need to request correction at the registry itself; we cannot override official public records.
• Right to erasure (Article 17). You may ask us to delete your personal data from Atlas. Please read the section below on limits to this right.
• Right to restriction (Article 18). You may ask us to restrict processing of your data while we consider a rectification or erasure request.
• Right to object (Article 21). You may object to our processing on the grounds of legitimate interests. We will assess your objection and cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

To exercise any of these rights, contact privacy@briefedmedia.com. We will respond within one month of receiving your request, as required by law.

Limits on the right to erasure

The right to erasure is not absolute. Where your personal data in Atlas was obtained from a statutory public register, and that register continues to publish the data as a matter of public record, we may not be able to permanently erase your data from Atlas for the following reasons:

• Our processing is grounded in legitimate interests that may override your erasure request in the specific context of publicly disclosed corporate officer and ownership data
• Even if we delete a record, our routine refresh processes will re-ingest it from the source registry unless the registry itself has removed or suppressed it

If you wish to have your data removed from a source registry (for example, to apply for the Companies House personal address suppression service for PSCs at risk of harm), you should contact the relevant registry directly. We will honour any suppression or removal recorded at the source registry when we next refresh from that source.

Where we cannot fully erase your data, we will explain our reasons and consider whether we can restrict processing in a way that addresses your concern.

International transfers

Atlas data is stored on infrastructure operated by Cloudflare, which may involve transfers of data outside the UK and EEA. Where such transfers occur, we rely on appropriate safeguards including the UK International Data Transfer Agreement and equivalent mechanisms to ensure your data is protected to UK GDPR standards.

Complaints

If you believe we have processed your personal data unlawfully, we would prefer you contact us first so we can try to resolve the matter. Email privacy@briefedmedia.com.

You also have the right to lodge a complaint with the UK Information Commissioner’s Office at ico.org.uk.

Contact

For all enquiries relating to this notice or your personal data in Atlas: privacy@briefedmedia.com

By post: Briefed Media Limited, Ground Floor, 1 Spinningfields Square, Manchester, M3 3AP, United Kingdom.