Data protection

This notice explains how the Unikorn Vision prototype handles personal data, under the Data Protection (Bailiwick of Guernsey) Law, 2017 and, where it applies, the GDPR.

Who is responsible

Bonnie Lawes, Guernsey, is the controller for data processed by this prototype. Email: bonnie.lp.lo@gmail.com

What is processed

• Details entered for a pre-screening (name, date of birth, nationality, city and, optionally, a passport number).
• Information from public sources (sanctions and PEP lists, adverse media and company registries) found about the person being pre-screened.
• Your sign-in details (name and email), only when you sign in to Unikorn Vision.

How the pre-screening works

The pre-screening does what a compliance officer does when searching public sources, with AI doing the searching and the first summary. It produces an unverified draft; it does not make decisions about anyone.

No sign-in is needed. Date of birth and passport numbers are compared only against sanctions and PEP lists and are never sent to web search.

What is stored

Nothing from a pre-screening is stored by Vision. The results are generated for your session and shown on screen only. When you leave the page, they are gone.

If you have a Unikorn Vision account, you can sign in and send the results to the KYC platform. Only then are they stored, as a draft marked AI-prepared, for a person to review. When the draft is approved, the record keeps who approved it and when.

Services used to run the checks

To run a pre-screening, details are sent to the following services, each only what it needs:

• OpenSanctions (sanctions and PEP data): name, former names, date of birth, nationality and, if given, passport number.
• Companies House (UK company registry): name and former names.
• Brave Search (news search): name with a search word such as "fraud". Brave keeps search logs for up to 90 days.
• Google Gemini (AI model): the name searched, details used to compare (places, roles, organisations and date of birth), and the headlines and extracts of the news articles found. Gemini processes data outside Guernsey and the United Kingdom. It is used on Google's paid service, under terms that do not allow requests to be used to train Google's models.

Your rights

You can ask to see, correct or delete personal data held about you, or object to its use, by contacting the address above. You can also complain to the Office of the Data Protection Authority in Guernsey.