CORRECTING COMPLIANCE DATABASES

CORRECTING COMPLIANCE DATABASES

Over the last few years, we have received a growing number of enquiries from individuals concerned about compliance databases storing incorrect or misleading information pertaining to them, and resulting in a detrimental impact on their personal and professional lives. These concerns frequently arise in circumstances where individuals are adamant that the data being relied upon by financial institutions, payment providers or other regulated entities does not accurately reflect reality.

The consequences of inaccurate compliance data can be significant. Individuals may face reputational harm, difficulties accessing banking facilities, restrictions on financial products or broader disruptions to their commercial activities. In many cases, the affected individual is left unequipped, attempting to navigate the system with limited visibility as to what information is being relied upon and why adverse decisions have been taken.

General process – if the information in a compliance database is incorrect

If you think that the information held about you in a compliance database is inaccurate (including an incorrect categorisation as a PEP), based on false information, or if you suspect that someone else may have used your details, there is a process you can follow to seek redress.

The first stage in this process is to ascertain whether you have been listed in one or more of these compliance databases. This may come to light through communication from an entity that relies on these databases, such as a bank informing you that you are unable to open an account or apply for a loan with them, or from making direct enquiries with a particular database under applicable Data Protection laws.

WHAT INFORMATION IS BEING SHARED?

Once this is established, the next step is to understand what information, whether incorrect, misleading or inaccurate, is being shared through these databases. Depending on your individual circumstances, this may be relatively simple to deduce, though the particulars of this information may be difficult to determine.

Having a firm grasp of the law and regulatory frameworks that govern this area is of particular importance here. Gherson have a wealth of experience in this field and can assist in this regard.

HOW CAN I AMEND INFORMATION IN THESE DATABASES?

Most compliance databases have internal mechanisms in place for individuals to request updates or corrections of their data. The individual will need to have valid reasons for doing so and produce documentary evidence in support of their assertions. Being incorrectly listed as a PEP is a particularly relevant reason for correction, especially when supported by evidence.

Importantly, the legislation in this field does not automatically guarantee individuals the absolute right to have their personal data expunged or amended in accordance with their wishes.

These databases will only accede to such requests if they are compelled to do so. Compliance databases make every effort to free themselves of any liability for publishing potentially false, inaccurate or misleading information by specifically informing subscribers of a number of caveats, which include emphasising the need for users to conduct their own independent checks to verify the credibility of information displayed in the report.

Therefore, it is advisable to consult experienced legal professionals to assist with navigating this complex legal and regulatory landscape.

Gherson’s successes

• Assisting a high-net-worth individual with the removal of inaccurate information (including a wrong PEP categorisation) on their World-Check profile.
• Assisting numerous individuals with the removal and correction of information on their compliance database profiles.

Summary of our blogs on this topic

Have compliance databases gone too far? The case of World-Check

In July 2025, further to comments from David Leppan (the founder of World-Check), we examined whether compliance databases had gone too far and looked into proposed recommendations.

Incorrect information about me in World-Check is having a detrimental effect – what can I do about it?

After successfully assisting two individuals with correcting their World-Check profiles, the team at Gherson published an article on the process for correcting information held in World-Check.

What can I do if I am incorrectly listed as a PEP in World-Check?

We have also previously considered the steps to take if you believe that you have been incorrectly listed by World-Check as a PEP.

HOW GHERSON CAN HELP

We advise individuals on addressing inaccurate or misleading information held in compliance databases, including:

• Advising on the legal and regulatory framework governing compliance databases and data processing;
• Assisting with identifying the instance(s) of storing and sharing information about you and where such information is kept;
• Preparing and submitting Data Subject Access Requests (DSARs) to obtain relevant personal data;
• Analysing the information held to assess whether it is inaccurate, misleading or unlawfully processed;
• Preparing detailed representations to database providers and relevant institutions requesting correction or removal of inaccurate data;
• Advising on correcting misclassifications, including incorrect designation as a Politically Exposed Person (PEP);
• Assisting with complaints to regulatory bodies and ombudsman schemes, where appropriate;
• Advising on strategic options, including potential litigation, where informal resolution proves unsuccessful.

WHY CHOOSE GHERSON?

• Specialist expertise: we have extensive experience advising on compliance databases, financial crime-risk data and regulatory frameworks;
• Strategic and considered: we approach each matter with a clear strategy, tailored to the specific database, institution and circumstances;
• Reputation focused: we understand the serious reputational and financial consequences of inaccurate data and act accordingly to protect your position;
• End-to-end support: we will guide you through every step of the process, from initial enquiries and data access requests through to representations, complaints and litigation.

CONTACT US

If you believe inaccurate or misleading information is being held about you in a compliance database, you may wish to seek advice.

Our team provides strategic, considered advice to help you address the issue and safeguard your position.