• Supplier hosts the Supplier Data
• The Ongoing Monitoring 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 Ongoing Monitoring service is supplied directly to the End User by the Data Supplier. The Supplier Data used to provide this Ongoing Monitoring service 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 set up an Ongoing Monitoring profile.
“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.
“Ongoing Monitoring” means the automated process which enables the End User to monitor individual Data Subjects and to receive PEP Screening and Sanctions Check updates on an ongoing basis.
“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 Ongoing Monitoring service for the Permitted Purpose.
2.2. In order to access the Ongoing Monitoring part of the Services the End User must complete the Data Template specified by the Data Supplier. Where Ongoing Monitoring Sanctions & PEPs (Set Up) ID Number 100087 is selected on the Order Form, GBG will provide support to the End User during the initial process of setting up the Data Template as part of its Professional Services obligations. However, the End User shall be solely responsible for the completion of the Data Template.
2.3. If the End User wishes to make any changes to the Data Template during the term of this Agreement (including deleting, adding or amending any Unique Records) the End User must communicate those changes to the Data Supplier directly in accordance with the process specified in the “ID3global Ongoing Monitoring Data Specification” document.
2.4. The End User will be charged a fixed fee for each Unique Record added to the Data Template at the end of the calendar month in which that Unique Record is added and again annually every 12 months thereafter until such time as the Unique Record is deleted from the Data Template.
2.5. The Data Supplier will determine the charges owed for the Ongoing Monitoring part of the Service by reference to the number of Unique Records within the End User’s Data Template. For the avoidance of doubt, the End User shall be liable to pay the charges owed for each Unique Record contained within its Data Template, including any Data uploaded by the End User and identified as Unique Record in error.

3. DATA PROTECTION AND COMPLIANCE WITH RELEVANT LAWS
3.1. 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 3.1.
3.2. The Data Supplier is based in the United Kingdom which is located within the EEA. On this basis, Personal Data is not transferred outside of the EEA in order to provide End Users with access to this element of the Service.