British citizens and TransUnion: FOI release

Information request and response under the Freedom of Information (Scotland) Act 2002.

Information requested


You asked for us to provide a response to a series of questions related to one of your suppliers TransUnion. Specifically you asked:

1. Why is it necessary for the identity of British Citizens to be processed and verified by an American organisation and not a more domestically based Agency?

2. Why, when this American organisation appears to have such a low standard of business practice, and where potentially inaccurate data is likely, are British Citizens forced to divulge their personal details in this way.

3. Does an alternative method of Basic Disclosure exist which more securely protects the Private & Confidential information of British Citizens during processing?

4. Does The Scottish Government make recompense for financial or other losses incurred by a British Citizen in the event of mistake or malpractice by TransUnion?




The answers to your questions are set out below

1. Disclosure Scotland (DS) agreed a bespoke two-year contract with UK company Call Credit in 2017 for online identity checking services. This procurement was carried out through government frameworks and as such was subject to rigorous processes.

This contract includes specific provisions and restrictions on the storage and use of our data gathered as part of our online application process, ensuring data is only stored inside the European Economic Area, only for a limited period (six months) and NOT used for the wider business interests of the company.

When Call Credit was later acquired by TransUnion, we confirmed that there was no change to the terms of our contract.

2. We request only information for a basic identity check online. Over 40,000 applicants have successfully used this service. We have had no evidence of any issues around the safety or accuracy of how Call Credit handles the data of our customers.

Where an identify check fails, which can be for a number of reasons, customers are informed immediately and asked to provide separate information directly to Disclosure Scotland to verify their identity.

3. As stated in our response to question 2, the identity checking service is only used as part of our online application. A paper application for a basic disclosure can be submitted to Disclosure Scotland. This method of application asks individuals to provide documentary evidence for a disclosure alongside the application form. The online service is a quicker and secure method of applying for a basic disclosure. There are also specific and separate arrangements in place for those people who apply for a disclosure through businesses or registered bodies e.g. employers. In these circumstances, the registered body or employer will conduct separate identity checks on behalf of Disclosure Scotland. As you can see there are alternatives to our online service. 

4. The Scottish Government does not have the information you have asked for because the situation you have requested details for is a hypothetical situation. Any such case would have to be considered on its own merits, each case investigated and determined on its circumstances and impact/distress/loss to the individual.

This is a formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested. 


About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at


Please quote the FOI reference
Central Enquiry Unit
Phone: 0300 244 4000

The Scottish Government
St Andrews House
Regent Road

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