Data inventory
ROPA Register
Processing-activity register covering the complete KYB lifecycle. Legal-basis entries are candidate assessments to be finalized by legal/compliance against the actual operating model and sector obligations.
| ID | Processing activity | Data subject | Personal data | Source | Purpose | Legal basis candidate | Recipient/Owner | Retention |
|---|---|---|---|---|---|---|---|---|
| R01 | Merchant account / case creation | Merchant organization | Company/contact data | Direct onboarding | Case management | Contract / legal obligation candidate | KYB Ops | Case life + policy |
| R02 | Director / officer collection | Directors/officers | Name, role, contact/ID where required | Merchant documents / form | Identity verification | Legal obligation / legitimate interest candidate | KYB Ops | Purpose-based |
| R03 | Beneficial owner collection | Beneficial owners | Identity / ownership data | Merchant / registry | Ownership verification | Legal obligation candidate | Compliance | Purpose-based |
| R04 | Legal document upload | Company & signatories | NIB/Akta/NPWP/SIUP content | Merchant upload | Verify legality | Legal obligation / contract candidate | Private document store | Shorter raw retention |
| R05 | Document malware/type validation | Upload subjects | File metadata | System generated | Security | Legitimate interest / security obligation | Security service | Operational |
| R06 | Document classification | Company | Document type/image | Uploaded document | Route OCR | Same as primary KYB purpose | AI runtime | Derived record |
| R07 | OCR field extraction | Company/persons | Structured document fields | Uploaded document | Verify identity/business | Same as primary KYB purpose | AI runtime | Purpose-based |
| R08 | Document authenticity analysis | Company/persons | Image quality/tamper signals | Uploaded document | Detect manipulation | Same as primary KYB purpose | AI runtime | Purpose-based |
| R09 | Cross-document consistency | Company/persons | Names, IDs, addresses, roles | Derived OCR | Detect inconsistency | Same as primary KYB purpose | Decision engine | Purpose-based |
| R10 | Registry / NIB verification | Company/persons | Registry identifiers/status | Approved registry | Validate business | Legal obligation candidate | Registry connector | Evidence retention |
| R11 | Website URL collection | Company | Business URL | Merchant | Website intelligence | Legitimate interest / KYB purpose | Case store | Case life |
| R12 | Website crawling | Company / incidental persons | Website content | Public merchant website | Business verification | Legitimate interest candidate | Crawler | Minimized evidence |
| R13 | LOB classification | Company | Derived business category | Website + declaration | Check business consistency | Same as KYB purpose | AI runtime | Derived record |
| R14 | Prohibited-category detection | Company | Products/services risk labels | Website | Detect high-risk/forbidden activity | Same as KYB purpose | AI runtime | Evidence retention |
| R15 | Domain history / WHOIS | Company / registrant if personal | Domain metadata | Licensed provider | Site-history risk | Legitimate interest candidate | Domain connector | Minimized |
| R16 | Domain reputation / blacklist | Company | Domain reputation signals | Licensed provider | Fraud/scam risk | Legitimate interest candidate | Domain connector | Freshness TTL |
| R17 | Google Business entity match | Company | Business profile metadata | Approved Google access | Identify correct profile | Legitimate interest candidate | Google connector | Minimized |
| R18 | Google review aggregation | Company / reviewers incidentally | Reviews, rating metadata | Approved Google access | Reputation risk | Legitimate interest candidate | Google connector | Minimized |
| R19 | Review sentiment analysis | Review authors incidental | Review text / derived sentiment | Google reviews | Identify negative themes | Legitimate interest candidate | NLP runtime | Derived + limited evidence |
| R20 | Review manipulation detection | Review authors incidental | Pattern metadata / derived score | Google reviews | Detect inauthentic patterns | Legitimate interest candidate | NLP runtime | Derived |
| R21 | Adverse-media query creation | Company/persons | Names/aliases/disambiguators | Case data | Search adverse media | Legal obligation / legitimate interest candidate | Search service | Operational |
| R22 | Adverse-media retrieval | Company/persons | Articles & source metadata | Licensed/public sources | Identify relevant adverse info | Legal obligation / legitimate interest candidate | Media connector | Evidence retention |
| R23 | Adverse-media entity resolution | Company/persons | Identity matching features | Case + media | Reduce false positives | Same as primary purpose | AI runtime | Derived |
| R24 | Adverse-media risk categorization | Company/persons | Issue/status/severity labels | Media content | Risk assessment | Same as primary purpose | AI runtime | Derived |
| R25 | PEP screening | Relevant individuals | Identity + PEP status | Licensed screening data | Regulatory/KYB screening | Legal obligation candidate | Screening provider | Evidence retention |
| R26 | Sanctions screening | Company/persons | Identity + list-match data | Licensed/domestic lists | Regulatory screening | Legal obligation candidate | Screening provider | Evidence retention |
| R27 | Criminal / court background candidate | Relevant individuals | Court/criminal information | Approved legal source | Enhanced due diligence | Legal obligation / high-risk assessment candidate | EDD restricted zone | Strict/short |
| R28 | Social account verification | Company/person | Business account metadata | Approved social access | Match account to merchant | Legitimate interest candidate | Social connector | Minimized |
| R29 | Social sentiment analysis | Company/persons / commenters incidental | Public/business content & sentiment | Approved social access | Reputation risk | Legitimate interest candidate | NLP runtime | Minimized |
| R30 | Social fraud/controversy signal | Company/persons | Derived risk themes | Social content | Risk assessment | Legitimate interest candidate | AI runtime | Derived |
| R31 | Image safe-search processing | Upload subjects | Image + safety scores | Merchant upload | Prevent inappropriate/sensitive upload | Security / KYB purpose | Private vision runtime | Raw short |
| R32 | Multi-source profiling | Company/persons | Combined risk signals | All modules | Holistic KYB assessment | Legal obligation / legitimate interest candidate | Decision engine | Decision record |
| R33 | Risk scoring | Company/persons | Module scores/reason codes | Derived | Risk classification | Same as KYB purpose | Decision engine | Decision record |
| R34 | Low-risk auto approval | Company/persons | Decision output | Risk engine | Onboarding decision | Contract/legal obligation candidate | Onboarding system | Decision record |
| R35 | EDD / manual review | Company/persons | Evidence, analyst notes | Module results | Resolve ambiguity | Legal obligation / legitimate interest candidate | EDD analysts | Decision record |
| R36 | Decision override / escalation | Company/persons | Reviewer rationale | EDD | Accountable decision | Same as KYB purpose | Compliance | Decision record |
| R37 | Correction / dispute processing | Company/persons | Correction request/evidence | Merchant/data subject | Correct inaccurate data | PDP rights handling | Privacy/KYB Ops | Rights case life |
| R38 | Audit & evidence logging | Users/data subjects | Event metadata, reason, source refs | System generated | Auditability | Legal obligation / legitimate interest | Audit store | Policy-defined |
| R39 | Ongoing re-screening | Company/persons | Updated external signals | Approved sources | Periodic risk monitoring | Policy/legal basis specific | Orchestrator | Freshness policy |
| R40 | Security monitoring | Users/data subjects incidental | Access/security logs | System generated | Protect system/data | Security obligation/legitimate interest | SOC/SIEM | Security retention |
| R41 | Vendor support / troubleshooting | Case data minimized | Diagnostic metadata | System/support | Resolve incidents | Processor instruction | Approved support | Ticket duration |
| R42 | Retention / deletion execution | All relevant subjects | Deletion metadata | System policy | Enforce retention/PDP rights | Legal obligation/PDP compliance | Data platform | Deletion evidence |