Data provenance and compliance
The UK data owner behind MyDataHub by Emailmovers, with its ICO registration, its lawful basis, where data is held and what is still planned, each with a date.
Emailmovers Ltd (company number 05046417) owns the data behind MyDataHub by Emailmovers and is registered with the ICO as Z9714386, renewing on 18 December 2026. Our lawful basis for named work emails is UK GDPR Article 6(1)(f), legitimate interests.
This page separates what is in place from what is planned, with a target date for each. It claims no certification until its register entry exists.
Who is behind MyDataHub?
| Legal name | Emailmovers Limited |
|---|---|
| Companies House number | 05046417 (registered in England) |
| ICO registration | Z9714386, renews 18 December 2026 |
| Registered office | 33-35 Exchange Street, Driffield YO25 6LL |
| Trading office | Scarborough, North Yorkshire, 01723 800030 |
| Data ownership | UK B2B data owner, not a reseller. Emailmovers has owned this data since 2003 |
Other, unrelated businesses also use the name MyDataHub, so we introduce it as MyDataHub by Emailmovers.
What is in place, and what is planned?
Trust claims are only useful if they are true on the day you read them. Each row below says whether the item exists today or is planned, and planned dates are targets, not promises.
| Commitment | Status | When |
|---|---|---|
| ICO registration Z9714386 | Registered | Renews 18 December 2026 |
| Legitimate interests assessment EM-LIA-2026-03, published with version history | Planned | Target 30 November 2026 |
| Article 14 notice programme: a notice to each new contact within one month | Planned | Target 31 January 2027, before launch |
| Article 30 records that match this page | Planned | Target 31 December 2026 |
| Sub-processor list and residency statement | Published | On this site |
| Cyber Essentials | Planned | October 2026 |
| Cyber Essentials Plus | Planned | Within 90 days, by January 2027 |
| CREST penetration test and external accessibility audit | Planned | First quarter of 2027, before public launch |
| ISO 27001:2022 | Planned | Fourth quarter of 2027 |
| ISO 27701 and G-Cloud 15 reopening | Planned | 2028 |
How do we answer the ICO's seven due diligence areas?
The ICO says that accepting a data broker's assurances is not enough. So every MyDataHub record carries the evidence for each of the seven due diligence areas below, and you can check it from a sample record.
| Due diligence area | Answered by | ICO source |
|---|---|---|
| Who compiled the data? | provenance.contact.source reads emailmovers_research. Emailmovers has owned its UK B2B data since 2003. | ICO guidance |
| Where was it obtained from? | Each field names its source, and Companies House data carries its attribution. | ICO guidance |
| What privacy information was used? | article14_status, article14_notified_at and notice_version, and the privacy notice for contacts. | ICO guidance |
| When was it compiled, and how old is it? | compiled_at, last_verified_at, record_age_days and the dataset version. | ICO guidance |
| How was it collected? | provenance.contact.method (telephone or web) and the verification provider and its location. | ICO guidance |
| What consent records exist? | None are claimed. The lawful basis is legitimate interests, and email_marketing_basis states the PECR position per record. | ICO guidance |
| Was it screened against opt-out and suppression lists? | tps_ctps_status on every number: not_screened, or a dated screen valid for 28 days. Then suppression_status, suppressed_removed in every count, and receipt counts. | ICO guidance |
The wording of each area is ours. The ICO's own wording is in its guidance for organisations using data brokers.
What does every record carry?
Every preview row, order record, lookup and enrichment response carries a compliance object. The same fields appear as CSV columns and as the MyDataHub property group on a CRM push.
| Field | What it holds |
|---|---|
lawful_basis, lia_ref | legitimate_interests_art6_1_f, and the reference of the assessment behind it |
subscriber_class, corporate_subscriber | ltd, plc, llp, scottish_partnership, public_body, charity_incorporated, sole_trader, ordinary_partnership or unknown, and whether the PECR corporate subscriber rule applies |
email_marketing_basis | pecr_corporate_subscriber, or consent_required |
article14_status, article14_notified_at, notice_version | notified, publicly_notified_disproportionate_effort or pending_within_window, with the date and the version of the notice |
provenance | The source of the company, contact and email facts, when each was compiled or verified, the method and the verification provider's location |
tps_ctps_status, tps_ctps_screened_at, tps_ctps_valid_until | clear, tps_registered, ctps_registered, tps_or_ctps_registered or not_screened, with the screen date and the date the screen stops being valid |
suppression_status | none, objected_to_emailmovers, objected_to_licensee, deceased or left_company |
record_age_days, attribution | How old the record is, and the Open Government Licence attribution where Companies House data is used |
Companies House officer names are personal data outside the Open Government Licence, so they carry an Article 14 status instead of the licence attribution.
What does every count and order show?
Every count returns a compliance summary beside the number, so you can reason before you spend.
Every order also issues a compliance receipt, signed as a JWS with ES256, with a PDF twin. Anyone can verify a receipt without an account through POST /v1/compliance/receipts/verify, which returns whether it is valid, whether the order exists, when the licence ends and whether it was revoked.
Where does the data come from?
Contacts, titles, named emails, direct phones and sites come from Emailmovers' own research. Company facts come from Companies House under the Open Government Licence v3.0, and places come from the ONS Postcode Directory under the same licence.
The UK business database page lists each source with its licence and cadence.
What is the legal position?
- PECR regulation 22 protects individual subscribers only. People at companies, LLPs, Scottish partnerships and public bodies can be emailed without consent, and sole traders and ordinary partnerships cannot.
- A named work email is personal data, so our lawful basis is UK GDPR Article 6(1)(f), legitimate interests, with an assessment planned for publication by 30 November 2026. Since 5 February 2026 direct marketing is an example of a legitimate interest.
- Because we obtain data indirectly, Article 14 requires privacy information within one month, or at first communication if sooner.
- Everyone has an absolute right to object to direct marketing, honoured within one month and kept by suppression rather than erasure.
- Live calls must not go to TPS or CTPS numbers without consent, and a screen lasts 28 days. The PECR fine ceiling is £17.5 million or 4 percent of worldwide turnover since 5 February 2026, and a statutory complaints procedure applies from 19 June 2026.
The guide explains each point and links the ICO sources.
How are objections and suppressions handled?
A buyer reports an objection with one call and gets a suppression id and a time. An objection to a licensee suppresses the record for that organisation at once, and an objection to us suppresses it database-wide within one working day.
Database-wide suppressions reach every licensee through a signed webhook, a property on a CRM push and a pull endpoint. Suppressed records never appear in counts or orders, and we keep only a hash.
Where is data held, and who processes it?
The residency statement we publish is this, and nothing broader:
Data is held in the UK (Google Cloud London). Email addresses are verified in the EU by Millionverifier, with some verification traffic passing through US providers under standard contractual clauses. Telephone numbers are checked by Telnyx in the United States under the UK Extension to the Data Privacy Framework. Every telephone number is screened against the TPS and CTPS each night through a licensed screening service based in the UK, which processes the numbers in the UK. Payments are processed by Stripe.
The statement describes the service at launch, and the hosting it names is a condition of launch. The sub-processor page lists each vendor with its purpose, location and transfer mechanism.
How are emails and phone numbers verified?
| Check | Provider and location | Cadence |
|---|---|---|
| Email, primary | Millionverifier (Hungary; EU processing, some verification traffic through US providers) | An ok result is rechecked every 90 days, unknown every 30, catch-all every 90. Invalid is retired after two failures, any bounce triggers a recheck, and every address in an order under 50,000 is checked at delivery. |
| Email, failover | Verifalia (EEA only, Germany) | Automatic on error or timeout |
| Email, UK-only tier | Email Hippo (UK, ISO 27001) | Paid option, about £2 per 1,000 records |
| Phone line type | Telnyx (United States; the number only) | At ingest and every 180 days |
| Mobile liveness | Data Soap HLR (UK hosted) | At delivery for mobiles |
| TPS and CTPS | A licensed screening service based in the UK, every number each night | Every number shows its status and the date of its screen, valid 28 days |
That is about 6.2 million email checks a year for 1.6 million addresses. Every telephone number is screened against the TPS and CTPS each night through a licensed screening service, and carries its status and the date of that screen, valid for 28 days.
Which quality figures do we publish?
We publish these numbers with their dates, and we never publish an accuracy percentage without a measured audit behind it. Coverage by field, such as direct phone, mobile, postal address and Companies House number, is published with each dataset version's changelog.
| Metric | Value | Measured |
|---|---|---|
| Named business emails at active companies | 1,605,275 | 26 September 2026 |
| Hard-bounce rate | Not yet published | First quarterly accuracy audit planned |
What is the warranty?
Today's policy replaces the affected records when hard bounces exceed 10 percent of an order. A stricter policy is proposed and is not current. It would replace or re-credit any hard bounce within 30 days automatically, exclude catch-all addresses unless you opt in and cap the payout at 10 percent of an order.
Which datasets exist?
| Dataset | Status | Source and licence | Credits per record |
|---|---|---|---|
| uk_contacts | Live at launch | Owned; Companies House under OGL v3.0 | 1 |
| ie_contacts | Later phase, after counsel's view on EU GDPR Article 3(2) and Article 27 | Owned; CRO daily register (CC BY 4.0) plus Emailmovers research | 1 |
| Partner data | Available through our team; not sold self-serve | Labelled as partner data | Not priced |
How is security handled?
These are our specified controls. A row marked Specified is a design commitment for launch, and Target and Planned rows are not yet complete.
| Area | Control | Status |
|---|---|---|
| Encryption at rest and in transit | AES-256 at rest, TLS 1.2 minimum, KMS key rotation | Specified |
| Accounts | MFA by authenticator app or passkey; scoped API keys with IP allowlists and expiry | Specified |
| Downloads | Signed URLs that last 15 minutes from the app and 5 minutes from the API, are single use, bound to the account and never emailed | Specified |
| Application security | OWASP ASVS 5.0 Level 2 across app, API and MCP, with Level 3 on authentication, ordering, download and payment paths | Target |
| Testing | A CREST penetration test before launch and annually, a retest within 30 days and weekly authenticated scanning | Planned |
| Privacy engineering | Counts rounded for anonymous callers, cells under 10 withheld, masked samples, hashed suppressions | Specified |
| Analytics | PostHog Cloud EU (Frankfurt), cookieless and first party; no contact data sent; session replay only after opt-in, masked and kept 30 days | Specified |
What are the resilience targets?
| Commitment | Target |
|---|---|
| Availability for paid plans | 99.9 percent a month, with service credits of 10 percent of the monthly fee below 99.9 and 25 percent below 99.0 |
| Recovery time | 4 hours for counts and previews, 8 hours for orders and billing |
| Recovery point | 15 minutes for transactions, 1 hour for uploads and order files, 24 hours for dataset versions |
| Backups | Two UK regions with separate keys, 35 days of snapshots, 12 months of archives and an offline copy; a restore test each quarter, dated on this page |
| Incidents | A first post within 15 minutes and updates every 30 minutes, with a review within 5 working days |
| Personal data breaches | The ICO's 72-hour clock starts at awareness. We aim to contain within 1 hour, record the notifiability decision within 12 hours, notify the ICO within 72 hours and tell customers within 24 hours of the decision |
Measured performance is published on the status page, not here. A target is not a measurement.
Frequently asked questions
Is Emailmovers registered with the ICO?
Yes. Emailmovers Ltd is registered with the Information Commissioner's Office under Z9714386, and the registration renews on 18 December 2026. The register entry is public.
Where is the data held?
Data is held in the UK (Google Cloud London). Email addresses are verified in the EU by Millionverifier, with some verification traffic passing through US providers under standard contractual clauses. The sub-processor list gives the full statement.
Which security certifications do you hold?
This page claims no certification until its register entry exists. Cyber Essentials is planned for October 2026, and ISO 27001:2022 for the fourth quarter of 2027. The table above shows every target and its date.
Do you sell data scraped from LinkedIn or intent data?
No. We never resell intent, technographic or LinkedIn-derived data. Our signals come from the Companies House register, each with its source and date.
How do I stop receiving marketing that uses my details?
You have an absolute right to object to direct marketing. Tell the organisation that wrote to you, and it must stop within one month. Objections reported to us are suppressed for every licensee.