Security & data

Merrin holds records about your ARs and the people who run them, including identity documents, criminal record checks and fit and proper declarations. This page sets out how we protect them, who else processes them, and what we have not done yet. For our Data Processing Agreement or a completed security questionnaire, get in touch.

The short version

• Production data is stored in Google Cloud’s London region.
• Identity documents are read by our own text recognition service, on our own servers. They are never sent to a third party to be read.
• The AI that briefs your approvers can never approve, reject or change anything, and never sees National Insurance numbers, criminal record disclosures or identity document numbers.
• Every change to a regulated record is logged with who made it, when, and the values before and after.
• We process your records as your processor, under a written Data Processing Agreement.
• We are not yet certified to SOC 2 or ISO 27001, and have not yet had an independent penetration test. See what we have not done yet.

How the product protects your records

• Your organisation’s data is kept apart. Every record belongs to one organisation, and every query is limited to it. If that limit is ever missing, the query returns nothing rather than everything, and another organisation’s records answer “not found”. Automated tests check this on every change.
• Roles limit what your team can do. Oversight users can read but not change records. Settings and team management are for admins only. There is no feature that lets anyone sign in as one of your users.
• ARs see only their own work. In the AR Portal a firm contact sees only their firm, and a person sees only their own record. Neither sees your risk scores, notes or review decisions, and they can change information only where you have given them an open task.
• No passwords for ARs. Firms and individuals sign in with a one-time code sent by email. Codes are random, single use, stored hashed, expire after ten minutes and allow five attempts.
• The most sensitive fields are encrypted again. National Insurance numbers, criminal record disclosures, fit and proper answers and identity document numbers are encrypted by the application before they reach the database, and are left out of lists. Document numbers are masked unless a user has permission to reveal them.
• Uploads are checked and kept private. A file’s type is checked from its contents, not its name. Files are stored privately and can only be downloaded after a permission check, and any file that could run code is only ever offered as a download.
• The record of what you knew cannot change. Reviews and filings are made over a snapshot that cannot be edited afterwards, and the activity log can only be added to.

Who processes your data

These are the services that process the records you hold in Merrin. Our Data Processing Agreement lists every sub-processor, and we tell customers before we add or replace one so you can object.

Merrin also reads public records from the FCA Register and Companies House, sending them only the reference numbers it looks up. Where personal data leaves the UK, as it does for the AI briefing, the transfer is protected by UK adequacy regulations or the UK International Data Transfer Addendum.

How Merrin uses AI

When a review is ready, Merrin sends its snapshot to Anthropic’s Claude to write a briefing for the people approving it: a summary, anything it would flag, and questions to ask. Each point cites the part of the record it rests on. Merrin also uses it to read a firm’s filed accounts and summarise its financial position.

• It is advice for your approvers, never a decision. It cannot approve, reject, block or change anything, and the briefing is kept apart from your approvers’ decisions.
• National Insurance numbers, criminal record disclosures and identity document numbers are never copied into a snapshot, so the AI only sees whether they are held.
• Anthropic does not train its models on data sent through its commercial API.
• Anything inside the record, such as text an AR typed, is treated as evidence and never as an instruction to the AI.

UK GDPR and the Data Protection Act 2018

Merrin is a trading name of Lloyd IT Limited, registered in England and Wales under company number 16349880. For the AR and Individual records you hold in Merrin, you are the controller and we are your processor: we act only on your instructions, under a written Data Processing Agreement. For our own account and marketing data, we are the controller, as set out in our Privacy Policy.

Fit and proper work involves criminal offence data and can involve special category data. As controller, you decide the lawful basis and the condition you rely on; we process that data only for the oversight you use Merrin for.

Personal data breaches

If we become aware of a breach affecting your records, we will tell you without undue delay, with what we know, so you can meet your own duty to report to the ICO within 72 hours. Where we are the controller, we report to the ICO ourselves.

Your data, and getting it out

An admin can export everything your organisation holds at any time: its records as CSV and its documents as the original files, in one zip. Records are kept for as long as you need them for your own FCA record-keeping, and when you leave we return or delete your data as your instructions and our Data Processing Agreement say.

What we have not done yet

We would rather you read this here than find it in a due diligence questionnaire.

• We are not certified to SOC 2 or ISO 27001. We are building our controls to those standards and will say so here when an audit is booked.
• Merrin has not yet had an independent penetration test. Our own security reviews prove each weakness found with a failing test before it is fixed, and those tests stay in place.

Reporting a security issue

If you think you have found a vulnerability in Merrin, email security@merrin.ai. We aim to acknowledge reports within one working day and will keep you updated until it is resolved. There is no paid bug bounty, but we are glad to credit responsible disclosure. Our security.txt has the same details.