Purpose: Pride & Pinion’s KYC Policy outlines our procedures for verifying the identity and integrity of our customers, particularly for high-value transactions. As a seller of luxury watches, establishing the true identity and legitimacy of our clients is critical to prevent fraud, money laundering, and dealing with prohibited persons.
This policy applies to all new customers and any transaction where identification is required (typically purchases over £1,000 or any suspicious circumstances).
- Customer Identification Requirements: In order to do business with Pride & Pinion, customers must undergo identification verification in line with the purchase value:
- Standard Identification (ID): For purchases above £1,000, customers are required to provide one form of photographic ID and one proof of address. Acceptable forms of photographic ID include a passport or driving licence, and acceptable proof of address includes a utility bill or bank statement (recent, within the last 2 months). The address on the document must match the billing and/or shipping address used for the purchase. We only require one of each (one ID + one address document) per customer. These documents must be submitted promptly (within 48 hours of our request) to avoid delays in order processing.
- Enhanced Due Diligence: If a customer engages in an exceptionally large purchase (e.g. watches valued over £50,000, multiple high-value orders, or other risk factors), or if the customer is not met face-to-face (online/remote sale), Pride & Pinion may request additional verification. This can include a second form of identification, information on the source of funds, or other supporting documentation. Enhanced checks are also applied if the customer is identified as a politically exposed person (PEP) or has other higher-risk indicators. While we currently do not use automated identity verification tools, we apply a careful manual review for these cases. Any discrepancies or concerns trigger a review by senior management before proceeding.
- Verification Process:
All customer identity documents are manually reviewed by a trained member of our team (usually the salesperson handling the sale or a designated compliance staff member). We inspect the ID for authenticity (checking security features and expiration date) and verify that the name matches the order and payment information. We confirm that the proof of address is recent and matches the customer’s delivery address. If the documents meet our criteria, the transaction can proceed. If a document appears fraudulent or cannot be verified, the transaction is put on hold and escalated to the Managing Director. At this stage, we may ask for additional proof or cancel the order if we are not satisfied with the customer’s credentials. We do not currently use automated KYC databases; all checks are done in-house. This manual process ensures a thorough review, though it may take additional time for completion.
- Data Security & GDPR Compliance:
Protecting customer data is taken very seriously. All identification documents and personal information collected for KYC purposes are handled in accordance with GDPR and applicable data protection laws. Specifically:
Secure Storage: Electronic copies of IDs and address documents are stored on secure, encrypted systems with access restricted to authorised personnel only (e.g. the Managing Director and relevant compliance staff). Physical copies, if made, are kept in locked cabinets in a secure area. - Limited Use: KYC documents are used solely for identity verification, fraud prevention, and legal compliance. They are not used for marketing or any unrelated purposes. We share customer KYC information only when necessary for compliance (for example, if requested by law enforcement or if required by court order). We may verify the documents’ information with third-party services (such as verifying identity details with government databases) but do not disseminate the documents to any unauthorised third parties.
- Retention & Deletion: In line with AML best practices, we retain KYC records for at least 5 years after the transaction (or longer if required by law or if an ongoing investigation is relevant). After the retention period, all personal data and documents will be securely destroyed or deleted, unless further retention is legally required. Customers have the right to request access to their personal data or ask for rectification under GDPR. Any such requests will be handled according to our Privacy Policy and GDPR procedures.
- Privacy Notice: Our Privacy Policy discloses to customers that we may collect and verify personal information (such as IDs and addresses) for fraud prevention and compliance. Customers are informed of this requirement at checkout or when initiating a high-value purchase. By proceeding with the transaction, they acknowledge and consent to this verification process.
Responsibilities:
Each sales representative is responsible for carrying out the KYC checks for their own clients as per this policy. They must ensure they have received and verified the required ID and address proof before dispatching any high-value watch. A checklist is followed to confirm all documents are in order. The Managing Director oversees the KYC programme’s implementation – reviewing records to ensure compliance and offering guidance on any complex cases. Stephen Davidson (MD) also acts as the data controller for KYC information, ensuring GDPR compliance in storage and handling.
If any staff member is unsure about the validity of documents or encounters a potential mismatch, they are required to seek advice from the MD or the appointed compliance manager before finalising the sale. Regular training sessions are held to keep staff updated on how to examine IDs and spot forgeries or discrepancies. By diligently following this KYC Policy, Pride & Pinion verifies the identity of its clientele and maintains the integrity of its luxury watch transactions.
Policy created: 8 October 2024
Last updated: 9 May 2025
Approved by: Nico Leonard (Company Director)