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Appropriate Policy Document — Voice Fingerprints

Datazero Ltd, trading as NumberGroup (company number 07390438, ICO registration ZA261621). Document owner and Data Protection Officer: Jody Samuel, Director (help@numbergroup.com). Version 2.0. Effective 1 November 2026. Next review due: 1 November 2027.

[SOLICITOR REVIEW: this published version describes the voice fingerprinting in use today. It replaces the internal APD of 8 September 2026, which covered only the fraud voice-matching gallery that is not active.]

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1. Purpose of this document

The Data Protection Act 2018 (Schedule 1, Part 4) requires a controller that relies on certain Schedule 1 conditions to process special-category data to have an Appropriate Policy Document. This document explains the condition we rely on for voice fingerprints, how we comply with the UK GDPR Article 5 principles, and our retention and deletion policy for this data. Our Data Protection Officer, who owns this document, is Jody Samuel, Director (help@numbergroup.com). It supplements our Privacy Policy.

2. Processing covered

Voice fingerprints. On numbers where a customer has enabled our AI call-intelligence services (transcribed or Call IQ), our systems automatically create a voice fingerprint — a numerical summary of voice characteristics — from the speakers on each call, and compare it with fingerprints from earlier calls. Voice characteristics used to identify a person are biometric data and therefore special-category data under UK GDPR Article 9(1). Datazero Ltd is the controller for this processing.

We use caller fingerprints to:

[STAFF VOICEPRINTS — Jody/engineering to confirm the purpose of the fingerprints also created for the customer's staff who answer calls, and whether this document covers them, or switch them off before publication.]

Scope limits:

3. Condition relied on and why

Article 9(2)(g) UK GDPR (substantial public interest), with Data Protection Act 2018, Schedule 1, Part 2, paragraph 10 — preventing or detecting unlawful acts. Our Article 6 basis is legitimate interests (Article 6(1)(f)).

[SOLICITOR REVIEW: whether paragraph 10 covers grouping withheld callers in caller history for the customer, or whether that part needs a narrower scope or a different condition; and the position for staff fingerprints.]

4. How we comply with the Article 5 principles

5. Retention and deletion

6. Your rights

You can object to voice fingerprinting, or ask for access to or deletion of your fingerprint, by emailing help@numbergroup.com. Please tell us the approximate date and time of your call and the number you called. Our Your Data Requests page explains the process.

7. Review

We review this document at least once a year, and sooner if the processing changes — for example new software, a new purpose, or the fraud voice matching in section 2 being switched on — or if the law or ICO guidance changes.

Datazero Ltd, trading as NumberGroup. Registered in England and Wales, company number 07390438. Registered office: International House, 36-38 Cornhill, London EC3V 3NG. ICO registration ZA261621.