Reviews
Part of Creator discovery platforms reviews: all 14 routes on HOLD
Reviewing a creator discovery agency: the dossier to demand before any verdict
How to review a creator discovery agency: the register check, data roles, outreach rules, ad labelling and accessibility evidence to demand before a verdict.
What to take away
- An agency review with no dossier ends at hold, not fail. Missing evidence is unknown, not a defect.
- Six lanes carry a verdictentity, data roles, outreach, advertising, accessibility and creator data.
- Five lanes have a named UK authority to measure the documents against. The sixth, creator data, is tested by the buyer.
- Agency-written test results and case studies stay claims until the buyer can examine the method.
- Every verdict needs a tested boundary, a date and an expiry.
Why an empty dossier means hold
A review needs evidence before it can score anyone. If an agency has sent no documents, the honest result is hold: nothing is known, so nothing can be marked down or up.
Hold is not an adverse finding. It says the buyer cannot yet recommend, reject or compare. The agency can reopen the review at any time by supplying the lanes below.
Six lanes, the documents to request and the authority behind each
| Lane | Documents to request from the agency | Authority to measure it against |
|---|---|---|
| Entity | Legal name, registered address, officers, contract signatory | Companies House register |
| Data roles | Data processing agreement, subprocessor list, deletion route | ICO controller and processor guidance |
| Outreach | Consent log, contact route for creators and brands | PECR rules for business marketing |
| Advertising | Brief template and disclosure policy for paid or gifted posts | Digital Markets, Competition and Consumers Act 2024 |
| Accessibility | Sample report or approval pack tested with assistive technology | GOV.UK Service Manual testing guidance |
| Creator data | Sourcing method for the creator roster, audience-quality checks, platform access basis | Buyer-run test with fictional creators |
Missing Dossier Fields
- Exact contracting entity
- Trading authority
- UK service boundary
- Creator-data source
- PECR analysis
- Account security and logs
- Suppression and deletion
Entity: who you are actually contracting with
Start with the legal entity and its company number. The Companies House register lets anyone see a company's registered address, date of incorporation and current and resigned officers for free.
That settles identity and filing facts only. It does not show that the agency offers the service, holds authority from a creator, works in England or delivers a result. Those need documents from the agency itself.
Data roles: controller or processor
Ask the agency to state its role for each data flow. A creator roster, an outreach list and campaign reporting may each have a different answer.
The distinction matters: controller and processor roles carry different weight, because controllers make decisions about processing activities and a processor has more limited compliance responsibilities. An agency that calls itself a processor but picks its own creator sources is acting as a controller in practice.
Under UK GDPR the role sets the duties, so ask for the subprocessor list and the route for correction and deletion requests. The vendor due diligence checklist covers the supplier questions in full.
Outreach, advertising and accessibility
Outreach rules depend on who is contacted.
Under PECR, companies and other bodies with separate legal status are corporate subscribers, while sole traders and some partnerships are treated as individual subscribers. A creator who trades as a sole trader is treated as an individual subscriber, so the agency's contact route needs a consent record, not an assumption.
Advertising is a separate lane. A commercial practice is a misleading omission if it fails to identify its commercial intent, unless the context makes that apparent. Ask how the agency briefs creators on labelling a paid or gifted post.
Accessibility covers the documents a buyer receives. Request evidence that reports and approvals work with screen readers and speech recognition software, not a policy statement. Our quality checks show how to test one record end to end.
Creator data and audience quality
An influencer agency sells access to creators and runs the campaign around them, so ask how the roster is built. Does it come from a creator discovery database, from public profiles, from a marketplace or from direct signing?
Ask how follower authenticity and audience location are measured, and on what access basis the agency reads Instagram, TikTok or YouTube data.
An agency that cannot describe its sourcing has told the buyer something, but not enough for a score.
Testing with fictional data
Agency-written results are first-party claims. A buyer-run test with fictional creators is stronger: include duplicate identities, a refused contact, a correction and a deletion, then ask for a complete export.
Record the service configuration, the people with access, the inputs and the expected outcomes. A passed case applies only to that task and date. The service standards set out measures for provenance, correction and revocation that make good test targets.
Before you issue a verdict
- Confirm the legal entity and registered address on the public register.
- Record the agency's controller or processor role for each data flow.
- Obtain the subprocessor list and the deletion route.
- Check the contact route against the corporate and individual subscriber distinction.
- Ask how paid or gifted posts are labelled as marketing.
- Run one fictional-data test and file the evidence with a date and expiry.
Common questions
Three questions come up when a buyer reviews an agency that runs creator discovery and influencer campaigns.
Why hold rather than fail?
A fail needs evidence of a defect. With no dossier there is none, so the review cannot recommend, reject or score the agency. Missing fields are unknown. The wider review methods explain how hold states are recorded across suppliers.
What can a register search prove?
Only identity and filing facts: the address, the incorporation date and the officers. It cannot show service capability. Our contract questions cover the written terms that should follow.
Where do the legal checks sit?
Data, outreach and advertising each have their own rules, and an agency policy does not clear a specific asset in advance. The UK compliance guide sets them side by side.
