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What Companies House and ICO records verify about a creator-platform supplier

Influencer platform due diligence in the UK: verify Companies House filings, director histories, PSC records and ICO registration before signing.

Treat public records as decision gates rather than a verdict on performance. Follow the branches below to establish the legal entity, inspect filings and control, check data-protection records, then resolve any remaining contract risks. Proceed only when important mismatches and warnings have a supported explanation.

Path through the decisions:

  1. If personal data will be processed, check the ICO record and fee position.
  2. If the contract name differs from the public name, identify the legal entity.
  3. If filings or ownership raise questions, ask for evidence and trace the explanation.
  4. If public records leave commercial risks unresolved, pause for answers.
  5. If a serious finding remains unexplained, do not proceed.

If the platform will process personal data

If the platform will process creator contact details, audience data or campaign analytics, verify its ICO entry and fee position before sharing information. Most UK organisations handling personal data must register, although exemptions exist; the UK compliance context gives the wider setting.

ICO compliance checks

  • Check ICO public register
  • Confirm data protection fee tier
  • Ask legal basis if exempt claimed
  • Record check in DPIA
  • Search ICO enforcement action records
  • Read enforcement notices for context

The register and the fee are separate checks. The data protection fee depends on the organisation's size and turnover, and some organisations are exempt. If the supplier claims an exemption, ask for its legal basis. Record the result and your decision in the data protection impact assessment.

Search the ICO's enforcement action records for fines, reprimands, notices or prosecutions. Read any relevant record to understand the conduct and compare it with the supplier's claims. One historic reprimand may call for a different response from repeated action concerning direct marketing or data breaches.

If the privacy notice promises that marketing is never sent without consent but an enforcement record concerns that conduct, ask the supplier to explain the difference. Registration alone does not establish compliant processing. Review the processing agreement, security arrangements, breach history and privacy notice as separate evidence.

  • Rule of thumb: Check registration, the ICO fee register and any relevant enforcement record before sharing data.

If the contract name differs from the public name

If the supplier's marketing name and proposed contracting name differ, identify the legal entity before discussing terms. Search Companies House and compare the company number, registered office, incorporation date and current status with the details proposed for the agreement.

A brand may sit apart from the registered company, so ask how the two are connected and make sure the correct entity appears in the contract. This identity check helps establish who is responsible for notices or a dispute. See the legal identity behind the supplier's public-facing name.

Companies House: verifies vs not

What it verifies

Legal entity
Real legal entity
Identity
Company number
Address
Registered office
Status
Current status
Ownership
PSC register

What it cannot verify

Legal entity
Service quality
Identity
Campaign performance
Address
Creator roster
Status
Freelancer payment
Ownership
Technology ownership

Treat identity evidence separately from evidence about capability. Companies House does not assess service quality, campaign performance, client satisfaction, creator numbers or freelancer payment. It also cannot show whether the supplier owns its technology or licences it from another business. A separate audit workflow can address those questions.

  • Rule of thumb: Do not sign until the contracting entity and its connection to the trading name are clear.

If company filings or accounts raise questions

If required filings are late, missing or changing repeatedly, review the filing history before proceeding. Companies submit annual accounts and a confirmation statement, but a clean administrative record does not establish that the supplier is financially sound or capable of delivering the work.

Filing history red flags

  • Late annual accounts filings
  • Late confirmation statement
  • Repeated late filing penalties
  • Changing accounting reference dates
  • Abridged accounts hiding detail
  • Previous company struck off
  • Parent accounts unchecked

Use the filed accounts to examine profit or loss, net assets and reliance on loans. Small companies may submit abridged accounts that provide less detail. If public company and accounting records do not answer your questions, request management accounts under a non-disclosure agreement.

If the supplier belongs to a group, compare its filings with the parent's accounts. The parent may hold the cash, but the supplier remains the contracting party. Search an earlier entity record for connected companies, and read the filings around a strike-off to distinguish voluntary closure from compulsory liquidation.

  • Rule of thumb: Treat an unexplained filing pattern as a reason to request evidence, not as proof of misconduct.

If you cannot trace who controls the supplier

If appointments, resignations or ownership details leave the control chain unclear, ask for an explanation before relying on the supplier. Director histories can show other appointments and director disqualification; a person disqualified under the Company Directors Disqualification Act 1986 cannot act as a director.

Tracing supplier ownership

  1. List all director appointments
  2. Check for disqualifications
  3. Spot frequent resignations
  4. Identify every PSC
  5. Check PSC is real person or known company
  6. Trace offshore trust or overseas company
  7. Request structure chart and legal opinions

Check the people with significant control register. A PSC may own more than 25% of shares or voting rights, or otherwise control the company. Confirm whether the listed person is identifiable and whether another ownership structure needs tracing; frequent director departures may warrant questions, although nominee directors are not illegal.

A trust or overseas company can make verification harder without automatically making the supplier unsuitable. If the ownership trail remains unclear, ask for a structure chart or legal opinion. Establish who could change control without your consent, then consider contract protections for any resulting effect on continuity or the platform's direction.

  • Rule of thumb: Do not treat a signature as sufficient assurance while control remains unexplained.

If public records leave commercial questions unanswered

If public records appear plausible but do not resolve commercial or data-handling questions, hold the decision and request evidence. Use the checks below to identify outstanding points, rather than treating an entry in a register as approval of the supplier.

Due-diligence checklist before signing

  • Confirm legal name and company number
  • Check status is active
  • Download latest accounts and confirmation statement
  • Review filing history for penalties
  • Search dissolved company register
  • List directors and check disqualifications
  • Identify every PSC and trace ownership
  • Verify ICO registration and fee tier

Record the evidence for each relevant item and mark unresolved points for follow-up. The single-record checks help assess an individual creator record, while supplier due diligence provides a route for identifying evidence gaps and deciding when to pause.

  • Search ICO enforcement records for the supplier and its directors.
  • Request the data processing agreement and sub-processor list.
  • Check change-of-control, exit and data-return terms in the contract.
  • Confirm insurance, including professional indemnity and cyber cover.

Not every question carries the same weight for every supplier: a small company may have a simple structure, while a group may need more tracing. If the parent's accounts are offered as reassurance, check whether the parent guarantees the supplier's obligations. Keep the answers and supporting records with the purchase decision.

  • Rule of thumb: An unanswered material question means hold, not assume.

If a finding could put delivery or compliance at risk

If the supplier is in liquidation or administration, a relevant director is disqualified, ownership is unexplained, or required ICO checks fail, stop until the issue is resolved. Check current company status and the underlying filings rather than relying on an old summary or a verbal assurance.

Pause the contract?

Company in liquidation or administration?

Yes

Pause until resolved

No

Continue checks

Refusal to explain ownership is a reason to pause verification. So is absent registration or an unpaid fee without a supported exemption. For enforcement history, distinguish a single historic issue from repeated action for similar conduct, then read the relevant notices before judging their significance.

Check that the contract lets you leave and retrieve your data. If the supplier controls creator data and export is blocked, the relationship may leave you locked in. Review data and exit terms alongside the public-record checks before signing.

Recheck the company at least annually and again before renewal or a major campaign, since its status may change. Keep the evidence with the decision, including any explanation for a dissolved company linked to a director. The public record informs the choice, but the contract determines your rights if ownership or delivery changes.

  • Rule of thumb: Do not proceed while a material risk remains unexplained or your exit is blocked.

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