Five jurisdictions without compromise

Due diligence runs into the laws of each country: personal data storage, identifiers, sources, consents and languages. A3.Trust was designed for this from day one.

Personal data storage

The storage region is set when the organization is created and does not change afterwards. The organization’s data and backups never leave the region, and exchange between A3 products happens inside it.

CountryLocalization requirement
KazakhstanStorage within Kazakhstan. The main infrastructure is hosted here.
RussiaPrimary collection and storage of Russian citizens’ personal data in databases located in Russia.
UzbekistanProcessing of citizens’ personal data using databases located in the country.
KyrgyzstanCross-border transfer is regulated. Requirements are being clarified by lawyers.
MongoliaRestrictions apply to cross-border transfer. Requirements are being clarified by lawyers.

Identifiers by country

An identifier is not a fixed-format field, but a typed set of “country, type, value”. One subject can have several from different countries: with labor migration in the region this is common.

CountryIndividualsLegal entities
KazakhstanIINBIN
RussiaINN, SNILSINN, OGRN
KyrgyzstanPIN, INNINN
UzbekistanPINFL, INNINN
MongoliaRegistration numberRegistration number

Consents and subject rights

A check on an individual never starts without recorded consent. Consent texts are versioned, translated and signed in the subject portal or via A3.EDM.

  • Separate consents for data processing, for the check, for transfer to third parties and for cross-border transfer
  • The text version, date and method of obtaining are recorded
  • Revoking consent stops checks and removes the subject from monitoring
  • A report to the subject on their data, and erasure requests

Data sources by country

Each country has its own legal entities registries, tax information, courts and enforcement proceedings. A subject is checked against the sources of the country of their identifiers, not the organization’s country.

  • A source provider is defined by country, not only by category
  • A scoring model refers to a feature, not to a specific source
  • The system distinguishes “feature checked and clean” from “source not available in the country”
  • A request to a source in another country is recorded as a cross-border transfer

Languages and scripts

Six interface languages: Russian, English, Kazakh, Kyrgyz, Uzbek and Mongolian. The interface language is a user setting, independent of the organization’s country.

  • Uzbek exists in both Latin and Cyrillic: search finds a record in either script
  • Kazakh is moving to the Latin script: transliteration is built in as a common mechanism
  • Mongolian Cyrillic has its own letters: sorting and comparison follow the rules of the language
  • Reference lists, consent templates and knowledge base articles have language versions

Time, calendars and currencies

  • A time zone is set for the user and for the legal entity: Russia alone has eleven
  • A working calendar is kept separately for each country
  • Deadlines expire in the time zone of the object, not of the viewer
  • Amounts are stored with their currency without conversion to a single one: tenge, ruble, som, sum, tugrik

Information on legal requirements is provided as a design reference and is confirmed by lawyers of the relevant jurisdiction before sales launch.

Shall we bring order to your checks?

We will show the dossier, a check, a verdict and monitoring on a demo environment, review your regulations and calculate a pricing plan for your actual volume.