There are two categories of protection for PSC information.
• Preventing the PSC’s usual residential address being shared with credit reference agencies
(Residential addresses are never made public on a company’s own register or on the central public register at Companies House, but Companies House does normally share them with credit reference agencies). Referred to in the act as 790 ZF protection (same as officers section 243)
• Preventing any information about the PSC being seen on the public record – removing relevant retrospective PSC information and replacing relevant PSC information with a note that protection is in place
(PSC information is usually available on a company’s own register and on the central public register at Companies House, minus the residential address and the day of the date of birth ). Referred to in the act as 790ZG protection or super secure.
Companies House will not allow any companies who have a PSC who is super secure to file any PSC transactions electronically, all filings for PSC01-PSC09, Confirmation Statement, elect and withdraw of a PSC register and Incorporation must all be filed on paper. This means if you have 1 PSC who is super secure and 3 non secure PSCs all filings for any of those PSCs will all be required to file on paper.
Where a company is holding it’s own PSC register can you confirm how (and if) these 2 protections would be used on the confirmation statement.
I assume we’d supply details for a PSC with 790ZF protection (and confirmation of the protection). Is this correct?
And what, if anything, would you expect to be supplied for a PSC with 790ZG protection?
790ZF protection works the same as the current directors protection and there is the secureIndicator located with residential address details in the PSC section on confirmation statement and notification schemas.
790ZG is completely new and due to the nature of the security level, Companies House is unable to accept these PSCs electronically. It is purely a paper process. If a company has a number of PSCs which come under ZG protection, then all PSC information including confirmation statement must be filed on paper. These forms are currently being developed, the indicator on the schema is only used to indicate to developers that they are unable to submit this information. It will be rejected by our XML gateway.
If a person gains 790ZG protection does this cover them for all companies where they may be a PSC? Or does a person need to register for the protection for each company that they are identified as a PSC?
For example, would it be possible for a PSC to be submitted through an electronic confirmation statement for one company but the same PSC could not be submitted electronically for another company due to the super secure status?
Reply from policy:
If a person gains 790ZG protection does this cover them for all companies where they may be a PSC? Or does a person need to register for the protection for each company that they are identified as a PSC?
790ZG protection will only be granted in respect of one company – if an individual requires protection for more than company, they have to apply in respect of each one.
For example, would it be possible for a PSC to be submitted through an electronic confirmation statement for one company but the same PSC could not be submitted electronically for another company due to the super secure status?
Does a PSC with section 790ZG protection need to flag this on the paper forms sent to Companies House, such as the IN01 and the confirmation statement?
Yes. If a company has a PSC with 790ZG protection, they will need to file certain forms on paper; these are the IN01, confirmation statement and any PSC forms that contain details about an individual PSC.
There will be special versions of these forms that these companies must use, which include a statement that The PSC’s details are not shown because restrictions on using or disclosing any of the individual’s particulars are in force under regulations under section 790ZG. These forms can be obtained by calling the secure registers team on 02920 348354. Alternatively, you can request forms by emailing secureforms@companieshouse.gov.uk.