What to Ask a Data Removal Service Before You Pay: A UK Director's Checklist
The data removal service market is not well regulated. Services can make broad claims about coverage and effectiveness that are difficult for consumers to evaluate without doing significant research. This piece is the research, structured as a checklist for UK directors considering a subscription.
The reference points throughout are the Deloitte limited assurance report on Incogni published in August 2025, publicly available coverage documentation for the major services, and the documented limitations of broker opt-out processes for UK-specific exposure sources.
Question One: Which Specific UK Brokers Are in Your Automated Coverage?
The most common evasive answer to this question is a general claim about UK coverage or a total number of brokers covered globally. Neither tells you what you need to know.
What you need is a list of specific sites that appear in search results when you search your own name and address, with confirmation of whether those specific sites appear in the service’s automated removal list.
Incogni’s broker list is partially documented in their published materials and was confirmed at 420 or more brokers by the Deloitte audit in August 2025. The audit confirmed broker coverage by count and removal frequency but did not publish the full list of brokers by name. Incogni’s published documentation categorises brokers by type: people-search, marketing data, B2B lead generation, risk mitigation, recruitment, and financial information.
DeleteMe’s coverage varies significantly by plan tier. The standard plan covers 85 automated brokers. The premium plan extends to approximately 262. The remaining brokers in their total claimed number require manual custom requests, limited to 40 per quarter on standard plans.
A good answer to this question names specific UK people-search sites and confirms whether they are in automated coverage. An evasive answer refers to global broker counts or geographic availability without specifying site-level coverage.
Question Two: Can Your Service Address Companies House or Electoral Register Exposure?
The honest answer to this question is no, and the reason is structural rather than a service limitation.
Companies House address records are part of a statutory public register. Removing or suppressing entries requires a formal application to Companies House under the Economic Crime and Corporate Transparency Act 2023. This process costs £30 per application, requires that the live registered office has already been updated, and is handled directly between the director and Companies House.
Open electoral register listings require a direct opt-out to the local council. There is no opt-out route that a third party can process on your behalf.
Both of these are upstream official sources. No broker opt-out service, automated or manual, can address them. The data that flows from these sources into commercial broker databases will keep flowing until the sources themselves are corrected.
A service that claims to address these sources, or implies that its privacy score accounts for these exposures, is misrepresenting its scope. A service that explains this limitation clearly before you subscribe is being honest.
Question Three: What Evidence Do You Provide That a Removal Was Confirmed?
Dashboards showing privacy scores and improvement trends are the norm. They are not the same as documented confirmation of specific removals.
Incogni’s Deloitte audit confirmed that removal requests are sent and that the company has processed over 245 million removals. It does not confirm that every removal request resulted in a confirmed deletion: some brokers may have suppressed data, some may have declined, and some may not have responded.
DeleteMe’s service includes human review and periodic privacy reports that document specific sites where information was found and what action was taken. That reporting model provides more granular per-site evidence than an aggregate dashboard.
A good answer to this question provides specific confirmation: which sites received requests, which confirmed deletions, which declined, and which have not responded. An evasive answer provides a dashboard metric without explaining what it measures.
Question Four: When Data Reappears After a Confirmed Removal, What Happens?
Broker databases refresh from upstream sources. Data that was removed from a broker site will often reappear when the broker’s next data acquisition cycle runs. This is not a service failure. It is how the system works.
The question is whether the service re-submits removal requests automatically and at what interval.
The Deloitte audit of Incogni confirmed that removal requests are re-submitted every 60 days for public brokers and every 90 days for private brokers. This recurring submission cycle is one of the clearest practical advantages of a subscription service over a one-time manual effort.
DeleteMe similarly re-submits removal requests on a recurring basis as part of active plan membership.
A good answer specifies the re-submission interval. An evasive answer describes the service as providing ongoing protection without explaining the mechanism.
Question Five: What Personal Data Do You Collect and Share With Brokers?
This question is the one most people never ask, and it is worth asking before you submit your personal details to any service.
To process removal requests, a service needs to know who to remove. You provide your name, current and recent addresses, email address, phone numbers, and potentially date of birth. The service then provides some or all of that information to data brokers to identify and remove your profile.
You are providing your personal details to a service, which then shares them with a list of data brokers, some of whom may previously have had limited information about you. That is a data sharing event.
Incogni, in the Deloitte audit context, confirmed that it does not sell user data to brokers or maintain broker affiliations. That specific commitment was part of the scope verified by Deloitte.
DeleteMe’s privacy policy describes how submitted personal information is used for the removal service process and the conditions under which it may be used for other purposes, with opt-out available.
A good answer from any service specifically confirms that your submitted personal data is used only for removal requests, that it is not retained beyond the service period, that it is not sold or shared for any commercial purpose, and ideally that this commitment has been independently verified.
An evasive answer directs you to a privacy policy without summarising the specific commitments relevant to this question.
The Summary Checklist
Before subscribing, get clear answers to:
Which specific UK people-search and data broker sites are in automated coverage, and are they the sites currently showing my data?
Can this service fix Companies House address records or open electoral register exposure, and if not, have I addressed those directly first?
What per-broker evidence is provided that a removal was confirmed, not just requested?
At what interval are removal requests re-submitted when data reappears?
What personal data is shared with brokers to process my requests, and what are the specific data handling commitments, verified by a third party if possible?
A service that answers all five questions clearly and specifically is a service worth considering. A service that deflects or responds with marketing language to any of these questions deserves more scrutiny before you share your personal details with it.
How to Turn This Into a Competitive Advantage
For MSPs and advisers, this five-question checklist is a client due diligence tool that most competitors have not developed. Being able to evaluate removal services rigorously on behalf of a client, and recommend one based on documented evidence rather than marketing claims, is a concrete differentiator.
For business owners, the checklist answers determine whether a service is fit for your specific situation. A subscription that cannot cover your actual top exposures is not a governance control. It is an administrative cost that creates false confidence.
How to Sell This to Your Board
The board question is simple: have we evaluated this service against our specific exposures, or did we subscribe based on a marketing claim?
If the service cannot fix Companies House or electoral register exposure, those sources need their own governance actions. If the service’s automated coverage does not include the broker sites currently holding director data, the subscription does not solve the relevant problem. The board should see documented answers to these questions, not a dashboard screenshot.
What to Do This Week
- Put all five questions in writing to any removal service you are currently evaluating or subscribed to.
- Run the two-hour test from Thursday’s guide if you have not done so, to establish which specific sites hold your data.
- Fix Companies House and electoral register exposure through official channels if you have not already.
- Evaluate any service response against the criteria in this guide.
- Document the evaluation, including the service’s answers and your coverage match assessment, and keep it with your risk register.