Requiring legal first and last name

Last we week we rolled out a change requiring creators to provide your legal first and last name.
We made these changes to support international sanctions compliance. I received a few questions via DM and wanted to share this FAQ in case other folks had some similar questions. Please let me know if there’s anything else you’d like help with around this.


Why is this now a requirement?

Patreon requires this information so we can verify ownership of the account, reduce the risk of fraud, and comply with our regulatory obligations. You will need to submit your legal first name, legal last name and country of residence. This is not shown on your public profile. Patreon may contact you privately to request additional information to ensure compliance with applicable laws and regulations. You can read our Sanctions Policy here.

Is this new? Have I done this before? Is there a database where this information already lives?

This is new. Previously, you only inputted your Creator name (or display name), which is different from your legal first and last name.

With this change, your “creator name” will be visible on your public Patreon page, but your legal name will not be visible. Because this is a new field of information we’re requiring in order to comply with our regulatory obligations, this information has not previously been stored in any database.

How is this information going to be used? Is it just to check against the sanctions database, or will it be transferred to third parties?

As a global company based in the United States with operations in other countries, we must comply with economic sanctions and trade restrictions, including those implemented by the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury. This means that Patreon cannot take part in transactions that involve designated people, places, or items that originate from those places, as determined by agencies like OFAC.

Our payment partners may independently monitor transactions for sanctions compliance, and they may block transactions as part of their own regulatory obligations. Patreon has no authority or control over the independent decision-making of these providers.

What do we put as our legal Name if there are 2 people running the account (ie business partner)?

We suggest listing the owner who will have principal administrative rights, e.g. they will contact Customer Service to make any changes to their account. You can always update and change the name on your account settings page.

Are there any other resources?

Sanctions Policy: https://support.patreon.com/hc/en-us/articles/360038061371-Sanctions-Policy

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@mindy Are we also to assume that this information will never be made public unless the creator wants it to be made public?

From what I am reading above we will be displaying the creator name only at this point and not showing legal names. What I don’t see (or know) is will this ever be an option or a requirement to show the public. I am assuming it will always be hidden if a creator wants it but was wondering if you can verify.

Thank you Mindy!

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Thanks @Ready_Art! here are some more answered FAQS:

Will this ever be an option or a requirement to show the public my legal first and last name?

No.

What about in the case of a data security breach?

We have internal data use policies and measures to limit access to sensitive user data.

How isolated (or not) is required first name and last name from a creators’ display names?

We currently store these fields together in our database and have the necessary access control to keep that data from being associated externally. We are dedicated to protecting user data through continually assessing and working towards the best path to user data protection, as we understand the sensitive nature of legal names for those in the creative field.

For GDPR deletion requests, we will null out these fields and replace the creators’ legal names with randomized fake names outside of our production environment.

Our payment partners may independently monitor transactions for sanctions compliance, and they may block transactions as part of their own regulatory obligations What does independently mean?

Independently in this context means that our third payment partners have regulatory obligations that they must adhere too. Patreon cannot impose or influence a decision made as a result of their own account reviews. We are not sending the creator name anywhere currently for payments or tax. This is separate from the W9/W8 info.

Do you need it in Latin characters or greek?
At this time, we support Latin characters but do not support Greek characters.

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@mindy Wow - that was an incredibly in-depth response!

THANK YOU! Thanks to the staff too!

-Ready

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Posting in my capacity as a Creator, not Discourse Staff

… can you try again with answering this? As phrased, the original post does not answer this question, it merely reiterates the reason for the change. Something along the lines of citing GDPR Article 6(1)(c) (“necessary for compliance with a legal obligation”) would be good, or pointing to your updated basis-for-processing documentation :slight_smile:

The rest of the post is informative, thanks.

Also, shouldn’t this be in #posts-from-Patreon:announcements ?

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Thanks for your patience @Riking which I worked with the various teams within Patreon to find out the specific info for you here.

No, we do not share this information with third parties. We use this info to check against the sanctions database and ensure we are in compliance with laws. To see a full explanation of how data is collected and used, please visit our Privacy Portal.

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