First Advantage has a separate privacy statement that applies to personal information pertaining to an identified
or identifiable individual that is received by First Advantage from the European Union, called the
European Union Safe Harbor Privacy Policy.
Welcome to First Advantage’s Web site. Please carefully read our privacy policy to understand how we will treat the information you provide while visiting this Web site ("Web site"). This policy may change from time to time. Please check the policy each time you use our Web site for the most current information. This policy only applies to this First Advantage Web site, www.fadv.com; some of First Advantage’s subsidiaries and affiliates may maintain their own privacy policies. Please refer to those Web sites for further information. This Web site is not intended for children and we do not knowingly collect any information about children.
First Advantage is a leading provider of risk mitigation and business solutions. We offer clients a comprehensive portfolio of best-in-class products, services and innovative tools to help them make smarter business decisions and empower them with timely, quality information. In order to market our services effectively and with due regard for the interests of consumers, we recognize that we have an obligation to protect the privacy and confidentiality of personally identifiable information (PII) that we may obtain about individuals through this Web site. Safeguarding the privacy of information we receive on this Web site is a top priority for consumers, our customers and First Advantage.
How We Collect and Use Information on Our Web Site
We follow the following privacy principles when you visit this Web site. In general, you can visit this First Advantage Web site on the World Wide Web without telling us who you are or revealing any information about yourself. Our Web servers automatically collect the domain names, not the e-mail addresses, of visitors. This information is used to measure the number of visits, average time spent on the site, pages viewed and similar information. First Advantage uses this information to measure the use of our Web site and to develop ideas to improve the content of our Web site.
There are times, however, when we may collect information from you, such as your name and email address. Typically, the instances when we collect information from you include when you request investor information, marketing information, additional information or sign up for a newsletter. The personal information we collect is used by us only to respond to such inquiries. If you choose to share any personal information with us, we will only use it in accordance with the following practices:
- Notice: If you elect to request investor information, marketing information, additional information or sign up for a newsletter, we will ask for certain types of information from you. The general purposes for which that information will be used or disclosed will be limited to the request you are making.
- Legal Requirements: The only exception to the non-disclosure policy is if disclosure is required by law.
- Security: We use safe and secure systems, physical and electronic, to safeguard the information that you provide on this Web site.
- Cookies: This Web site may make use of "cookie" technology to measure site activity and to customize information to your personal tastes. A cookie is an element of data that a Web site can send to your browser, which may then store the cookie on your hard drive. We only use “session” cookies. These cookies are not retained after you end your session.
- Changes to Policy: We may change this privacy policy in the future, but will not change our practices until they have been posted at this Web site. If changes occur, we will also show the new policy and the date of the revision on this Web site.
- Point of Contact: If you have any questions about this policy, please contact TAS@FADV.com.
How We Use and Collect Information in Our Various Businesses
A number of First Advantage businesses are consumer reporting agencies (CRAs) operating in accordance with the requirements of the Fair Credit Reporting Act (FCRA). FCRA establishes the following principles for all CRAs:
- Privacy: Information about you may only be furnished to third parties that have a permissible purpose. In general, these deal with credit, employment, insurance, rental or banking transactions initiated by you, or where the object is to make a firm offer to you. CRAs must qualify their customers to make certain that they have a permissible purpose to receive the information.
- Access: Consumers may receive a copy of information the CRA maintains about them. Such reports can be obtained free of charge once per year or for a reasonable fee for additional disclosures. Please visit the applicable subsidiary Web sites to obtain more information.
- Accuracy: CRAs must follow reasonable procedures to assure accuracy of the information they maintain and furnish. When you obtain a copy of your information, you have a right to dispute and have the information reinvestigated and corrected in the CRAs database.
- Fairness: Information is obtained from various sources including public records sources. However, certain information over a specified time period may not be reported.
- Accountability: The Federal Trade Commission is charges with overseeing the operations of CRAs and enforcing FCRA requirements.
First Advantage companies subject to FCRA operate within this framework. If you would like to obtain a report about the information we have about you, please visit the following Web sites:
http://www.fadv.com/uploadedFiles/Screening_And_Assessment/I9_EVerify_Solutions/FreeReport_requestforcopyofconsumerreportpacket.pdf
For credit reports from the credit bureaus:
https://www.annualcreditreport.com/cra/index.jsp
Privacy Notice: Preparation and Processing of Investigative Consumer Reports
This notice is provided to California residents. Under California law, an “investigative consumer report” is a consumer report containing information on a consumer's character, general reputation, personal characteristics, or mode of living. First Advantage compiles investigative consumer reports about individuals and provides them to business for background screening, tenant screening, and similar purposes.
Personal Information Disclosure: United States or Overseas – In connection with its preparation and processing of investigative consumer reports, First Advantage may transfer personal information about you to our authorized service providers and affiliates outside the United States and its territories. Such transfer will be conducted in accordance with all applicable laws and regulations.
To obtain additional information about the privacy practices and policies of First Advantage in connection with its preparation and processing of investigative consumer reports, please contact:
First Advantage Corporation
Nicolas Dufour, Chief Regulatory Counsel
United States
(202) 321-3585
For additional information about privacy or consumer reporting, visit the following Web sites:
Federal Trade Commission: www.ftc.gov
Consumer Data Industry Association: www.cdiaonline.org
Experian: www.experian.com/consumer/credit_education.html
Equifax: https://www.econsumer.equifax.com/consumer/landing.ehtml?^start=&companyName=PSHP1_hpg
TransUnion: http://www.transunion.com/corporate/personal/personal.page
California Office of Privacy Protection: www.privacy.ca.gov
European Union Safe Harbor Privacy Policy
First Advantage Corporation and First Advantage Corporation’s subsidiaries (“FADV”) respect the privacy of our visitors and clients. It is our policy to maintain the confidentiality and privacy of any personal data voluntarily submitted to us in writing, submitted electronically via our website, or submitted to us by our clients in connection with employment background screening, credential verification, investigations, credit and fraud risk management and other services.
SCOPE
This Safe Harbor Privacy Policy (“Policy”) applies to personal information pertaining to an identified or identifiable individual that is received by FADV from the European Union or other personal information that FADV acquires pursuant to its performance of services for its clients or other third parties to which FADV has contractually agreed to apply this privacy policy (“EU Personal Data"). This Policy does not apply to: (a) data collected and used by FADV which is not EU Personal Data; (b) the subsidiaries of FADV which do not receive or process EU Personal Data or; (c) data collected on any other subsidiary website not reasonably calculated to capture EU Personal Data. Those subsidiary websites reasonably calculated to capture EU Personal Data contain a link to this Safe Harbor Privacy Policy.
In the event of a conflict between this Policy and FADV’s obligations under the Fair Credit Reporting Act, 15 U.S.C. Sec. 1681 et. seq., other statutes, regulations, or case law, or to the extent necessary to meet national security, public interest or law enforcement requirements, adherence to this Policy may be limited.
PROVISIONS OF OUR SAFE HARBOR PRIVACY POLICY
FADV receives certain EU Personal Data at the request of clients and other third parties for investigative, credential verification, and employment related purposes, as well as credit and fraud risk mitigation related purposes. FADV has joined the U.S. Department of Commerce's "Safe Harbor" program with respect to EU Personal Data and utilizes such information in accordance with the Safe Harbor principles. The Safe Harbor principles and our Safe Harbor certification can be found at www.export.gov/safeharbor. Our Policy addresses each of the Safe Harbor Privacy Principles, as described below.
1. Notice
Where FADV collects EU Personal Data from individuals, FADV informs individuals about the purposes for which it collects and uses EU Personal Data about them, how to contact FADV with any inquiries or complaints, the types of third parties to which it discloses the information and the choices and means FADV offers individuals for limiting its use and disclosure. Notice is provided in clear and conspicuous language either when individuals are first asked to provide EU Personal Data or as soon thereafter as is practicable, but in any event before FADV uses such information for a purpose other than that for which it was originally collected or processed by the transferring organization or discloses it for the first time to a third party (other than agents acting under our instructions). Information about how FADV collects and uses EU Personal Data also follows below.
FADV gathers and maintains consumer and other data which it provides to employers or their agents (such as recruiters or staffing firms) for use in making employment-related decisions, such as who to hire, retain, promote, or re-assign. FADV also gathers and maintains consumer and other data which it provides to entities including lenders, credit reference agencies and fraud prevention agencies. Provided below is an illustrative list of common ways in which employers use the data provided by this service:
- Performance of applicant and employee background checks
- Verification of the credentials of job applicants and current employees
- Investigation into a suspicion of work-related misconduct or wrongdoing
- Investigation into matters of employee compliance with employer policies, or
- Investigation into matters of employee compliance with Federal, State, or local laws and regulations
Provided below is an illustrative list of common ways in which lenders, credit reference agencies and fraud prevention agencies use the data provided by this service:
- Authentication of consumer applicants for loans or other credit services
- Prevention or detection of fraud by consumer applicants for loans or other credit services
- Determination of credit worthiness or capacity of consumer applicants for loans or other credit services
- Location of absconded borrowers
The scope of this notice covers consumer report data that FADV has obtained on behalf of employers and other businesses by manually or electronically contacting the appropriate sources of the data (court records, references, licensing bureaus, etc.). FADV also performs services related to corporate litigation and investigative services as requested by our clients.
More information regarding the nature and scope of consumer data inquiries is available by contacting FADV in writing or by e-mail at the addresses listed on the Contact Us page or by writing to the contacts listed below.
2. Choice
FADV affords individuals the opportunity to choose whether their EU Personal Data will be disclosed to a third party (not including our agents) or will be used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by the individual. Therefore, consumer data may be disseminated under these circumstances unless the consumer explicitly “opts-out.” Where a consumer chooses to “opt-out,” the EU Personal Data is not necessarily erased or deleted. Various laws require that certain information be maintained on file for a specified period of time for consumer protection purposes.
A consumer may “opt-out” by contacting FADV in writing or by e-mail at the addresses listed on our Contact Us page or by writing to the contact listed below.
With respect to sensitive information, however, an individual must “opt-in” to the disclosure of the information to a third party or to the use of this information for a purpose other than its original purpose or that purpose authorized subsequently by the individual. In other words, unless a consumer chooses to provide explicit consent, a disclosure of sensitive information to a third party or for an unauthorized purpose will not be made.
3. Onward Transfer (Transfers to Third Parties)
With respect to the transfer of EU Personal Data to third parties (other than our agents), the principles of “Notice” and “Choice” apply. Accordingly, EU Personal Data is only provided to third parties for purposes described in the “Notice” section or otherwise disclosed to consumers, and will not be disseminated to a third party where a consumer has “opted-out” or, in the case of sensitive information, failed to “opt-in.”
FADV may disclose EU Personal Data clients and third parties, which may include lenders, credit reference agencies, fraud prevention agencies, employers or their agents, who certify that they subscribe to the Safe Harbor Principles or the EU Data Protection Directive or a law subject to an adequacy finding by the EU. FADV also may disclose EU Personal Data to employer clients, other types of clients or their agents who enter into a written agreement with FADV, in which the third party agrees to comply with the FCRA, if applicable, and to provide at least the same level of privacy protection as is required by the seven Safe Harbor Principles (in the instance where EU Personal Data is requested).
4. Access
A consumer may request, in writing, access to all EU Personal Data collected and maintained about him or her. FADV affords the consumer a reasonable opportunity to correct, amend, or delete information that is inaccurate or incomplete, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated. In cases where the information is subject to the FCRA, FADV complies with the FCRA’s requirements regarding access and correction rights of consumers.
FADV reserves the right to engage in reasonable efforts to confirm the identity of the individual requesting EU Personal Data to ensure the information is provided only to the subject of the data.
To request information relating to his or her EU Personal Data, a consumer may contact FADV in writing or by e-mail at the following email address, nicolas.dufour@fadv.com, or by writing to the contacts listed below. In addition, the consumer will be asked to provide sufficient evidence of his or her identity so we may ensure that information is being released to the correct individual. If we are unable to provide the consumer with access to his or her EU Personal Data or to correct the data, we will notify the consumer.
5. Security
FADV takes reasonable procedures to protect EU Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.
6. Data Integrity
FADV collects EU Personal Data that is relevant for the purposes for which it is to be used, consistent with the Safe Harbor Principles. We process EU Personal Data in ways that are compatible with the purposes for which it has been collected (as identified in the Notice section above) or subsequently authorized by the individual. To the extent necessary for those purposes, FADV takes reasonable steps to ensure that EU Personal Data collected is accurate, complete, current, and reliable for its intended use.
7. Enforcement
FADV will verify adherence to the EU Safe Harbor Policy via in-house verification and internal policies and procedures implemented by the management of our company. FADV also will cooperate with an independent third party as a means of providing consumers a readily available and affordable recourse mechanism by which individual consumer complaints and disputes, if any, can be investigated and remedied.
8. Amendments
From time to time, this Privacy Policy may be amended to reflect new products and services, or as necessary to reflect a new business practice. Consistent with the Safe Harbor requirements, we will post any revised policy on this website.
CONTACT INFORMATION
To request information relating to your EU Personal Data, please contact:
Click here to send us an inquiry.
If you have questions regarding our Safe Harbor Privacy Policy contact:
First Advantage Corporation
Nicolas Dufour, Chief Regulatory Counsel
United States
(202) 321-3585
Australian and New Zealand Privacy Policy
INTRODUCTION
First Advantage Australia Pty Ltd ACN 101 863 209 and First Advantage New Zealand Limited ("First Advantage", "we", "us" or "our") provides a background screening service for its clients (the Clients), to assist them in considering candidates for employment, change in the level of responsibility, other circumstances where an individual's background is relevant, or to determine if further verification or investigation is necessary.
As part of our services, we receive information about candidates for the purposes of conducting our checks. Some of this information may be "personal information" for the purposes of the Australia and New Zealand Privacy Acts: Privacy Act 1988 (Cth) & Privacy Act 1993 No. 28 (Act)(collectively referred to as the “Act”).
"Personal information" is defined (i) under the Australia Privacy Act , as "information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion", and (ii) under the New Zealand Privacy Act, as “Information about an identifiable individual; and includes information relating to a death that is maintained by the Registrar-General pursuant to the Births, Deaths, Marriages, and Relationship Registration Act 1995, or any former Act”. We recognise the importance of privacy issues and respect the confidentiality of the personal information candidates provide to us.
We will deal with personal and sensitive information in accordance with the Act, and our Privacy Statement and this Privacy Policy (both as amended from time to time).
This Privacy Policy is to be read in conjunction with the Privacy Statement. Should there be any difference between them, the provisions of the Privacy Policy will prevail.
SENSITIVE INFORMATION
We may collect other personal information which is sensitive information (e.g. criminal records, membership of a political association, health). Sensitive information is given a greater level of protection under the Act. The \ Act imposes greater obligations on us regarding any collection, use or disclosure we make of a candidate's sensitive information. Any sensitive information we collect will be done in accordance with the Act.
MAIN PURPOSES FOR WHICH WE COLLECT INFORMATION
When engaged by a Client, First Advantage verifies a candidate's information and responses by carrying out verification checks for the purposes of enabling the Client to assess a candidate's suitability for employment, promotion, provision of services, or other purposes in accordance with their legal obligations and internal risk management policy.
In certain circumstances, First Advantage may be engaged by a Client because they are required by law to determine a candidate’s suitability for a position of employment, for example under the Corporations Act 2001 (Cth) and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
In order to process and verify information for a Client's request, the Client and First Advantage may collect a candidate's personal information (including but not limited to information relating to background, character and personal reputation) from the candidate and, if necessary, use some or all of the collected personal information to collect additional personal information from various other entities (the Sources). Examples of Sources include, but are not limited to, government agencies, law enforcement bodies, publicly available records, public registries, court or tribunal records, ratings agencies, educational institutions, and regulatory and licensing bodies.
Depending on the background checks required by the Client and information candidates supply to us, we may also conduct background checks and collect information regarding employment history and references (with the exception of a candidate's current employer, unless the candidate has authorised such contact or commences employment with the Client), education, professional qualifications, residency, sanctions, immigration status, criminal records, claims, judgments, current and previous directorships, character, personal reputation, and such other checks and enquiries as the Client considers necessary to verify information provided by a candidate.
We may, from time to time, need to collect information about a candidate from a third party a candidate refers us to. In these circumstances, we will assume that the candidate has referred First Advantage to them and informed them of the purposes involved in the collection, use and disclosure of the relevant personal or other information.
HOW WE STORE AND USE PERSONAL INFORMATION
We may use and disclose the information and responses a candidate has provided to us to apply to the Sources for verification of a candidate's personal and other information a candidate or a third party has provided, and to conduct public record searches.
The personal information provided to us by a candidate and any other personal information provided by the Sources as a result of the verification process will be processed and provided by us.
First Advantage may then report the findings of its investigations to the Client via a secure means. The Client may then use that information to consider a candidate's suitability for employment, or change in the level of responsibility, other circumstances where an individual's background is relevant or to determine if further verification or investigation is necessary.
We store the personal information we receive in hard copy files and/or in electronic format in a database. We take precautions to store personal information securely. We may, from time to time, need to retain personal information collected from a candidate and the Sources to comply with our contractual, statutory or other legal obligations even after the employment or other application process is completed or terminated.
IDENTIFIERS
An "identifier" is a unique identification number assigned to a candidate by the Commonwealth Government or a Commonwealth Government Agency. Examples of identifiers include a Tax File Number (TFN) or a Medicare number. First Advantage does not use identifiers to identify a candidate's personal information in our systems.
OVERSEAS TRANSFERS OF PERSONAL INFORMATION
From time to time, we will need to transfer personal information overseas in order to liaise with the Sources, the Employer and/or our offshore related entities. We will transfer personal information overseas if:
- we reasonably believe that the recipient of the information is subject to a law or a contract which effectively upholds the Australian Privacy Legislation;
- the candidate has consented to the transfer;
- the transfer is necessary for us to provide the Client with their requested service;
- it is not practical to obtain a candidate's consent, the transfer is for the candidate's benefit and the candidate's consent would likely be given; or
- we have taken reasonable steps to ensure that a candidate's personal information will not be held, used or disclosed by the recipient in a manner inconsistent with this Privacy Policy and the Privacy Act.
ACCESS AND CORRECTION OF INFORMATION
A candidate may apply to obtain details of their personal information which is held by us. A candidate may apply for that information by contacting the Privacy Officer at the contact details set out in this Privacy Policy. Please note that the Privacy Officer listed below handles requests from Australia and New Zealand.
We will handle requests for access to a candidate’s personal information in accordance with the Privacy Act. However, in some circumstances permitted under the Privacy Act we may not be required to give a candidate access to the information we hold about them.
It is also important to us that the information we hold about a candidate is accurate, complete and up to date. If a candidate becomes aware that this is not the case and would like to correct their personal information, they may lodge a correction request by contacting the Privacy Officer at the contact details listed in this Privacy Policy. First Advantage will make all reasonable efforts to correct the information.
Any complaints about a breach of privacy will be dealt with in accordance with our Privacy Policy. If a candidate has a complaint about the way First Advantage has dealt with their personal information, a candidate may contact our Privacy Officer at:
The Privacy Officer
First Advantage
PO Box 455
North Sydney NSW 2059
Tel: + 61 2 9017 4300
If a candidate is unsatisfied with the outcome, they may refer the matter to the Privacy Commissioner at:
Australian Residents:
Website: www.privacy.gov.au
Tel: 1300 363 992
New Zealand Residents:
enquiries@privacy.org.nz
Tel: 04-474 7590
Japan Privacy Policy
Constitution Date: 1 July 2005
Revised Date: 1 December 2010
First Advantage Japan K.K.
General Manager - Timothy Stephen Bennett
Our company, as a business entity handling personal information and conducting pre-employment screening, observes the laws and regulations relating to personal information and respects the individual’s rights to personal information protection as well as the importance of a public mission of protection.
The Personal Information Protection Management System is structured in accordance with our policy below. We are hereby committed to regular improvement in terms of information technology, changes in social demands, and management environment.
- Personal information is collected, used and provided solely for the execution of our business operations relating to Pre-Employment Screening of personnel and for management of First Advantage Japan staff. No personal information will be handled beyond the specified purpose of use.
- All laws and regulations regarding personal information will be observed.
- Responsible security measures and corrective actions will be employed to safeguard against unauthorized access, loss, destruction and compromise of any personal information. We will ensure the continuous improvement of the Personal Information Protection Management System using reasonable management resources.
- Queries relating to the handling of personal information will be responded to promptly and with integrity.
- Regular improvements to the Personal Information Protection Management System will be made in accordance with changes to the situation and environment.
This policy is shared with all employees and available to all on the internet.
Inquiries:
Please contact below for inquiries relating to our privacy policy.
First Advantage Japan K.K.
ASK Bldg. 3F
1-24-4, Ebisu
Shibuya-ku, Tokyo 150-0013
E-mail: pmark@fadv.com
TEL：03‐5449‐7373 （9:00～17:30*）
* Monday – Friday except national holidays