First Advantage respects the privacy of our offline/online 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 and other services. All data shall be collected, stored and used in compliance with applicable law, which may include the United States' Fair Credit Reporting Act ("FCRA"), the European Union Data Protection Directive and other international laws.

SCOPE
This Safe Harbor Privacy Policy applies to information pertaining to an identifiable individual residing in the European Union or other data that First Advantage acquires pursuant to its performance of services for its clients (“EU Personal Data"). This Policy does not apply to: (a) data collected and used by First Advantage which is not EU Personal Data; (b) the subsidiaries of First Advantage which do not receive EU Personal Data or; (c) data collected on any other First Advantage subsidiary website not related to EU Personal Data. The First Advantage Online Privacy Policy is located on www.FADV.com.

First Advantage is committed to protecting the privacy of personal data that is gathered and maintained on behalf of employers and clients requesting consumer data. We certify that, in relation to EU Personal Data, we adhere to the seven "Safe Harbor Principles" of the United States Department of Commerce as outlined in the European Commission's Directive on Data Protection. Our adherence to the seven Safe Harbor Principles is demonstrated below:

1. Notice
First Advantage gathers and maintains consumer 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. 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

The scope of this notice covers consumer report data that First Advantage has obtained on behalf of employers by manually or electronically contacting the appropriate sources of the data (court records, references, licensing bureaus, etc.). First Advantage also performs services related to corporate litigation and investigative services as requested by our clients. All services are performed in accordance with applicable local and national laws.

More information regarding the nature and scope of consumer data inquiries is available by contacting First Advantage in writing or by e-mail at the addresses listed on www.FADV.com or by writing to the contact listed below.

2. Choice
First Advantage affords individuals the opportunity to choose whether their personal information will be disclosed to a third party 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 data is not necessarily erased or deleted. Various laws require that the data be maintained on file for a specified period of time for consumer protection purposes.

A consumer can “opt-out” by contacting First Advantage in writing or by e-mail at the addresses listed on www.FADV.com 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 consumer data to third parties, the principles of “Notice” and “Choice” apply. Accordingly, consumer data is only provided to an employer or its agent for purposes described in the “Notice” section, 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.”

First Advantage will disclose consumer data to employers or their agents who certify that they subscribe to the Safe Harbor Principles or are subject to the FCRA, the Data Protection Directive or applicable regulations governing consumer data. In the alternative, First Advantage will also disclose consumer data to employers or their agents who enter into a written agreement with First Advantage, in which the third party agrees to comply with the FCRA, certifies that they have a permissible purpose to use such data, and provides 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 data collected and maintained about him or her. First Advantage 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.

First Advantage reserves the right to engage in reasonable efforts to confirm the identity of the individual requesting the data to ensure the information is provided only to the subject of the data.

First Advantage makes every effort to ensure that the data we collect and store is as accurate as possible. We cannot guarantee, however, that third party data sources are committed to making the same efforts, and therefore, we deny any responsibility for the accuracy of the data provided.

To request information relating to his or her personal data, a consumer may contact First Advantage in writing or by e-mail at the addresses listed on www.FADV.com or by writing to the contact 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, for a good reason, we are unable to provide the consumer with access to his or her data or to correct data, we will let him or her know.

5. Security
First Advantage takes all reasonable procedures to protect personal and identifiable information from loss, misuse, unauthorized access, disclosure, alteration and destruction. All of our users' information, not just the sensitive information mentioned above, is kept strictly confidential in our offices and is stored on our servers in a secure, encrypted manner. Only employees who need the information to perform a specific job are granted access to personally identifiable information. Strong password protection protocols are used on all computers. Furthermore, all employees are kept up-to-date on our security and privacy practices. Finally, the servers that are used to store personally identifiable information are kept in a secure environment, with appropriate security measures.

If you have any questions about the security of our service, you can send a letter to the contact listed below.

6. Data Integrity
First Advantage takes reasonable steps to ensure that data collected is accurate, complete, current, and reliable for its intended use. We only collect data that is strictly necessary for the purposes listed under the section entitled “Notice,” including (but not limited to) information that is necessary to identify the consumer.

7. Enforcement
First Advantage 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.

CONTACT INFORMATION
You may send any question regarding our Safe Harbor Privacy Policy to the following address and contact person:

First Advantage Corporation
Attn: Chief Regulatory Counsel
100 Carillon Parkway,
St. Petersburg, FL 33716
United States of America
727.290.1000

*We may amend this privacy policy from time to time as we add new products and services. Any changes that are made to the existing privacy policy of First Advantage will be posted on this website.