Privacy Policy – First Advantage EMEA

First Advantage® Corporation Privacy Policy

Our Privacy Policy comprises a number of components. Click any link below to be transferred to the appropriate section:

First Advantage Biometric Information Privacy and Record Retention Policy

PRIVACY POLICY FOR ALL COUNTRIES EXCEPT THOSE SET FORTH BELOW

First Advantage Privacy Vision

First Advantage is committed to the responsible use of information and protecting individual privacy rights. First Advantage strives to provide services to businesses, consumers, non-profit organizations and government agencies that help reduce fraud, mitigate risk, facilitate more informed decisions, and make society safer, in ways that protect consumer privacy. We aspire to protect consumer privacy through the design of our products, by credentialing, monitoring, and auditing our customers as appropriate, and through other information security safeguards. We also strive to promote transparency through consumer education initiatives, privacy principles and policies, and appropriate opportunities for consumer choice, access, and correction with respect to personal information about the consumer.

Data Privacy Principles

The First Advantage Data Privacy Principles speak to the personally identifiable information including sensitive personally identifiable information, collected, maintained, used or disseminated in connection with services offered by First Advantage, or by its affiliates (all hereinafter “First Advantage”).

First Advantage applies these Principles to our domestic U.S. products and services where appropriate. In addition, other uses or disclosures may occur as required by applicable law, such as the Fair Credit Reporting Act and its state analogues (“FCRA”), the Driver’s Privacy Protection Act and its state analogues (“DPPA”), and the Gramm Leach-Bliley Act (“GLB”). If the law requires or upon request of law enforcement, or, if necessary, to prevent fraud or to protect our computer systems, these principles may not apply. First Advantage also, from time to time, may revise our Data Privacy Principles by posting changes on its Web site.

SECURITY

Data security is a company imperative. First Advantage strives to protect personally identifiable information that we maintain or disseminate, including using appropriate administrative, physical, and technical safeguards, so it is not obtained by unauthorized individuals or used impermissibly.

DISTRIBUTION OF PERSONALLY IDENTIFIABLE INFORMATION

First Advantage seeks to limit the distribution of personally identifiable information consistent with the nature and sensitivity of the information. In its services, First Advantage also strives to make available personally identifiable information from sources other than public records or publicly available information only to its authorized users or customers. Similarly, where applicable, First Advantage strives to restrict access to information in accordance with privacy laws such as the FCRA, the GLB, and the DPPA and comparable state statutes. In the case of public record information available to the general public (such as bankruptcy, liens, judgments, criminal records and Uniform Commercial Code filings) and publicly available information (such as telephone directory information or personal information available through widely available media), we may make this information available to the general public unless applicable law operates to limit our distribution of such information to authorized users.

If, upon investigation, First Advantage finds that personally identifiable information has been used or accessed inappropriately or unlawfully, First Advantage strives to take reasonable steps to stop the misuse or access, educate the user concerning the appropriate use of the information, and prevent similar future misuses. Such steps may include measures up to and including discontinuation of the user’s access to First Advantage information products and services, pursuit of other legal remedies, and the referral of misuse to the appropriate authorities.

ACCURACY

First Advantage strives to accurately report information in its products. First Advantage also strives to accurately report information that it receives from its data sources. First Advantage recognizes, however, that reporting errors may occur and offers consumers opportunities, where applicable, to dispute and correct information that we report as discussed further in Principle 9 on Access and Correction.

PROTECTION OF SOCIAL SECURITY NUMBERS AND DRIVER’S LICENSE NUMBERS

First Advantage strives to provide additional safeguards for sensitive personally identifiable information, such as Social Security numbers and driver’s license numbers. First Advantage strives to limit the availability and access to full Social Security Numbers (“SSNs”), Driver’s License Numbers and State Identification Numbers. First Advantage strives to protect the confidentiality of SSNs by limiting access to SSNs to certain legitimate and authorized users, such as: state, local and federal government entities; financial institutions; insurers; employers; creditors; debt collectors and other user types to which First Advantage may decide to provide such access. A limited number of public records may contain SSNs that are already available to the public and, if such public records are accessed through First Advantage services, our services may provide access to such SSNs. First Advantage prohibits the unlawful disclosure of

SSNs. First Advantage also takes steps to limit the availability of Driver’s License Numbers (“DLNs”) and state identification card numbers.

EDUCATION

First Advantage strives to inform its employees, users and the general public about appropriate use of First Advantage products and services. First Advantage strives to inform its users and employees about:

Privacy and security issues associated with First Advantage information products and services; and
The responsible use of personally identifiable information.

First Advantage strives to inform the public about:

The responsible use of personally identifiable information; and
Measures First Advantage has undertaken to enhance consumer privacy; and choices available to consumers regarding information access and the ability to opt-out of certain products and services which utilize personally identifiable information.

REPUTABLE SOURCES

First Advantage strives to acquire personally identifiable information from established, reputable sources in the government and private sectors. In support of this Principle, First Advantage takes reasonable steps to assess the reputation and reliability of its private sector data sources before incorporating personally identifiable information from the source into its products and services. First Advantage also strives to obtain assurances from its data suppliers that they have the legal right to license or sell the data to First Advantage.

NOTICE

First Advantage strives to make its Data Privacy Principles publicly known. First Advantage publicly posts these Data Privacy Principles.

Security;

Distribution of Personally Identifiable Information;

Accuracy;

Protection of Social Security Numbers and Driver’s License Numbers;

Education;

Reputable Sources;

Notice;

Choice;

Access and Correction;

Accountability;

Online Privacy;

Identity Theft; and

Compliance

CHOICE

First Advantage strives to allow customers to opt-out of the dissemination of personally identifiable information from certain First Advantage owned databases used solely for marketing our services to which customers have previously opted in.

ACCESS & CORRECTION

First Advantage strives to provide consumers with a central point of contact regarding their questions about First Advantage and its commitment to the responsible use of personally identifiable information. First Advantage strives to inform individuals about the nature of the public records, non-public information, and publicly available information that First Advantage makes available in its information products and services. First Advantage also strives, whenever practicable, to provide consumers, upon request, with meaningful opportunities to review personally identifiable information we maintain about them. First Advantage also strives, as appropriate and practicable, to provide opportunities for consumers to dispute and correct information by assisting them in identifying the potential information sources at which corrections should be made. First Advantage strives to direct individuals to the government and private entities that collect and maintain public records and publicly available information to correct any claimed inaccuracies found in that data, and to direct individuals to consumer reporting agencies where such agency is the source of the information about the individual and where the individual seeks to correct claimed inaccuracies found in that data.

ACCOUNTABILITY

First Advantage supports accountability of information industry standards and practices, responsible and effective federal regulation of the data industry, and legislation governing the practices of all data providers. First Advantage also supports industry oversight and active engagement with the privacy community. First Advantage believes that strong privacy and information security protections are vital for an effective and trusted data industry.

ONLINE PRIVACY

First Advantage strives to protect the privacy of personally identifiable information obtained over the Internet and strives to apply our Data Privacy Principles and evolving standards to the online environment.

IDENTITY THEFT

First Advantage strives to prevent the acquisition of information from its products and services for improper purposes, such as identity theft. First Advantage believes that it is important that individuals who may have had their sensitive personally identifiable information acquired by an unauthorized individual be notified as follows: Where an applicable law requires notice, First Advantage complies with the law. Where notification laws do not exist, First Advantage follows its Information Security Breach Response and Notification Policy, which provides that affected individuals will be notified when sensitive personally identifiable information owned or licensed by First Advantage is acquired by an unauthorized individual and whenever First Advantage has a reasonable basis to believe the breach has resulted in, or there is a significant risk that it will result in, identity theft to the consumer to whom the information relates.

COMPLIANCE

First Advantage will obtain assessments from a qualified, objective, independent third party, who uses procedures and standards generally accepted in the profession to assess First Advantage’ administrative, technical, and physical safeguards, as appropriate.

How We Use and Collect Information in Our Various Businesses

First Advantage collects Personal Data that is relevant for the purpose(s) for which it is to be used.

In order to process and verify information for a Client’s request, the Client and First Advantage may collect an individual’s Personal Information directly from the individual. Such data may be collected through live or recorded voice calls. We may also collect information about an individual from a third party a candidate refers us to. In these circumstances, we will assume that the individual 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.

We process Personal Data in ways that are compatible with the purpose(s) for which it has been collected (as identified in this Policy, or as subsequently authorized by the individual). To the extent necessary for those purposes, First Advantage takes reasonable steps to ensure that Personal Data collected is accurate, complete, current, and reliable for its intended use. First Advantage retains Personal Data only for as long as it serves a purpose of processing.

When engaged by a Client, First Advantage verifies an individual’s information, documentation and any responses by carrying out verification checks for the purposes of preparing an employment, investigative, or due diligence report. This is done at the Client’s request to enable them to assess an individual’s suitability for employment, promotion, provision of services, or other purposes in accordance with their legal obligations and internal risk management policy (including but not limited to insurance and claims review).

In certain circumstances, First Advantage may be engaged by a Client to prepare an employment or investigative report because they are required by law to determine a candidate’s suitability for a position of employment.

First Advantage may use the Personal Information, documentation and any responses an individual or third party reference has provided to us to apply to various other entities (“Sources”) for verification of an individual’s personal and other information, to collect additional Personal Information, and to conduct public record searches. Examples of Sources include, but are not limited to, government agencies, law enforcement bodies, publicly available records, public registries, court or tribunal records, educational institutions, current and/or previous employers, and regulatory and licensing bodies.

First Advantage will then use the Personal Information to prepare a report outlining the findings of its investigations and provide the report to the Client via a secure means. The Client may then use that information to consider an individual’s suitability for employment, change in the level of responsibility, or other circumstances where an individual’s background is relevant, or to determine if further verification or investigation is necessary.

We do not use the PII which we receive from the candidate for any marketing and advertising purpose. Any data used for statistical purposes will be anonymized.

A number of First Advantage businesses are consumer reporting agencies (CRAs) operating in accordance with the requirements of the Fair Credit Reporting Act (FCRA).

The 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 charged 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 call 800-8456004 or go to http://www.fadv.com/free-report-for-consumers.aspx.

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 email: privacy@fadv.com

For additional information about privacy or consumer reporting, visit the following Web sites:

Federal Trade Commission: www.ftc.gov

Consumer Financial Protection Bureau: http://www.consumerfinance.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=&compan yName=PSHP1_hpg

TransUnion: https://www.transunion.com/customer –support/contact –us#

California Department of Justice Privacy Unit: https://oag.ca.gov/privacy

All other requests, including customer and job applicant help, support or additional information please visit our contact page or call:

U.S. client support: 800.888.5773

APAC client support: +65 6534 3262

Canadian client support: 1.800.833.7511

EMEA client support: +44 (0) 8448 24 34 44

PRIVACY POLICY FOR USE OF THE FIRST ADVANTAGE WEB SITE

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 accessing through 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.

We also apply this privacy policy in the offline context in those limited cases where we require a consumer to provide his or her Social Security Number in order for the consumer to order an information product by mail or telephone.

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 below 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.

1. Personally-identifiable information

This site only collects personally-identifiable information from you if you choose to provide this information to us. Personally-identifiable information collected with your consent may include name, mailing address, e-mail address, telephone number, date of birth, credit card number, social security number, driver’s license number, user name and password, any response you provide to survey questions, information relating to any orders you place, or any inquires you may make through our web site. We also may request this type of information if you place an order by mail or telephone.

1. Cookies

“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. This site uses first and third party cookies, however personally identifiable information is not collected through the use of cookies. Cookies allow us to store your User ID during your visit to keep track of reports you have ordered or any updates to those reports. Cookies also help us detect potential fraud or misuse of our system.

While most browsers are set to accept cookies by default, you can set yours to refuse cookies or to alert you before accepting them. Your browser manufacturer has information on changing the default setting for your specific browser. However, be aware that if you do not accept cookies from this web site, you will not be able to use some of the features of this site, such as those for ordering reports.

III. Non-personally-identifiable information

This site also collects non-personally-identifiable information. For example, as you browse this web site we may collect information about your visit, but not about you personally. Via web server logs, for example, we may monitor statistics such as: the number of people that visit our site, which page(s) are visited on our site, from which domain our visitors come (e.g., aol.com, hotmail.com, etc.), and which browsers people use to visit our site (e.g., Google Chrome, Microsoft Internet Explorer, etc.). Our web site may use an outsourcing program to assist us in analyzing this data to better tailor our web site.

POLICY CHANGES

We may revise this online privacy policy from time to time. If we make any material changes, we will notify you by posting a prominent announcement on the web site. If we are going to use your personally identifiable information in a manner different from that stated at the time of collection we will notify you via email if an email address has been provided and is available. You will have a choice as to whether or not we use your information in this different manner.

INFORMATION USE AND CONSUMER CHOICE

The information collected by this web site is used only for responding to your inquiries and otherwise corresponding with you, for processing transactions you request, maintaining your account (if you have one), and for the administration, review and/or the improvement the content of our web sites. We do not share, sell, rent or trade PII with third parties for their promotional purposes.

We may contact you in response to your comments or inquiries, as part of the maintenance of your account with us (if you have one), or in order to complete a transaction that you requested.

We may also contact you to inform you of other products or services we think may be of interest to you, but we always offer you an opportunity to opt not to receive such communications.

If you decide that you do not want to receive further e-mails regarding your inquiry from First Advantage, you can reply to the e-mail or visit http://www.fadv.com/myemailsubscriptions with a request that we not continue to email you. We do not use outside data sources to enrich marketing data obtained online.

ONWARD TRANSFER

We may disclose information you provide to us to third parties in order to complete a transaction that you requested. If, for example, you pay for a transaction using a credit card, disclosing that information for processing purposes is necessary to complete the transaction. In other cases, it may be necessary to disclose information you provide about yourself or third parties in order to obtain the information product you requested. We may also outsource some tasks, including the operation of some website functions, which require access to information you supply online. In such cases, however, we require that the companies acting on our behalf abide by our privacy policy and institute safeguards to protect the confidentiality of your information.

If our company or our assets are acquired by another company, that company will assume responsibility for the personal information collected by us through this Web site and it will assume the rights and obligations regarding the information collected through this Web site, as described in this privacy policy.

Finally, please note that we may disclose personal information when required by law or in the good faith belief that such action is necessary in order to conform to the law or to comply with a legal process.

ACCESS AND CORRECTION

As an information company, we know the importance of accurate data. Therefore, we strive to maintain the accuracy of the information collected through this Web site. We will provide you (whether you are a consumer or a customer) with access to personally identifiable information you provide through this Web site for as long as we maintain that information in a readily accessible format. Similarly, we permit and encourage you to correct inaccuracies in the information you submit to us through this Web site.

If you wish to access information that you have submitted through this web site or to request the correction of any inaccurate information you have submitted through this site, please use the mechanisms provided by the site, or send an e-mail to privacy@fadv.com.

The access and correction provisions of this online privacy policy only apply to personally identifiable information collected from you through this web site. Individuals that are interested in information about how to access and/or request the correction of personal information First Advantage companies maintain about them for potential inclusion in information products and services can contact privacy@fadv.com.

SECURITY

We take steps to protect against the loss, misuse, or unauthorized alteration of personally-identifiable information collected through this web site and otherwise subject to this policy. We recognize the importance of security for all personally-identifiable information collected by our web site. Once we receive personally-identifiable information, we take steps to protect its security on our systems. In the event we request or transmit sensitive information, such as credit card information or Social Security Numbers through this web site, we use industry standard, secure socket layer (SSL) encryption.

We limit access to personally-identifiable information to those employees who need access in order to carry out their job responsibilities.

When we dispose of personally identifiable information collected through this website, we use procedures to dispose of personal information by means such as shredding documents and erasure of electronic media that information cannot be practicably read or reconstructed.

OTHER WEB SITES

In the online context, this online privacy policy only applies to the Web site(s) identified in the first paragraph of this privacy policy. Our Web site, however, may include links to other Web sites which may be operated by other First Advantage companies or by third parties. If you visit a Web site not listed above, we recommend that you review the online privacy policy of that Web site to determine how the operator of that Web site will handle personal information collected through that Web site.

EUROPEAN UNION AND UNITED KINGDOM EXTENSION DATA PRIVACY FRAMEWORK PRIVACY POLICY

First Advantage Corporation and its U.S. subsidiaries (“First Advantage”) complies with the EU-U.S. Data Privacy Framework as well as the United Kingdom Extension as set forth by the U.S. Department of Commerce (“DOC”) regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom (“EU / UK Personal Data”) to the United States in reliance on the Data Privacy Framework. You can find more information on this Data Privacy Framework at: https://www.dataprivacyframework.gov/.

First Advantage has certified to the DOC that it adheres to the Data Privacy Framework Principles with respect to such information. In the event of a conflict between this policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. Our Data Privacy Framework certification can be found at https://www.dataprivacyframework.gov/s/participant-search.

In compliance with the EU-US Data Privacy Framework Principles, First Advantage commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union with inquiries or complaints regarding this policy should first contact First Advantage at GDPR@fadv.com or at one of the contacts provided below. If such a complaint goes unresolved, First Advantage further commits to comply with the advice of the Data Protection Review Court (DPRC) established to investigate and resolve Data Privacy Framework complaints. Contact details for the EU data protection authorities can be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en#member-bg. Contact for the UK data protection authorities can be found at https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/.

Finally, First Advantage agrees to participate in binding arbitration for any complaints unresolved by the DPRC, ICO, or FTC that meet the conditions set forth in Annex I of the Data Privacy Framework requirements. For more information about binding arbitration please visit: https://www.dataprivacyframework.gov/s/All of the above-described recourse mechanisms are available at no cost to you.

In cases where First Advantage transfers EU / UK Personal Data received pursuant to the EU-US Data Privacy Framework onward to third party agents, First Advantage is potentially liable under the Data Privacy Framework Principles if its agents process that EU / UK Personal Data in a manner inconsistent with the Principles, unless First Advantage is not responsible for the event giving rise to the damage.

First Advantage is subject to the investigatory and enforcement powers of the Federal Trade Commission. First Advantage may be required to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

1. Notice

Where permissible and at the direction of its clients (that act as the data controller), First Advantage processes EU / UK Personal Data which it provides to its clients (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. First Advantage uses a limited number of third-party service providers to assist us in providing our services to clients. These third-party providers perform reference and credential verifications and complete portions of services requested by our clients, such as by obtaining records from data sources. These third parties may access or process personal data in the course of providing their services. First Advantage maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our Data Privacy Framework obligations.

The scope of this notice also covers personal data that First Advantage has obtained on behalf of employers by manually or electronically contacting the appropriate sources of the data (court records, education and employment references, licensing bureaus, etc.). First Advantage also performs services related to investigative services as requested by our clients.

2. Choice

First Advantage or its clients will offer individuals the opportunity to choose (opt-out) whether their EU / UK Personal Data will be disclosed to a third party (not including our agents) or will be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. With respect to sensitive information, however, an individual must “opt-in” to the disclosure of the information to a non-agent 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. First Advantage or its clients will provide individuals with a readily available mechanism to exercise their choices should circumstances arise that require opt-out or opt-in. In addition, First Advantage will treat as sensitive any EU / UK Personal Data received from a third party where the third party identifies and treats it as sensitive.

3. Onward Transfer (Transfers to Third Parties)

With respect to the transfer of EU / UK Personal Data to third parties (other than our agents), the principles of “Notice” and “Choice” apply. Accordingly, EU / UK Personal Data is only provided to these types of third parties for purposes described in the “Notice” section or otherwise disclosed to individuals, and will not be disseminated to such a third party where an individual has “opted-out” or, in the case of sensitive information, failed to “opt-in.”

Non-agent third parties to whom we transfer EU / UK Personal Data will be obligated to provide the same level of protection as the Data Privacy Framework Principles.

First Advantage may disclose EU / UK Personal Data to clients and third parties acting as agents. We will transfer such data only for limited and specified purposes and ascertain that agents are obligated to provide at least the same level of privacy protection as is required by the Data Privacy Framework Principles.

4. Security

First Advantage takes reasonable and appropriate measures to protect EU / UK Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

5. Data Integrity and Purpose Limitation

First Advantage collects EU / UK Personal Data that is relevant for the purpose(s) for which it is to be used, consistent with the Data Privacy Framework Principles. We process EU / UK Personal Data in ways that are compatible with the purpose(s) for which it has been collected (as identified in the Notice section above, or as subsequently authorized by the individual). To the extent necessary for those purposes, First Advantage takes reasonable steps to ensure that EU / UK Personal Data collected is accurate, complete, current, and reliable for its intended use. First Advantage retains EU / UK Personal Data only for as long as it serves a purpose of processing.

6. Access

An individual may request, in writing, access to EU / UK Personal Data collected and maintained about them, which First Advantage will make a good faith effort to provide. First Advantage affords the individual 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 EU / UK Personal Data to ensure the information is provided only to the subject of the data.

To request information relating to their EU / UK Personal Data, an individual may contact: First Advantage in writing or by e-mail at the following email address: GDPR@fadv.com; or by writing to the contacts listed below. In addition, the individual 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 individual with access to his or her EU / UK Personal Data or to correct the data, we will notify the individual.

7. Recourse, Enforcement and Liability

First Advantage will verify that its attestations and assertions about its privacy practices with respect to Data Privacy Framework are true and that those privacy practices have been implemented as presented via in-house verification and internal policies and procedures implemented by First Advantage management. First Advantage will take reasonable and appropriate steps to remediate any issue that comes to its attention with respect to compliance with the Data Privacy Framework Principles.

As described above, First Advantage will cooperate with the DPRC, ICO, and FTC as independent, readily available recourse mechanism by which individual complaints and disputes that cannot be resolved between the individual and First Advantage can be investigated and remedied at no cost to the individual and by reference to the Data Privacy Framework Principles.

First Advantage will respond promptly to inquiries and requests by the Department of Commerce for information related to the Data Privacy Framework, as well as to complaints regarding compliance with the Data Privacy Framework Principles referred by the EU Data Protection Authorities through the Department of Commerce.

First Advantage will arbitrate claims and follow the terms set forth in Annex I of the Data Privacy Framework requirements, provided that an individual has properly invoked binding arbitration and delivered notice to First Advantage in accordance with the appropriate procedures and conditions.

8. Amendments

From time to time, this policy may be amended to reflect new products and services, or as necessary to reflect a new business practice. Consistent with the Data Privacy Framework requirements, we will post any revised policy on this website.

CONTACT INFORMATION

To request information relating to your EU/UK Personal Data, please contact: GDPR@fadv.com.

If you have questions regarding this European Union Data Privacy Framework Privacy Policy, contact:

First Advantage Corporation

Data Protection Officer

Email: GDPR@fadv.com

SWITZERLAND DATA PRIVACY FRAMEWORK PRIVACY POLICY

First Advantage Corporation and its U.S. subsidiaries (“First Advantage”) complies with the Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the Switzerland to the United States. First Advantage has certified to the Department of Commerce that it adheres to the Data Privacy Framework Principles. If there is any conflict between the terms in this privacy policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification, please visit.

https://www.dataprivacyframework.gov/.

“Swiss Personal Data” is data pertaining to an identified or identifiable individual located in Switzerland that is received by First Advantage.

In compliance with the Swiss-U.S. Data Privacy Framework Principles, First Advantage commits to resolve complaints about our collection or use of your personal information. Individuals in Switzerland with inquiries or complaints regarding this policy should first contact First Advantage at GDPR@fadv.com or at one of the contacts provided below.

If such a complaint goes unresolved, First Advantage further commits to comply with the advice of the Swiss Federal Data Protection and Information Commissioner (“FDPIC”), established to investigate and resolve Data Privacy Framework complaints. Contact details for the FDPIC can be found at https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html. Finally, First Advantage agrees to participate in binding arbitration for any complaints that meet the conditions set forth in Annex I of the Data Privacy Framework requirements. For more information about binding arbitration please visit: https://www.dataprivacyframework.gov/s/. All of the above described recourse mechanisms are available at no cost to you.

In cases where First Advantage transfers Swiss Personal Data received pursuant to the Swiss-U.S. Data Privacy Framework onward to third party agents, First Advantage is potentially liable under the Data Privacy Framework Principles if its agents process that Swiss Personal Data in a manner inconsistent with the Principles, unless First Advantage is not responsible for the event giving rise to the damage. In the event of a conflict between this policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern.

1. Notice

Where permissible, First Advantage processes Swiss Personal Data at the direction of its clients (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.

First Advantage uses a limited number of third-party service providers to assist us in providing our services to customers. These third-party providers perform reference and credential verifications and complete portions of services requested by our customers, such as by obtaining records from data sources. These third parties may access or process personal data in the course of providing their services. First Advantage maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our Data Privacy Framework obligations.

The scope of this notice also covers Swiss Personal Data that First Advantage has obtained on behalf of employers by manually or electronically contacting the appropriate sources of the data (court records, education and employment references, licensing bureaus, etc.). First Advantage also performs services related to investigative services as requested by our clients.

2. Choice

First Advantage or its clients will offer individuals the opportunity to choose (opt-out) whether their Swiss Personal Data will be disclosed to a third party (not including our agents) or will be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. With respect to sensitive information, however, an individual must “opt-in” to the disclosure of the information to a non-agent 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. First Advantage or its customers will provide individuals with a readily available mechanism to exercise their choices should circumstances arise that require opt-out or opt-in. In addition, First Advantage will treat as sensitive any Swiss Personal Data received from a third party where the third party identifies and treats it as sensitive.

3. Onward Transfer (Transfers to Third Parties)

With respect to the transfer of Swiss Personal Data to third parties (other than our agents), the principles of “Notice” and “Choice” apply. Accordingly, Swiss Personal Data is only provided to these types of third parties for purposes described in the “Notice” section or otherwise disclosed to individuals, and will not be disseminated to such a third party where an individual has “opted-out” or, in the case of sensitive information, failed to “opt-in.”

Non-agent third parties to whom we transfer Swiss Personal Data will be obligated to provide the same level of protection as the Data Privacy Framework Principles.

First Advantage may disclose Swiss Personal Data to clients and third parties acting as agents. We will transfer such data only for limited and specified purposes and ascertain that agents are obligated to provide at least the same level of privacy protection as is required by the Data Privacy Framework Principles.

4. Security

First Advantage takes reasonable and appropriate measures to protect Swiss Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

5. Data Integrity and Purpose Limitation

First Advantage collects Swiss Personal Data that is relevant for the purpose(s) for which it is to be used, consistent with the Data Privacy Framework Principles. We process Swiss Personal Data in ways that are compatible with the purpose(s) for which it has been collected (as identified in the Notice section above, or as subsequently authorized by the individual). To the extent necessary for those purposes, First Advantage takes reasonable steps to ensure that Swiss Personal Data collected is accurate, complete, current, and reliable for its intended use. First Advantage retains Swiss Personal Data only for as long as it serves a purpose of processing.

6. Access

An individual may request, in writing, access to Swiss Personal Data collected and maintained about him or her, which First Advantage will make a good faith effort to provide pursuant to our client’s approval (as the client acts as the data controller). First Advantage affords the individual 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 Swiss Personal Data to ensure the information is provided only to the subject of the data.

To request information relating to his or her Swiss Personal Data, an individual may contact First Advantage in writing or by e-mail at the following email address: GDPR@fadv.com; or by writing to the contacts listed below. In addition, the individual 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 individual with access to his or her Swiss Personal Data or to correct the data, we will notify the individual.

7. Recourse, Enforcement and Liability

As described above, First Advantage will cooperate with the FDPIC as an independent, readily available recourse mechanism by which individual complaints and disputes that cannot be resolved between the individual and First Advantage can be investigated and remedied at no cost to the individual and by reference to the Data Privacy Framework Principles.

8. Amendments

CONTACT INFORMATION

If you have questions about this policy, or to request information relating to your Switzerland Personal Data, please contact:

First Advantage Corporation

Data Protection Officer

Email: GDPR@fadv.com

PRIVACY POLICY FOR THE EUROPEAN ECONOMIC AREA AND THE UNITED KINGDOM

First Advantage Europe Ltd. and its affiliates (“First Advantage”) are committed to protecting the personal data of individuals located in the European Economic Area (EEA) and the United Kingdom (UK) in compliance with the EU General Data Protection Regulation (EU-GDPR) for the EEA region and with the UK General Data Protection Regulation (UK-GDPR) for the UK region. The term ‘personal data’ in this policy, and under the GDPR, refers to any information relating to an identified or identifiable natural person, which is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

The information presented in this Privacy Policy (“Policy”) should be read in conjunction with any privacy notice(s) presented to you by the employer/prospective employer on whose behalf First Advantage is performing a background check.

This Policy was published on 1^st July. The content of this Policy may be updated from time to time. Please check our website regularly for the most current information.

Purposes for Processing Personal Data

First Advantage provides background screening services for the purposes of and at the direction of its clients (“Client”) to assist them in considering individuals for employment, changes in the level of responsibility and other circumstances where an employee’s background is relevant. This is achieved by preparing a background screening report for the Client.

The Client determines the lawful basis for such processing under the EU-GDPR or UK-GDPR, as the data controller. Further detail regarding the Client’s lawful basis is generally set forth in the Client’s privacy notice(s), which are presented, as appropriate, prior to the commencement of screening.

We recognise the importance of privacy and respect the confidentiality of the personal data individuals provide to us. As a data processor under both the EU-GDPR and the UK-GDPR, we process personal data in accordance with the instructions of our Client and comply with the requirements on processors under the EU-GDPR or UK-GDPR.

Data Processor and Data Controller Roles and Responsibilities

Both the EU-GDPR and the UK-GDPR differentiate between the “data controller” and the “data processor” of information and each have their own obligations under them with respect to the processing of your personal data. In general, our Client (i.e., your employer, or the entity with which you have applied for employment) is the data controller of personal data and determines the means and purposes for processing your personal data. First Advantage is the data processor for processing purposes. It is important to understand that, as the data processor, we act on the instructions from the data controller regarding your personal data.

Scope of Personal Data Processing

Clients determine the scope of the background checks conducted on each individual and First Advantage provides such checks upon the instructions of the Client. The personal data collected from you may include name, age, date of birth, contact details, address history, employment history, reference information, education, professional qualifications, residency, sanctions, immigration status, claims, judgments, insolvency, current and previous directorships, and such other information necessary to perform a background search or verification.

We may also process other categories of personal data (only where directed by our Client and permitted by applicable law) such as criminal records.

Sources of Personal Data

We receive your personal data from two primary sources: your employer/prospective employer and you. Based on the personal data we receive, we conduct a background check. In preparing the report, we may also receive personal data about you from third party data sources such as government agencies, law enforcement bodies, publicly available records, public registries, court or tribunal records, insolvency registers, educational institutions, your referees or references, current and/or previous employers, and regulatory and licensing bodies.

Use of Personal Data

First Advantage verifies your personal data by carrying out various types of checks for the purposes of preparing a background screening report.

First Advantage then compiles the personal data and search results into a report which is provided to the Client via a secure means. First Advantage does not use personal data for any reason other than to provide background screening services to our Client.

We do not use the PII which we receive from the candidate for any marketing or advertising purpose. Any data used for statistical purposes will be anonymised

Retention of Personal Data

First Advantage retains personal data only as long as it is required and in conformance with the Client’s requirements. Our Client, as the data controller, sets the data retention period. Certain legal requirements and/or government bodies may also require First Advantage to retain your personal data for a minimum or maximum period of time. In the absence of such predefined periods, First Advantage will delete your personal data two years from the date of completion of the background screening check.

Storage of Personal Data

Personal data for background checks conducted in the EEA and the UK is generally stored in the EU.

Cross Border Data Transfers

To the extent necessary in order to conduct the background check, your personal data may be transferred overseas (in other words, a “cross border transfer of data”) for processing purposes. The circumstances of cross border transfer may be as follows:

To our affiliated entities and/or third-party fulfilment partners to fulfil the services to our Client. Affiliates and third parties may be located outside of the EEA or the UK; and/or
To third party sources of information to the extent that you have lived or worked outside the EEA or the UK.

To affiliated entities and third-party fulfilment partners:

We may need to transfer your personal data to our affiliates located outside the EEA and the UK for administrative purposes, operational and/or processing purposes in connection with the preparation of a report to the Client.

We also use a limited number of third-party fulfilment partners to assist us in providing our background screening services to customers. These third parties perform reference and credential verifications and complete portions of services requested by our Clients, such as by obtaining records from data sources.

In all circumstances of cross border transfers of data to a First Advantage affiliate and/or third-party fulfilment partner, a data transfer agreement is in place in the EEA region and in the UK region containing appropriate Standard Contractual Clauses as approved by the EU Commission or by the UK Information Commissioner’s Office (ICO).

To third party sources of information:

We may need to transfer your personal data to sources outside the EEA and the UK region depending on your prior work or address history and the extent to which our Client requests us to verify certain information. For example, if you lived, studied or worked overseas, we may need to transfer certain limited personal data to liaise with sources, former employers, third party references, or educational institutions.

GDPR Data Subject Rights

First Advantage operates as the data processor on behalf of the data controller (i.e. your employer or prospective employer). If you are seeking to assert your rights either under the EU-GDPR or the UK-GDPR we ask that you do so through the Client at the address they have provided to you. Both the EU-GDPR and UK-GDPR provide rights such as the right of access, rectification, erasure, data portability, and restriction of processing. The Client (as data controller) will then instruct First Advantage on what action to take as necessary. As a reminder, the data controller will generally be your employer or the organisation to which you are applying for employment.

If you contact our Data Protection Officer (DPO) first via our GDPR mailbox (GDPR@fadv.com), we will ensure that the data controller is involved and aware of requests and/or concerns you send to us so that they have the opportunity to provide instruction to First Advantage.

Security of Information

First Advantage is committed to ensuring that your personal data is kept secure. We have a comprehensive data security program in place that implements appropriate technical and organisational measures and which at a minimum cover:

Protection against loss, misuse, or unauthorised alteration of personal data.
Our customer facing web applications utilise Secure Sockets Layer (SSL) encryption to protect all confidential data across the public network, reducing the risk of exposure.
In addition, data is encrypted while at rest when it is stored in our data centres, further protecting the data from unauthorised access or loss.
Access to personal data is strictly limited to those employees who need this access in order to carry out their job responsibilities.

When disposing of personal data, ensuring that information cannot be practicably read or reconstructed.

Our Data Centre, located in the EU, is certified to meet ISO Standard 27001:2013 and is regularly audited to ensure that the security controls are effective and in place.

EU Representative

To comply with the General Data Protection Regulation (2016/679), we have appointed a European representative. If you wish to contact them, their details are as follows: EUrepresentative@fadv.com.

Questions or Complaints

If you have a query or complaint or wish to understand more about how your personal data is handled, please contact our Data Protection Officer by email at GDPR@fadv.com.

If you are not satisfied with the outcome of a complaint and you are located in the United Kingdom, you may refer the matter to the UK Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/ or by calling their help line on +44 303 123 1113. Data protection authorities for other EU and EEA member countries can be located here: https://edpb.europa.eu/about-edpb/board/members_en

We are committed to protecting your personal data and investigating and resolving any complaints about our collection or use of your personal data.

PRIVACY POLICY FOR AUSTRALIA AND NEW ZEALAND

Introduction

This privacy policy applies to First Advantage Australia Pty Ltd ABN 67 101 863 209 and First Advantage New Zealand Limited [NZBN 9429034295540] ("First Advantage", "we", "us" or "our"). First Advantage provides a background screening service for its clients to assist them in making important decisions about their customers, employees, job applicants and other stakeholders in line with the Australian Privacy Principles and/or the New Zealand Information Privacy Principles.

Protecting your privacy is important to us. This policy sets out how we manage your personal information. It also sets out your rights in relation to the personal information we hold about you when you deal with us in Australia or New Zealand.

Types of personal information we collect

We collect different types of personal information depending on how you interact with us. If we are conducting background screening, the personal information we collect will depend on the type of background screening we are performing and the location where you live. In some circumstances, we may also collect sensitive personal information about you. The kinds of personal information that we collect about you may include:

Identifying information – such as your name, gender, photograph and date of birth.
Contact information – such as your postal address, email address and telephone number.
Financial information – such as credit card, bank account or other payment details.
Background-check information – such as your employment history, reference information, education, professional qualifications, residency, sanctions, criminal records, immigration status, claims, judgments, insolvency, current and previous directorships, character and personal reputation (including social media information) and medical assessments.
Usage information – information we collect when you use our website, such as server log information (your IP address, browser type, operating system, browser language, time zone, access times and any referring addresses).
Other information – this includes information about any products or services that we provide using your information, communications with you (including any messages you send us) and other information you voluntarily provide to us.

Without this information listed above, we may not be able to provide our services. We also require this information to offer the features and functionality of our website and other online products, and to respond to queries or requests that you submit to us.

How we collect your personal information

We collect personal information about you:

directly from you, including as part of background screening, when you submit a query or request to us or when you apply for a job with us;
from our clients, including where we are engaged to periodically screen a client’s employees or contractors;
when we are engaged to provide background screening services:
- from third parties who are entitled to disclose that information to us, such as government agencies, law enforcement bodies, publicly available records, public registries, court or tribunal records, insolvency registers, educational institutions, current and/or previous employers, regulatory and licensing bodies and medical assessment providers; and
- from public sources, such as social media and through search engine searches; and
by tracking your use of our website.

If we are conducting background screening on you, we will inform you of our background screening process and the types of information we collect when conducting a background check. In some cases, we will ask for your express consent for the collection of sensitive personal information.

How we use your personal information

We use the personal information that we collect about you for the following purposes:

to verify your identity when you are dealing with us;
to enable us to provide our products and services to you or one of our clients, including our background screening services;
to answer your queries and requests;
to comply with our legal and regulatory obligations;
to assess, maintain, upgrade and improve our products and services;
to carry out education and training programs for our staff;
to manage and resolve any legal or commercial complaints or issues; and
to keep you informed about our activities, including by sending out newsletters.

We may from time to time use your personal information in order to send you marketing materials about products or services that we think you may be interested in (including in some cases products and services that are provided by a third party). You can opt-out of receiving marketing communications from us by contacting us at privacy.sapac@fadv.com or following the “unsubscribe” link in the communication.

We may also use your information for other purposes if you ask or tell us to do so.

Who we share your personal information with

We may share personal information about you with:

our clients when we report back to them after we complete a background check on you;
your representatives, advisers and others you have authorised to interact with us on your behalf;
our staff who need the information to discharge their duties;
related entities within our corporate group;
our business partners, agents and service providers;
prospective purchasers of all or part of our business or shares in our company or a related entity;
professional advisers who we engage to provide advice on our business;
government authorities who ask us to disclose that information, or to other people as required by law; and
third parties who we use to help us provide our background screening services, such as government agencies, law enforcement bodies, educational institutions, current and/or previous employers and medical assessment providers

If we need to disclose personal information to third parties in a different country to where the information was collected, we will take steps to ensure that there is a lawful basis for the disclosure and that the disclosure complies with all applicable laws. This may include entering into a legally binding contract with the recipient under which they are obliged to handle your information in accordance with applicable laws.

How we store and protect your personal information

We use various secure computer systems located both within and outside of Australia and New Zealand to store your personal information. Our employees located outside Australia and New Zealand may undertake various components of background checks. As a result, we may transfer your personal information to our affiliates located in countries including Australia, Canada, India, the Netherlands, New Zealand, the Philippines, the USA or the UK.

We store personal information for as long as it is needed for the purpose for which it was collected, or as required by law. We generally store the personal information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers. Sometimes we also keep hard copy records of this personal information in physical storage facilities. We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats.

We ensure that our staff are aware of and properly trained in their obligations for managing your privacy. We limit access to personal information to those of our employees who require access in order to carry out their job responsibilities.

Access and correction of your personal information

We take reasonable steps to ensure that any personal information which we hold about you is accurate, complete and up-to-date, including promptly updating personal information when we are advised that the information has changed.

If you want to access any of the personal information that we hold about you or to correct some aspect of it (e.g. because you think it is incomplete or incorrect), please contact us using the details below.

There is no charge if you request access to your personal information, but we may require you to pay our reasonable costs in actually providing you with access. We will inform you of this before proceeding. There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality obligations. In these cases, we will let you know why we cannot comply with your request.

If you consider that the information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information if you so request. We may be unable to correct information about you if doing so would be contrary to law or impact the integrity of a product or service that we provide.

Updates to this policy

This policy will be updated where necessary to reflect changes in applicable laws or in our privacy compliance practices. The latest version of this policy will always be available on our website

How you can contact us

If you are concerned about the way in which we are managing your personal information, please contact our Privacy Officer at:

The Privacy Officer
First Advantage
PO Box R1783
Royal Exchange NSW 1225
Australia
Email: privacy.sapac@fadv.com

Complaints must be lodged in writing. We will deal with the matter within a reasonable time and will keep you informed of the progress of our investigation.

If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved satisfactorily, you can contact us to discuss your concerns. You are also entitled to make a complaint to the Privacy Commissioner in your country:

For Australia:

Website: www.privacy.gov.au
Email: enquiries@oaic.gov.au
Telephone: 1300 363 992 or +61 2 9284 9749

For New Zealand:

Website: www.privacy.org.au
Email: enquiries@privacy.org.nz
Telephone: 0800 803 909 or +64 4 474 7590

PRIVACY POLICY FOR JAPAN

CANADA PRIVACY POLICY

To read this policy in French, click here

First Advantage Canada, Inc. (“FADV,” “our”, “us” or “we”) provides background screening services for the purposes of and at the direction of its clients to assist them in considering individuals for employment, changes in the level of responsibility and other circumstances where an employee or prospective employee’s background is relevant. This is achieved by preparing a background screening report for the client.

Please carefully read our privacy policy to understand how we will treat personal information provided to us by candidates (“you”) and/or our client in the context of such background screening services. This policy may change from time to time. Please check the policy each time you use our site for the most current information.

Some of our subsidiaries and affiliates maintain their own privacy policies. Please refer to those unique websites directly for further information. This site is not intended for children and we do not knowingly collect any information about children.

How We Use and Collect Information in Our Specific Business Dealings

While international requirements vary, these acts all follow the same general principles: Privacy, Access, Accuracy, Fairness and Accountability.

As our main business operations for the performance of background screening services in Canada are in Canada, the following most specifically addresses our compliance requirements under the Personal Information Protection and Electronic Documents Act (PIPEDA).

We are committed to being an international leader in employee screening services by providing our clients the most accurate information and we take our role as a partner to our clients seriously. We believe in, and demonstrate, compliance and transparency in our business practices.

Summary of PIPEDA

PIPEDA applies to private-sector organizations across Canada that collect, use or disclose personal information in the course of a commercial activity. Consent is required for the collection, use or disclosure of personal information about an individual. The individual has a right to access their personal information and to challenge its accuracy, if necessary. Personal information can only be used for the purposes for which it was collected and this purpose must be clearly noted to the individual. Individuals should also be assured that their information will be protected by specific safeguards, including measures such as locked cabinets, computer passwords or encryption.

Core Principles of PIPEDA

1. Accountability: An organization is responsible for the personal information under its control and shall designate an individual or individuals accountable for the organization’s compliance with the following principles. This role is called a Privacy Officer.

2. Identifying Purposes: The purposes for which personal information is collected shall be clearly identified by the organization to the individual concerned, at or before the time the information is collected, and prior to any new use.

3. Consent: The knowledge and consent of the individual whose information is involved are required for the collection, use or disclosure of personal information, except where inappropriate.

4. Limiting Collection: The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means only.

5. Limiting Use, Disclosure and Retention: Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by the law. Personal information shall be retained only as long as necessary for fulfilment of those purposes.

6. Accuracy: Personal information shall be as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.

7. Safeguards: Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. This includes password-protected computers, shredding of documents and electronic retention of data as a preferred means to hard copy.

8. Openness: An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

9. Individual Access: Upon request, an individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

10. Challenging Compliance: An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals for the organization’s compliance.

Personal Information

Personal information includes any information, recorded or not, about an identifiable individual. The types of personal information about candidates that FADV collects, uses and discloses are described below under the heading "What Personal Information does FADV Collect." Personal information does not include the name, title, business address or telephone number of an employee of an organization (e.g. the name, title, business address and/or business telephone number of a candidate’s reference).

Consent

FADV requires the express written consent of individuals to deliver our services; this consent may be provided in hard copy or via electronic signature through our online platforms. In rare circumstances, FADV may be required to disclose personal information without the knowledge or consent of the candidate. These include disclosure to a third party when required or authorized by law, regulation, search warrant, subpoena or court order; in situations involving the collection of a debt owned by the individual to the organization; in an emergency that threatens the life, health or security of an individual; or upon suspicion of an illegal activity.

A candidate may withdraw their consent by advising the applicable client who ordered the background check. We rely on our clients to explain to candidates the implications relevant to the client of the candidate withdrawing their consent. If in the course of our services, we are informed a candidate has withdrawn their consent, we will cease work on the file and confirm with the client this action.

Accountability

Ryan Nardontonia, is our designated Privacy Officer and appointed representative for all privacy and records management issues. Mr. Nardontonia has complete authority to investigate, enforce, educate, and ensure compliance with FADV’s privacy policies and procedures. Clients and candidates may request a copy of or raise questions related to this privacy policy by contacting our Appointed Representatives at any time.

What Personal Information Does FADV Collect

Our company performs employment screening services for various companies and, depending on the nature of the client request, we may collect, use, disclose, transfer and retain some or all of the following personal information:

• Name / Maiden Name / Other Names (if applicable)

• Gender

• Date of Birth

• Social Insurance /Security Number

• Driver’s licence number

• Current address / address history

• Passport number

This information is generally provided to FADV in written format on the following documents:

• Resume

• Client’s official application form

• FADV’s consent release form

• FADV’s criminal consent release form

Additional information will only be collected if it is a requirement of completing the background check.

Identify the Purpose for Obtaining Personal Information

We receive personal information from our clients for the sole purpose of performing background checks on individuals. The personal information we require is dependent on the checks we need to complete and we ask our client and the candidate to only provide the personal information that is necessary. The use of this information is strictly limited to the fulfilment of the client’s request and will not be used by FADV for any other purpose.

NOTE: International searches may have unique and additional requirements. The candidate is made aware of the need for personal information:

• Verbally and in writing by the client

• By reading and signing the client’s and FADV’s consent form(s)

Once the information is in our possession, the candidate’s personal information will be used specifically for this client’s request and will not be used in association with any other request/search/client.

Obtain Consent

Depending on the services required by the client we will obtain consent through written forms only. When written consent is required to perform a service, FADV staff is required to retain a soft copy of this consent in the candidate’s file.

Under PIPEDA, for consent to be valid, individuals must be able to understand the consequences of the collection, use or disclosure to which they are consenting. While FADV takes all reasonable measures to protect data, there is always inherent risk when providing personal information. We have procedures and practices to safeguard your personal information against loss, theft and unauthorized access.

Limiting Collection

FADV collects only the information about candidates that is listed above to perform the searches requested by clients and will only request additional information when it is needed for the successful completion of the check. If we do make this type of request our staff will document when and why we need the additional personal data. We will not use any of the candidate’s personal information for any purpose other than to perform the checks as requested by the client.

We do not make any recommendations as to a candidate’s suitability for employment and leave that decision solely to the discretion of the client.

If a client cancels a request we will not collect or pursue any outstanding information. We will submit a report to the client outlining all of the information we obtained and cancel all outstanding requests for information.

Once a file is archived only authorized administrative personnel and management are allowed to access this information. The date and reasons for accessing this information will be documented in the candidate’s file.

Limit Use, Disclosure, and Retention

We will retain all documentation and personal data for each check we perform for a maximum period of two years. This will provide every candidate a reasonable amount of time in which to dispute any inaccuracies.

We will retain a soft copy of our findings (reports) for a maximum of two years (or whatever time period is required by our clients), after which this information is deleted from our databases.

We may share information you provide with affiliates, suppliers and/or sources in order to complete your background check. This includes the following:

• Suppliers and affiliates with whom we contract to complete background checks (we only provide these affiliates and suppliers the personal information necessary to run these checks);
• Past employers
• Educational institutions
• Professional licencing bodies
• Criminal/civil record sources
• Credit bureaus; and
• Online database holders

We will only send the results of the checks to the individual(s) who requested the checks or as directed by the administration of the account.

Accuracy

When our staff receives personal information which is unclear (i.e. difficult to read) we contact the client immediately and clarify the discrepancy. The client is then asked to provide clarification of same. We will not process any check without accurate information. The candidate also has the right to dispute the information we provide to the client if they believe it is inaccurate.

Use Appropriate Safeguards

Shredding of hard copies and deletion of electronic files is handled in a secure manner by FADV. All current and archived files containing personal data are housed in an office that is secured by lock and a security system. Files that are archived can only be accessed by authorized administrative personnel and management. We retain only soft copies of our final reports. Current soft copies are stored on the network, which is protected using a router -based firewall. A router is a safe and reliable means of protecting data because it provides two levels of security. Data is transmitted to and from our clients using fax, email, encrypted email, this online web interface and the telephone.

Be Open and Give Individuals Access to their Personal Information

Candidates can gain access to their personal information including their resume, list of references, and signed release forms, if applicable, by providing our Appointed Representative written notice. They must provide a legitimate reason for requesting the information and four personal identifiers, as requested, which may include date of birth, full name, social insurance number, and current and past addresses.

These will be used to verify the identity of the requestor before any information is released. Candidates who believe our company is in possession of inaccurate personal data that led to inaccurate checks or dispute the accuracy of our findings may write a letter which outlines the inaccuracy to our Appointed Representative. The candidate must also provide a copy of this letter to the client in question.

Our Appointed Representative will then have 30 days to investigate the issues and resolve any inaccuracies. Discrepancies, if any, will be communicated in writing to the client and candidate at the same time. We will also make any corrections to our files at that time. If a candidate’s request is, for any reason, denied they will receive a letter explaining why.

Challenging Compliance

If a candidate wishes to file a complaint and/or gain access to their personal information they may write to:

First Advantage Canada Inc.
C/O Ryan Nardontonia
2 Sheppard Ave East
Suite 603
North York, ON
M2N 7E7

Candidates must clearly state the nature of their inquiry, the client name, and provide their mailing address and telephone number. They must also provide personal identifiers including date of birth, full name, social insurance number, and current and past addresses, which will be used to verify the identity of the requestor as well as a clear, legible copy of one piece of government-issued photo identification.

Access to personal information will be disclosed within 30 days. FADV will provide access to all personal information except that permitted under PIPEDA to be exempted from disclosure. We will acknowledge receipt of a complaint inquiry with a written letter that will be mailed or emailed to the address provided. This letter will reiterate the nature of the inquiry and provide the candidate with a tentative date when the issue will be resolved. We will record and file the initial inquiry as well as the letter to the candidate in our files. Once a decision has been rendered it will be mailed to the candidate. A copy will also be filed in our records. A copy of all documentation used to arrive at the decision will be copied and filed in our records.

If the candidate disputes the decision he/she has a right to contact the Privacy Commissioner of Canada at:

112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa, Ontario
K1A 1H3

DATA PROTECTION CONTACT FOR SINGAPORE AND THE PHILIPPINES

Our Data Protection Officer for Singapore and the Philippines is Anselm Pinto.

To request information or receive help with data protection issues, contact our Data Protection Officer at:

Anselm Pinto

Regional Compliance Officer (NAPAC)

Email: privacy.napac@fadv.com

PRIVACY OFFICER FOR SOUTH KOREA

Our Privacy Officer for South Korea is Anselm Pinto.

To request information or receive help with data protection issues, contact our Privacy Officer at:

Anselm Pinto

Regional Compliance Officer (NAPAC)

Email: privacy.napac@fadv.com

PRIVACY POLICY FOR THAILAND

Last Updated: 1 June 2022

As a data processor of individual’s personal information, First Advantage and/or its affiliates (all hereinafter “First Advantage”) fully respects personal information, which is protected under the Personal Data Protection Act B.E. 2562 (2019) (the “PDPA”). We are committed to handling any personal data with transparency and in compliance with the PDPA.

This Policy has been prepared to explain our principles regarding personal data protection in compliance with the PDPA including the ways in which First Advantage collects, uses, and discloses individual’s personal information. However, full details of information required by the PDPA to be informed to such individual as a data subject (e.g. purposes of the collection of personal data, disclosure/transfer of personal data or retention period in more specific details), shall be fully presented to him/her, separately from this Policy, by First Advantage and/or his/her employer/prospective employer prior to or at the time of collection of the personal data.

What is Personal Data/Information

“Personal information/data” means any information relating to a natural person, which enables the identification of such natural person, whether directly or indirectly. However, personal information shall not include information of a deceased person.

First Advantage Privacy Vision

Data Privacy Principles

The First Advantage Data Privacy Principles speak to personal information including sensitive personal information, collected, maintained, used or disseminated in connection with services offered by First Advantage.

1. SECURITY

Data security is a company imperative. First Advantage strives to protect personal information that we maintain or disseminate, including using appropriate administrative, physical, and technical safeguards, so it is not obtained by unauthorized individuals or used impermissibly.

2. DISTRIBUTION OF PERSONAL INFORMATION

First Advantage seeks to limit the distribution of personal information consistent with the nature and sensitivity of the information. In its services, First Advantage also strives to make available personal information from sources other than public records or publicly available information only to its authorized users or customers. In the case of public record information available to the general public (such as bankruptcy, liens, judgments, criminal records and Uniform Commercial Code filings) and publicly available information (such as telephone directory information or personal information available through widely available media), we may make this information available to the general public unless applicable law operates to limit our distribution of such information to authorized users.

If, upon investigation, First Advantage finds that personal information has been used or accessed inappropriately or unlawfully, First Advantage strives to take reasonable steps to stop the misuse or access, educate the user concerning the appropriate use of the information, and prevent similar future misuses. Such steps may include measures up to and including discontinuation of the user’s access to First Advantage information products and services, pursuit of other legal remedies, and the referral of misuse to the appropriate authorities.

3. ACCURACY

4. PROTECTION OF SOCIAL SECURITY NUMBERS, DRIVER’S LICENSE NUMBERS AND IDENTIFICATION NUMBERS

First Advantage strives to provide additional safeguards for Social Security numbers, driver’s license numbers and identification numbers. First Advantage strives to limit the availability and access to full Social Security Numbers, Driver’s License Numbers and Identification Numbers. First Advantage strives to protect the confidentiality of these personal information by limiting access thereto to certain legitimate and authorized users, such as: government entities; financial institutions; insurers; employers; creditors; debt collectors and other user types to which First Advantage may decide to provide such access. A limited number of public records may contain these information that are already available to the public and, if such public records are accessed through First Advantage services, our services may provide access to such information. First Advantage prohibits the unlawful disclosure of the aforesaid information s well as any personal information.

5. EDUCATION

Privacy and security issues associated with First Advantage information products and services; and

The responsible use of personal information.

First Advantage strives to inform the public about:

The responsible use of personal information; and
Measures First Advantage has undertaken to enhance consumer privacy; and choices available to consumers regarding information access and the ability to opt-out of certain products and services which utilize personal information.

6. REPUTABLE SOURCES

First Advantage strives to acquire personal information from established, reputable sources in the government and private sectors. In support of this Principle, First Advantage takes reasonable steps to assess the reputation and reliability of its private sector data sources before incorporating personal information from the source into its products and services. First Advantage also strives to obtain assurances from its data suppliers that they have the legal right to license or sell the data to First Advantage.

7. NOTICE

First Advantage strives to make its Data Privacy Principles publicly known. First Advantage publicly posts these Data Privacy Principles.

Security;

Distribution of Personally Identifiable Information;

Accuracy;

Protection of Social Security Numbers and Driver’s License Numbers;

Education;

Reputable Sources;

Notice;

Choice;

Access and Correction;

Accountability;

Online Privacy;

Identity Theft; and

Compliance

8. CHOICE

First Advantage will allow customers to opt-out of the dissemination of personal information from certain First Advantage owned databases used solely for marketing our services to which customers have previously opted in.

9. ACCESS & CORRECTION

First Advantage will provide consumers with a central point of contact regarding their questions about First Advantage and its commitment to the responsible use of personal information. First Advantage strives to ensure that requests of an individual, who is a data subject, to exercise their right of access and correction will be fulfilled.

10. ACCOUNTABILITY

11. ONLINE PRIVACY

First Advantage strives to protect the privacy of personal information obtained over the Internet and strives to apply our Data Privacy Principles and evolving standards to the online environment.

12. IDENTITY THEFT

13. COMPLIANCE

How We Use and Collect Information in Our Various Businesses

First Advantage collects personal data that is relevant for the purpose(s) for which it is to be used.

In order to process and verify information for a Client’s request, the Client and First Advantage may collect an individual’s personal information directly from the individual. Such information may be collected through live or recorded voice calls. We may also collect information about an individual from our Client or a third party a candidate refers us to. In these circumstances, we will assume that the individual 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.

We process personal information in ways that are compatible with the purpose(s) for which it has been collected (as identified in this Policy, or as separately identified and informed to and subsequently authorized by the individual). We are also able to rely on grounds described under the PDPA to process personal information without individual’s authorization. Said grounds include but are not limited to:

Where it is necessary for us to enter into an agreement with an individual;

Where we have to comply with statutory obligations;

Where it is necessary for legitimate interests of us, our Client or any third party to collect, use or disclose individual’s personal information. However, where we rely on merely the basis of legitimate interests to collect, use or disclose personal information, we will take into account interests or fundamental rights of individual who is a data subject;

Where it is necessary for us to collect, use or disclose personal information for vital interests to prevent or suppress any danger to a person’s life, body or health; and

Where it is necessary for public interest or for the exercise of official authority.

For ‘sensitive personal information’, namely criminal history information; racial or ethnic origin; religious or philosophical beliefs; political opinions; heath data; biometric data, such as individual’s finger scans and facial data; labour union membership; and sexual orientation information, they will be processed in accordance with an individual’s explicit consent unless we are able to rely on the grounds described under the PDPA to collect, use or disclose sensitive personal information without obtaining individual’s consent. Should this be the case, we will do so in a limited manner and only to the extent allowed by applicable laws.

To the extent necessary for those purposes, First Advantage takes reasonable steps to ensure that personal information collected is accurate, complete, current, and reliable for its intended use. First Advantage retains personal information only for as long as it serves a purpose of processing.

First Advantage may use the personal information, documentation and any responses an individual or third party reference has provided to us to apply to various other entities (“Sources”) for verification of an individual’s personal and other information, to collect additional personal information, and to conduct public record searches. Examples of Sources include, but are not limited to, government agencies, law enforcement bodies, publicly available records, public registries, court or tribunal records, educational institutions, current and/or previous employers, and regulatory and licensing bodies.

First Advantage will then use the personal information to prepare a report outlining the findings of its investigations and provide the report to the Client via a secure means. The Client may then use that information to consider an individual’s suitability for employment, change in the level of responsibility, or other circumstances where an individual’s background is relevant, or to determine if further verification or investigation is necessary.

We do not use personal information which we receive from the candidate for any marketing and advertising purpose. Any data used for statistical purposes will be anonymized.

What are Individual’s Rights under the PDPAAs a data subject, individuals have the rights over their personal information that First Advantage holds about them under the PDPA. However, they may not be entitled to exercise all the rights since their rights are subject to the nature or the purpose of the collection, use or disclosure of your personal information carried out by First Advantage as will be further explained below.

Right to Withdrawal of Consent: Individuals have the right to withdraw their consent to collect, use and/or disclose their personal information so long as there are no restrictions in so doing by law or the contract which gives benefit to them. However, the withdrawal of consent shall not affect the collection, use, or disclosure of personal information for which they have already given consent legally.

Right to Access: Individuals have the right to request information about how their personal information is collected, used or disclosed, including the right to access to their own personal information and to obtain a copy of such personal information, as well as to request for disclosure of their personal information that they believe First Advantage obtained without their consent.

Right to Rectification: Individuals have the right to require First Advantage to correct or complete their personal information that they believe it is inaccurate or incomplete.

Right to Erasure: Individuals have the right to request First Advantage to have their personal information erased and to have confirmation of such erasure, or to make their personal information anonymous under certain conditions and on certain grounds in accordance with the PDPA, as follows:

Where their personal information is no longer necessary in relation to the purpose for which it was collected, used or disclosed;

Where their consent for collection, use or disclosure of such personal information is withdrawn, and where First Advantage has no legal grounds for such collection, use or disclosure;

Where they have objected to the collection, use or disclosure of their personal information, and First Advantage has no legal ground to reject such request; or

Where there is no legal basis for the collection, use or disclosure thereof.

Right to Restriction: Individuals have the right to request First Advantage to restrict the use of their personal information in the following circumstances:

Where there is a pending examination process to their request for rectification as stated above;

Where they have a right to erasure on the grounds that the collection, use or disclosure of their personal information carried out by First Advantage is unlawful but they do not want such personal information to be erased;

Where their personal information is no longer needed for the purpose of collection, use or disclosure but they still require it for the establishment, exercise or defence of legal claims; or

Where they have objected to the collection, use or disclosure of their personal information, and the verification of such objection is pending.

Right to Data Portability: Individuals have the right to request that First Advantage sends or transfers their personal information which First Advantage collected and arranged to be in a format readable or commonly used by ways of automatic tools or equipment, and which can be used or disclosed by automated means to another organization or directly to them in accordance with the conditions and grounds specified under the PDPA. Their right in this regard will only apply to the personal information which they have consented to be collected, used or disclosed, or which the First Advantage collects, uses or discloses by relying on the necessity for performance of a contract.

Right to Object: Individuals have the right to object to the collection, use or disclosure of their personal information in accordance with the conditions and grounds specified under the PDPA, for example, where the First Advantage relies on the legitimate interest ground to collect, use or disclose their personal information without their consent, unless First Advantage can demonstrate compelling legitimate grounds for the collection, use or disclosure which override their interests; or where it was done for the establishment, exercise or defence of legal claims.

Right to Lodge a Complaint: Individuals have the right to lodge a complaint to relevant committee(s) under the PDPA if Advantage or its employees fail to comply with the PDPA or the announcements issued under the PDPA.

To obtain additional information about the privacy practices or exercise your rights as a data subject, please contact:

First Advantage Corporation

Bret Jardine, Esq.

General Counsel

United States

Telephone: +1.678.710.7260

Email: privacy.sapac@fadv.com

All other requests, including customer and job applicant help, support or additional information please visit our contact page or call:

U.S. client support: 800.888.5773

APAC client support: +65 6534 3262

Canadian client support: 1.800.833.7511

EMEA client support: +44 (0) 8448 24 34 44

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