Corporate Screening Services, Inc. PRIVACY POLICY

Effective Date: May 25, 2018

Corporate Screening Services, Inc. (“CSS”) is a Consumer Reporting Agency as defined by the federal Fair Credit Reporting Act (“FCRA”). CSS is committed to protecting your privacy

This Privacy Policy covers CSS’s web site, and CSS’s practices for handling personal information provided to CSS over the Internet by the general public using CSS’s publicly available web site. This Policy also covers personal information provided by CSS’s clients, and their job applicants and employees (as well as other individuals who have given their written authorization for CSS’s clients to conduct a background investigation on them), using CSS’s online background screening solution that is accessible only through an access-restricted portion of CSS’s web site. CSS will collect, store, and use personally identifiable information only in compliance with applicable law, including the FCRA, individual state background screening and privacy laws, the European Union Data Protection Directive and other national laws. Please note that your use of the Site constitutes your acceptance of and consent to this Policy. When you sign up to use CSS products and services (the “Services”), you also consent to receive electronic notices and disclosures.

CSS reserves the right to change this Policy at any time. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Policy will mean you accept those changes.

This Policy seeks to answer questions you may have about the Services and CSS’s information practices. While we’ve tried to make this policy easy to follow and read, we understand that you may still have questions. If you do, you can contact us at Compliance@CorporateScreening.com. We’re here to help.

Information we collect

How does CSS use the collected information?

Sharing and onward transfer of information

Access, update and correcting your information

Does this Policy apply to third parties?

Choices regarding online tracking, analytics and email communications from CSS?

How does CSS protect your information?

Where is your information processed or stored?

Who can use the Services?

Recourse, Enforcement, and Liability

How can you contact CSS with more questions?

 

Information We Collect

Information Collected that is Provided Directly to Us

We may collect information you provide directly through the Services. For example, we may collect your name, email address, or other contact information when you access certain CSS content available through the Services such as whitepapers, videos, webinars, and other materials, or request additional information about CSS or the Services. CSS also collects information from you when you fill out any form in the Services such as when you submit questions or comments.

Information Collected When We Provide Services to Our Customers

If you want to use the Services to screen applicants (“Customers”), CSS may collect the following information (collectively, the “Customer Information”), including, but not limited to:

  • Account creation information, including your name, email address, and a custom password;
  • Contact information such as address and phone number;
  • Corporate and license information;
  • Hiring practice information such as employee work location and salary necessary for the application of state and federal consumer reporting laws
  • If you are an employer, employer identification number

Information Collected If You Are An Applicant Who Will Be The Subject Of A Background Check

If you are an applicant who will be the subject of a screening or background check (“Applicants”), CSS may collect the following information (collectively, the “Background Check Information”), including, but not limited to:

  • Account creation information, including your full name, e-mail address, and custom password;
  • Contact information, including phone number and address;
  • Identity verification information, including Social Security Number (or Social Insurance Number) and date of birth; and
  • Additional information or supporting documentation you submit or upload regarding identity, background, evidence of rehabilitation, or a dispute.

Examples include an uploaded picture, a driver’s license, or court records.

Information Automatically Collected When You Visit Our Website

When you visit or use the Services, we automatically gather certain technical and usage information, which may be associated with your user account. This technical and usage information (“Technical Information”) includes usage information, such as information on when, how often and for how long you use the Services; and server log data such as a computer’s IP address, browser type, device type, operating system and version, or the webpage you were visiting before you came to the Services.

Technical Information also includes “Cookies,” which are small text files containing a string of alphanumeric characters that are downloaded by your web browser when you visit a website. Like many online services, we may use both session cookies and persistent cookies when you access and use the Services. Cookies are used to remember your user account information and your preferences, to customize the Services for you and to assist us in measuring and analyzing utilization of the Services.

Third-party web analytics services providers we engage, such as Google Analytics, may use cookies in order to provide analytics services for the Services to us. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. Persistent cookies can be removed. Please review your web browser’s documentation to learn the best way to modify your cookie settings and see the section below regarding your choices on tracking 

How does CSS use the collected information?

This website only collects personally identifiable information from you if you choose to provide this information to CSS. CSS is the sole owner of the information collected on this Site. We only have access to information that you voluntarily give us via e-mail or other direct contact from you through this website. Only authorized employees have the ability to access or view this data.

We use information provided by you solely for the purpose of conducting the specific business transactions for which it was collected. Depending on the type of transaction or service requested, you may provide us with certain personally identifiable information (PII) such as first and last name; previously used names; social security number; date of birth, home address, or other physical address; email address (for contact purposes); telephone number; employment information, schools attended, licenses held and other information as required to process your verification. Other information might include usernames and passwords, information relating to any orders you place, or inquiries you make through our website.

This information is required for us to properly process criminal background checks, motor vehicle reports, employment verifications, education verifications, sanction checks, etc. We will only use the information collected from you for the purpose of completing your background screening. We will not release your PII to third parties except as necessary for us to process your transaction.

CSS does not engage in the practice of selling, renting or leasing your personally identifiable information to others. CSS may disclose personal information when audit requirements are necessary or when required by law or in the good faith belief to obey the law or comply with a legal obligation.

Sharing and Onward Transfer of Information

We may share the information we collect from and maintain about you as follows:

  • Employers or Other Customers Requesting Background Reports. We provide background reports, which may include Background Check Information, about Applicants to the requesting employer or Customer. We may also provide an employer or Customer other communications related to background reports such as notification of a dispute.
  • Furnishers and Researchers. We provide Background Check Information to entities that research and furnish data contained in background reports.
  • Service Providers. We may provide access to your information to select third parties who perform services on our behalf. These third parties provide a variety of services to us, including without limitation conducting components of background checks, billing, fulfillment, data storage, analysis and processing, identity verification, fraud, accounting, auditing, and legal services.
  • Affiliates. We may share information with our affiliates for use as described in this Policy.
  • Legal Requirements. We will use and disclose information where we, in good faith, believe that the law or legal process (such as a court order, search warrant or subpoena) requires us to do so or in other circumstances where we believe is necessary to protect the rights or property of CSS, our users, or third parties.
  • Consent. We may disclose your information to nonaffiliated third parties based on your consent to do so.
  • Business Transfer. In the event of a merger, sale of capital stock or assets, reorganization, consolidation or similar transaction involving CSS, or in contemplation of such a transaction (e.g., due diligence), the information we possess may be transferred as a corporate asset to the acquiring entity.
  • Analytics. We use Google Analytics for purposes of analyzing usage of the Services. You can find more information about Google privacy practices here. here.

Access, Update And Correcting Your Information

Applicants should promptly update their contact information if it changes or is inaccurate. Applicants may review, access, and change certain account information such as email address, phone number and mailing address via the applicant portal on the Services. Requests to change certain other information, such as Social Security Information, may require verification before the change is accepted. Applicants can request deletion of certain information in CSS’s control by contacting CSS as set forth at the end of this Policy. Applicants can dispute background check reports by contacting the CSS Compliance Department at 800-229-8606 or at Compliance@CorporateScreening.com.

Once a Customer, such as an employer, has received a background check report, CSS does not control the Customer’s retention of such information.

Our policy is to retain personally identifiable information only as long as reasonably necessary to provide the Services or as otherwise required for legal compliance purposes. For example, we may retain information, including from closed accounts, in order to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations of any user, enforce our Terms of Use, and/or for any other purposes otherwise permitted by law that we deem necessary in our sole discretion.

Does this Policy apply to third parties?

No. The Services may contain links to third-party websites, but this Policy does not apply to information that you may provide to or that may be collected by such third parties. We encourage you to review such third parties’ privacy policies and terms and conditions before engaging with such third parties.

Choices regarding online tracking, analytics and certain email communications from CSS?

  • Online Tracking and Cookies. Like many websites, the Services do not currently respond to “do not track” browser headers. But you can take steps to limit tracking by erasing cookies from your computer’s hard drive and by setting your browser to block all cookies or warn you before a cookie is stored. If you disable cookies, you may be prevented from taking full advantage of the Services because they may not function properly without cookies.
  • Analytics. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. here.

Promotional Emails. As discussed in this Policy, subject to any restrictions under applicable laws, we may send periodic promotional or informational emails to you. You may opt-out of such communications by clicking unsubscribe in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.

How does CSS protect your information?

CSS maintains safeguards to help protect the security of information we maintain about you. We may use encryption, passwords, and physical security measures to help protect your information against unauthorized access and disclosure. However, no security measures are 100% effective and we cannot guarantee your information will not be collected, disclosed and/or used by others. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, keeping your log-in and password private, and not recycling passwords from other websites or accounts. CSS is not responsible for the unauthorized use of your information nor for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity. WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ENSURING, GUARANTEEING, OR OTHERWISE OFFERING ANY DEFINITIVE PROMISE OF SECURITY IN CONNECTION WITH YOUR INFORMATION OR TECHNICAL INFORMATION.

Where is your information processed or stored?

CSS uses servers located in the United States. CSS may also use partners or affiliates located in other countries besides the US to process your information. By using the Services, you consent to the transfer of information outside of your country, even if your country has more rigorous data protection standards. 

Who can use the Services?

You must be 18 years of age or older to use the Services. If you are a parent or guardian and believe that your child under the age of 13 has provided personally identifiable information to us through the Services, please contact us at the contact information listed below. If we discover that an individual under 13 has provided us with personal information, we will take steps to delete the account and any such personally identifiable information to the extent required by applicable law.

Recourse, Enforcement, and Liability

Corporate Screening is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB).

CS verifies adherence to the EU-US and Swiss-US Privacy Shield by means of in-house verification by the management of this company. In addition, we provide readily available recourse mechanisms by which each individual’s complaints and disputes are investigated and resolved by reference to the Principles and damages are awarded where the applicable law or private sector initiatives so provide.

CS has agreed to participate in the dispute resolution procedures of the panels established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC)  to resolve disputes pursuant to the EU-US and Swiss-US Privacy Shield Principles.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

How can I contact you with more questions?

If you have any questions, concerns or complaints about this Policy or CSS’s handling of your personal information, or if you would like to access or update personal information that is not available via this website, please contact:

Quality & Compliance Manager

Corporate Screening Services, Inc.

16530 Commerce Court

Cleveland, OH 44130-6305

P: 800-229-8606 x383 F: 440-239-6203

compliance@corporatescreening.com