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
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 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.
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.
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.
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.
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.
- 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.
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.
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.
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.
EU-U.S. and Swiss-U.S. Privacy Shield Frameworks
We fulfill our obligation under the seven Privacy Principles in the following manner:
CS collects information on individuals for the purpose of providing the information to employers for employment related decisions. The information is used by employers to make decisions on whom to hire, retain, promote or re-assign. It may also be utilized to conduct employee investigations where an employer has a suspicion of work related misconduct or wrongdoing, or an issue arises as to employee compliance with Federal, State, or local laws and regulations, or any employer policies.
This notice covers human resources data that is obtained manually by this service on behalf of employers. The data is obtained by manually contacting the appropriate sources of the data.
A consumer may find out more about the nature and scope of any inquiry that is made about them by contacting this service through the contact links on this web site.
Consumers are given a choice to opt-out of having their personal information collected by way of a disclosure form provided to them by our client (their prospective or current employer) prior to a background investigation report being procured. The consumer can opt-out by not signing the disclosure, thereby stating they do not give their consent to have their personal information collected. By consenting to the procurement of a background investigation report, and submitting information to our client, the consumer is agreeing to allow CS to disclose information about them to our client and to our sharing that information with our subcontractors.
Choice is further afforded by the fact that CS only collects personal information from those employers, educational institutions, or other credential granting organizations that are identified by the consumer. The collected information is then only utilized for the purpose as described above in the section on “Notice.”
Accountability and Onward Transfer
Please note Corporate Screening may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
CS has taken and will continue to take appropriate measures to assure the security of personal data. Any personal data transmitted to or from CS web site is protected by a secure socket layer (SSL) key which encrypts the data transmitted over the Internet. Personal data on our servers is stored in a secure manner. Access to those servers and data is strictly limited to authorized personnel of CS, who have been trained to protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of personal data under CS control.
CS only collects data that is strictly for the purposes listed under the section on “Notice.” The data includes information that is necessary to identify the consumer for purposes of collecting employment related information.
If you are an EU or Swiss resident or a resident of any other country where CS is doing business, you may contact us at any time to determine whether we hold personal data about you and for purposes of reviewing your personal information. If you wish to have access to that information or to correct information that you have already received from us, please contact CS as listed below.
If the consumer wishes to have information in their report corrected, amended, or deleted CS will review that in accordance with section 611 of the Fair Credit Reporting Act.
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.
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