Privacy Policy

Online Privacy Policy 
First Advantage has a separate privacy statement that applies to personal information pertaining to an identified or identifiable individual that is received by First Advantage from: (i) the European Union, called the
European Union Safe Harbor Privacy Policy, (ii) from Switzerland, called the Switzerland Safe Harbor Privacy Policy, (iii) from Australia and New Zealand, called the Australian and New Zealand Privacy Policy, and (iv) from Japan, called the Japanese Privacy Policy

Singapore Data Protection Information
Our Data Protection Officer for Singapore is Kerstin Bagus. To request information or receive help with data protection issues, contact our Data Protection Officer at: 
Kerstin.Bagus@fadv.com
+1.678-710-7138 direct
+65 6534 3262

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; 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.

I. 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.

II. 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. Nonpersonally-identifiable information

This site also collects nonpersonally-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 e-mail 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, that 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 with 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.

How We Use and Collect Information in Our Various Businesses  

A number of First Advantage businesses are consumer reporting agencies (CRAs) operating in accordance with the requirements of the Fair Credit Reporting Act (FCRA). FCRA establishes the following principles for all CRAs:
Privacy: Information about you may only be furnished to third parties that have a permissible purpose. In general, these deal with credit, employment, insurance, rental or banking transactions initiated by you, or where the object is to make a firm offer to you. CRAs must qualify their customers to make certain that they have a permissible purpose to receive the information.

Access: Consumers may receive a copy of information the CRA maintains about them. Such reports can be obtained free of charge once per year or for a reasonable fee for additional disclosures. Please visit the applicable subsidiary Web sites to obtain more information.

Accuracy: CRAs must follow reasonable procedures to assure accuracy of the information they maintain and furnish. When you obtain a copy of your information, you have a right to dispute and have the information reinvestigated and corrected in the CRAs database.

Fairness: Information is obtained from various sources including public records sources. However, certain information over a specified time period may not be reported.

Accountability: The Federal Trade Commission is charges with overseeing the operations of CRAs and enforcing FCRA requirements.

First Advantage companies subject to FCRA operate within this framework. If you would like to obtain a report about the information we have about you, please call 800-845-6004 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 contact: 

First Advantage Corporation
Nicolas Dufour, Chief Regulatory Counsel
United States
(202) 321-3585
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=&companyName=PSHP1_hpg
TransUnion:
http://www.transunion.com/corporate/personal/personal.page
California Office of Privacy Protection:
www.privacy.ca.gov.  

 

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, nonprofit 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.

1. SECURITY

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

2.  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.

3. 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.

4. 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. 

5.  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.

6.  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.

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 strives to allow consumers to opt-out of the dissemination of personally identifiable information from certain First Advantage owned databases used solely for marketing services.

9. 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, nonpublic 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.

10. 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.

11. 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.

12. 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 a state law requires notice, First Advantage complies with the law. In those states 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.

13. 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.

 


European Union Safe Harbor Privacy Policy

First Advantage Corporation and First Advantage Corporation's subsidiaries ("FADV") respect the privacy of our visitors and clients. It is our policy to maintain the confidentiality and privacy of any personal data voluntarily submitted to us in writing, submitted electronically via our website, or submitted to us by our clients in connection with employment background screening, credential verification, investigations, credit and fraud risk management and other services.

SCOPE 

This Safe Harbor Privacy Policy ("Policy") applies to personal information pertaining to an identified or identifiable individual that is received by FADV from the European Union or other personal information that FADV acquires pursuant to its performance of services for its clients or other third parties to which FADV has contractually agreed to apply this privacy policy ("EU Personal Data"). This Policy does not apply to: (a) data collected and used by FADV which is not EU Personal Data; (b) the subsidiaries of FADV which do not receive or process EU Personal Data or; (c) data collected on any other subsidiary website not reasonably calculated to capture EU Personal Data. Those subsidiary websites reasonably calculated to capture EU Personal Data contain a link to this Safe Harbor Privacy Policy.

In the event of a conflict between this Policy and FADV's obligations under the Fair Credit Reporting Act, 15 U.S.C. Sec. 1681 et. seq., other statutes, regulations, or case law, or to the extent necessary to meet national security, public interest or law enforcement requirements, adherence to this Policy may be limited. 

PROVISIONS OF OUR SAFE HARBOR PRIVACY POLICY 

FADV receives certain EU Personal Data at the request of clients and other third parties for investigative, credential verification, and employment related purposes, as well as credit and fraud risk mitigation related purposes. FADV has joined the U.S. Department of Commerce's "Safe Harbor" program with respect to EU Personal Data and utilizes such information in accordance with the Safe Harbor principles. The Safe Harbor principles and our Safe Harbor certification can be found at www.export.gov/safeharbor. Our Policy addresses each of the Safe Harbor Privacy Principles, as described below.  

1. Notice  

Where FADV collects EU Personal Data from individuals, individuals are informed about the purposes for which it collects and uses EU Personal Data about them, how to contact FADV with any inquiries or complaints, the types of third parties to which it discloses the information and the choices and means FADV offers individuals for limiting its use and disclosure. Notice is provided in clear and conspicuous language either when individuals are first asked to provide EU Personal Data or as soon thereafter as is practicable, but in any event before FADV uses such information for a purpose other than that for which it was originally collected or processed by the transferring organization or discloses it for the first time to a third party (other than agents acting under our instructions). Information about how FADV collects and uses EU Personal Data also follows below. 

FADV gathers and maintains consumer and other data which it provides to employers or their agents (such as recruiters or staffing firms) for use in making employment-related decisions, such as who to hire, retain, promote, or re-assign. FADV also gathers and maintains consumer and other data which it provides to entities including lenders, credit reference agencies and fraud prevention agencies. Provided below is an illustrative list of common ways in which employers use the data provided by this service: 

Performance of applicant and employee background checks  

Verification of the credentials of job applicants and current employees  

Investigation into a suspicion of work-related misconduct or wrongdoing  

Investigation into matters of employee compliance with employer policies, or  

Investigation into matters of employee compliance with Federal, State, or local laws and regulations  

Provided below is an illustrative list of common ways in which lenders, credit reference agencies and fraud prevention agencies use the data provided by this service: 

Authentication of consumer applicants for loans or other credit services 

Prevention or detection of fraud by consumer applicants for loans or other credit services 

Determination of credit worthiness or capacity of consumer applicants for loans or other credit services 

Location of absconded borrowers 

The scope of this notice covers consumer report data that FADV has obtained on behalf of employers and other businesses by manually or electronically contacting the appropriate sources of the data (court records, references, licensing bureaus, etc.). FADV also performs services related to corporate litigation and investigative services as requested by our clients.  

More information regarding the nature and scope of consumer data inquiries is available by contacting FADV in writing or by e-mail at the addresses listed on the Contact Us page or by writing to the contacts listed below.  

2. Choice 

FADV will offer individuals the opportunity to choose (opt-out) whether their EU Personal Data will be disclosed to a third party (not including our agents) or will be used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by the individual. 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. FADV will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.

3. Onward Transfer (Transfers to Third Parties) 

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

FADV may disclose EU Personal Data clients and third parties, which may include lenders, credit reference agencies, fraud prevention agencies, employers or their agents, who certify that they subscribe to the Safe Harbor Principles or the EU Data Protection Directive or a law subject to an adequacy finding by the EU. FADV also may disclose EU Personal Data to employer clients, other types of clients or their agents who enter into a written agreement with FADV, in which the third party agrees to comply with the FCRA, if applicable, and to provide at least the same level of privacy protection as is required by the seven Safe Harbor Principles (in the instance where EU Personal Data is requested).  

4. Access 

A consumer may request, in writing, access to all EU Personal Data collected and maintained about him or her. FADV affords the consumer a reasonable opportunity to correct, amend, or delete information that is inaccurate or incomplete, except where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy, or where the rights of persons other than the individual would be violated.  In cases where the information is subject to the FCRA, FADV complies with the FCRA's requirements regarding access and correction rights of consumers.  

FADV reserves the right to engage in reasonable efforts to confirm the identity of the individual requesting EU Personal Data to ensure the information is provided only to the subject of the data.  

To request information relating to his or her EU Personal Data, a consumer may contact FADV in writing or by e-mail at the following email address, privacy@fadv.com, or by writing to the contacts listed below. In addition, the consumer will be asked to provide sufficient evidence of his or her identity so we may ensure that information is being released to the correct individual. If we are unable to provide the consumer with access to his or her EU Personal Data or to correct the data, we will notify the consumer.

5. Security 

FADV takes reasonable procedures to protect EU Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.   

6. Data Integrity 

FADV collects EU Personal Data that is relevant for the purposes for which it is to be used, consistent with the Safe Harbor Principles.  We process EU Personal Data in ways that are compatible with the purposes for which it has been collected (as identified in the Notice section above) or subsequently authorized by the individual.  To the extent necessary for those purposes, FADV takes reasonable steps to ensure that EU Personal Data collected is accurate, complete, current, and reliable for its intended use. 

7. Enforcement 

FADV will verify adherence to the EU Safe Harbor Policy via in-house verification and internal policies and procedures implemented by the management of our company. FADV also will cooperate with an independent third party as a means of providing consumers a readily available and affordable recourse mechanism by which individual consumer complaints and disputes, if any, can be investigated and remedied.   

8. Amendments 

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

CONTACT INFORMATION 

To request information relating to your EU Personal Data, please contact: 
privacy@fadv.comIf you have questions regarding our Safe Harbor Privacy Policy contact:  

First Advantage Corporation
Nicolas Dufour, Chief Regulatory Counsel
United States
(202) 321-3585
privacy@fadv.com

 

Switzerland Safe Harbor Privacy Policy

First Advantage Corporation and First Advantage Corporation's subsidiaries ("FADV") respect the privacy of our visitors and clients. It is our policy to maintain the confidentiality and privacy of any personal data voluntarily submitted to us in writing, submitted electronically via our website, or submitted to us by our clients in connection with employment background screening, credential verification, investigations, credit and fraud risk management and other services.

SCOPE 

This Safe Harbor Privacy Policy ("Policy") applies to personal information pertaining to an identified or identifiable individual that is received by FADV from Switzerland or other personal information that FADV acquires pursuant to its performance of services for its clients or other third parties to which FADV has contractually agreed to apply this privacy policy ("Switzerland Personal Data"). This Policy does not apply to: (a) data collected and used by FADV which is not Switzerland Personal Data; (b) the subsidiaries of FADV which do not receive or process Switzerland Personal Data or; (c) data collected on any other subsidiary website not reasonably calculated to capture Switzerland Personal Data. Those subsidiary websites reasonably calculated to capture Switzerland Personal Data contain a link to this Safe Harbor Privacy Policy.

In the event of a conflict between this Policy and FADV's obligations under the Fair Credit Reporting Act, 15 U.S.C. Sec. 1681 et. seq., other statutes, regulations, or case law, or to the extent necessary to meet national security, public interest or law enforcement requirements, adherence to this Policy may be limited. 

PROVISIONS OF OUR SAFE HARBOR PRIVACY POLICY 

FADV receives certain Switzerland Personal Data at the request of clients and other third parties for investigative, credential verification, and employment related purposes, as well as credit and fraud risk mitigation related purposes. FADV has joined the U.S. Department of Commerce's "Safe Harbor" program with respect to Switzerland Personal Data and utilizes such information in accordance with the Safe Harbor principles. The Safe Harbor principles and our Safe Harbor certification can be found at www.export.gov/safeharbor. Our Policy addresses each of the Safe Harbor

Privacy Principles, as described below.  

1. Notice  

Where FADV collects Switzerland Personal Data from individuals, FADV informs individuals about the purposes for which it collects and uses Switzerland Personal Data about them, how to contact FADV with any inquiries or complaints, the types of third parties to which it discloses the information and the choices and means FADV offers individuals for limiting its use and disclosure. Notice is provided in clear and conspicuous language either when individuals are first asked to provide Switzerland Personal Data or as soon thereafter as is practicable, but in any event before FADV uses such information for a purpose other than that for which it was originally collected or processed by the transferring organization or discloses it for the first time to a third party (other than agents acting under our instructions). Information about how FADV collects and uses Switzerland Personal Data also follows below. 
FADV gathers and maintains consumer and other data which it provides to employers or their agents (such as recruiters or staffing firms) for use in making employment-related decisions, such as who to hire, retain, promote, or re-assign. FADV also gathers and maintains consumer and other data which it provides to entities including lenders, credit reference agencies and fraud prevention agencies. Provided below is an illustrative list of common ways in which employers use the data provided by this service: 

Performance of applicant and employee background checks  

Verification of the credentials of job applicants and current employees  

Investigation into a suspicion of work-related misconduct or wrongdoing  

Investigation into matters of employee compliance with employer policies, or  

Investigation into matters of employee compliance with Federal, State, or local laws and regulations  

Provided below is an illustrative list of common ways in which lenders, credit reference agencies and fraud prevention

agencies use the data provided by this service: 

Authentication of consumer applicants for loans or other credit services 

Prevention or detection of fraud by consumer applicants for loans or other credit services 

Determination of credit worthiness or capacity of consumer applicants for loans or other credit services 

Location of absconded borrowers 

The scope of this notice covers consumer report data that FADV has obtained on behalf of employers and other businesses by manually or electronically contacting the appropriate sources of the data (court records, references, licensing bureaus, etc.). FADV also performs services related to corporate litigation and investigative services as requested by our clients.  

More information regarding the nature and scope of consumer data inquiries is available by contacting FADV in writing or by e-mail at the addresses listed on the Contact Us page or by writing to the contacts listed below.  

2. Choice 

FADV affords individuals the opportunity to choose whether their Switzerland Personal Data will be disclosed to a third party (not including our agents) or will be used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by the individual. Therefore, consumer data may be disseminated under these circumstances unless the consumer explicitly "opts-out." Where a consumer chooses to "opt-out," the Switzerland Personal Data is not necessarily erased or deleted. Various laws require that certain information be maintained on file for a specified period of time for consumer protection purposes.  

A consumer may "opt-out" by contacting FADV in writing or by e-mail at the addresses listed on our Contact Us page or by writing to the contact listed below.  

With respect to sensitive information, however, an individual must "opt-in" to the disclosure of the information to a third party or to the use of this information for a purpose other than its original purpose or that purpose authorized subsequently by the individual. In other words, unless a consumer chooses to provide explicit consent, a disclosure of sensitive information to a third party or for an unauthorized purpose will not be made. 

3. Onward Transfer (Transfers to Third Parties) 

With respect to the transfer of Switzerland Personal Data to third parties (other than our agents), the principles of "Notice" and "Choice" apply. Accordingly, Switzerland Personal Data is only provided to third parties for purposes described in the "Notice" section or otherwise disclosed to consumers, and will not be disseminated to a third party where a consumer has "opted-out" or, in the case of sensitive information, failed to "opt-in."  

FADV may disclose Switzerland Personal Data clients and third parties, which may include lenders, credit reference agencies, fraud prevention agencies, employers or their agents, who certify that they subscribe to the Safe Harbor Principles or the Switzerland Data Protection Directive or a law subject to an adequacy finding by Switzerland. FADV also may disclose Switzerland Personal Data to employer clients, other types of clients or their agents who enter into a written agreement with FADV, in which the third party agrees to comply with the FCRA, if applicable, and to provide at least the same level of privacy protection as is required by the seven Safe Harbor Principles (in the instance where Switzerland Personal Data is requested).

4. Access 

A consumer may request, in writing, access to all Switzerland Personal Data collected and maintained about him or her. FADV affords the consumer a reasonable opportunity to correct, amend, or delete information that is inaccurate or incomplete, except where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy, or where the rights of persons other than the individual would be violated.  In cases where the information is subject to the FCRA, FADV complies with the FCRA's requirements regarding access and correction rights of consumers. 

FADV reserves the right to engage in reasonable efforts to confirm the identity of the individual requesting Switzerland Personal Data to ensure the information is provided only to the subject of the data.  

To request information relating to his or her EU Personal Data, a consumer may contact FADV in writing or by e-mail at the following email address, privacy@fadv.com, or by writing to the contacts listed below. In addition, the consumer will be asked to provide sufficient evidence of his or her identity so we may ensure that information is being released to the correct individual. If we are unable to provide the consumer with access to his or her Switzerland Personal Data or to correct the data, we will notify the consumer.

5. Security 

FADV takes reasonable procedures to protect Switzerland Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.   

6. Data Integrity 

FADV collects Switzerland Personal Data that is relevant for the purposes for which it is to be used, consistent with the Safe Harbor Principles.  We process Switzerland Personal Data in ways that are compatible with the purposes for which it has been collected (as identified in the Notice section above) or subsequently authorized by the individual.  To the extent necessary for those purposes, FADV takes reasonable steps to ensure that Switzerland Personal Data collected is accurate, complete, current, and reliable for its intended use. 

7. Enforcement 

FADV will verify adherence to the Switzerland Safe Harbor Policy via in-house verification and internal policies and procedures implemented by the management of our company. FADV also will cooperate with an independent third party as a means of providing consumers a readily available and affordable recourse mechanism by which individual consumer complaints and disputes, if any, can be investigated and remedied.   

8. Amendments 

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

CONTACT INFORMATION 

To request information relating to your Switzerland Personal Data, please contact: 

Click here to send us an inquiry. 

If you have questions regarding our Safe Harbor Privacy Policy contact:  

First Advantage Corporation
Nicolas Dufour, Chief Regulatory Counsel
United States
(202) 321-3585
privacy@fadv.com

 

Australian and New Zealand Privacy Policy

INTRODUCTION

First Advantage Australia Pty Ltd ACN 101 863 209 and First Advantage New Zealand Limited ("First Advantage", "we", "us" or "our") provides a background screening service for its clients (the Clients), to assist them in considering candidates for employment, change in the level of responsibility, other
circumstances where an individual's background is relevant, or to determine if further verification or investigation is necessary. 

As part of our services, we receive information about candidates for the purposes of conducting our checks. Some of this information may be "personal information" for the purposes of the Australia and New Zealand Privacy Acts: Privacy Act 1988 (Cth) & Privacy Act 1993 No. 28 (Act)(collectively referred to as the “Act”).

"Personal information" is defined (i) under the Australia Privacy Act, as "information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be
ascertained, from the information or opinion", and (ii) under the New Zealand Privacy Act, as “Information about an identifiable individual; and includes information relating to a death that is maintained by the Registrar-General pursuant to the Births, Deaths, Marriages, and Relationship Registration Act 1995, or any former Act”. We recognise the importance of privacy issues and respect the confidentiality of the personal information candidates provide to us.

We will deal with personal and sensitive information in accordance with the Act, and our Privacy Statement and this Privacy Policy (both as amended from time to time).

In the event a candidate does not provide the information required to perform the background screening services, First Advantage may not be able to process the background check for a Client.

SENSITIVE INFORMATION

We may collect other personal information which is sensitive information (e.g. criminal records, membership of a political association, health). Sensitive information is given a greater level of protection under the Act. The Act imposes greater obligations on us regarding any collection, use or disclosure we make of a candidate's sensitive information. Any sensitive information we collect will be done in accordance with the Act.

MAIN PURPOSES FOR WHICH WE COLLECT INFORMATION

When engaged by a Client, First Advantage verifies a candidate's information and documentation and any responses by carrying out verification checks for the purposes of enabling the Client to assess a candidate's suitability for employment, promotion, provision of services, or other purposes in accordance with their legal obligations and internal risk management policy.

In certain circumstances, First Advantage may be engaged by a Client because they are required by law to determine a candidate’s suitability for a position of employment, for example under the Corporations Act 2001 (Cth) and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

In order to process and verify information for a Client's request, the Client and First Advantage may collect a candidate's personal information (including but not limited to information relating to background, character and personal reputation) from the candidate and, if necessary, use some or all of the collected personal information to collect additional personal information from various other entities (the Sources). Examples of Sources include, but are not limited to, government agencies, law enforcement bodies, publicly available records, public registries, court or tribunal records, ratings agencies, educational institutions, and regulatory and licensing bodies.

Depending on the background checks required by the Client and information candidates supply to us, we may also conduct background checks and collect information regarding employment history and references (with the exception of a candidate's current employer, unless the candidate has authorised such contact or commences employment with the Client), education, professional qualifications, residency, sanctions, immigration status, criminal records, claims, judgments, current and previous directorships, character, personal reputation, and such other checks and enquiries as the Client considers necessary to verify information provided by a candidate.

We may, from time to time, need to collect information about a candidate from a third party a candidate refers us to. In these circumstances, we will assume that the candidate has referred First Advantage to them and informed them of the purposes involved in the collection, use and disclosure of the relevant personal or other information.

HOW WE STORE AND USE PERSONAL INFORMATION

We may use and disclose the information and documentation and any responses a candidate has provided to us to apply to the Sources for verification of a candidate's personal and other information a candidate or a third party has provided, and to conduct public record searches.

The personal information provided to us by a candidate and any other personal information provided by the Sources as a result of the verification process will be processed and provided by us.

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

We store the personal information we receive in hard copy files and/or in electronic format in a database. We take precautions to store personal information securely. We may, from time to time, need to retain personal information collected from a candidate and the Sources to comply with our contractual, statutory or other legal obligations even after the employment or other application process is completed or terminated.

IDENTIFIERS

An "identifier" is a unique identification number assigned to a candidate by the Commonwealth Government or a Commonwealth Government Agency. Examples of identifiers include a Tax File Number (TFN) or a Medicare number. First Advantage does not use identifiers to identify a candidate's personal information in our systems.

OVERSEAS TRANSFERS OF PERSONAL INFORMATION

From time to time, we will need to transfer personal information overseas in order to liaise with the Sources, the Employer and/or our offshore related entities. We will transfer personal information overseas if:

  • we reasonably believe that the recipient of the information is subject to a law or a contract which effectively upholds the Australian Privacy Legislation;
  • the candidate has consented to the transfer;
  • the transfer is necessary for us to provide the Client with their requested service;
  • it is not practical to obtain a candidate's consent, the transfer is for the candidate's benefit and the candidate's consent would likely be given; or
  • we have taken reasonable steps to ensure that a candidate's personal information will not be held, used or disclosed by the recipient in a manner inconsistent with this Privacy Policy and the Privacy Act.

ACCESS AND CORRECTION OF INFORMATION

A candidate may apply to obtain details of their personal information which is held by us. A candidate may apply for that information by contacting the Privacy Officer at the contact details set out in this Privacy Policy. Please note that the Privacy Officer listed below handles requests from Australia and New Zealand.

We will handle requests for access to a candidate’s personal information in accordance with the Privacy Act. However, in some circumstances permitted under the Privacy Act we may not be required to give a candidate access to the information we hold about them.

It is also important to us that the information we hold about a candidate is accurate, complete and up to date. If a candidate becomes aware that this is not the case and would like to correct their personal information, they may lodge a correction request by contacting the Privacy Officer at the contact details listed in this Privacy Policy. First Advantage will make all reasonable efforts to correct the information.

Any complaints about a breach of privacy will be dealt with in accordance with our Privacy Policy. If a candidate has a complaint about the way First Advantage has dealt with their personal information, a candidate may contact our Privacy Officer at:

The Privacy Officer
First Advantage
PO Box R1783
Royal Exchange NSW 1225
Tel: + 61 2 9017 4300

If a candidate is unsatisfied with the outcome, they may refer the matter to the Privacy Commissioner at:

Australian Residents:
Website: www.privacy.gov.au
Tel: 1300 363 992

New Zealand Residents:
Website: www.privacy.org.nz
enquiries@privacy.org.nz
Tel: 0800 803 909, 04-474 7590 (Wellington), or 09-302-8680 (Auckland)

 

Japan Privacy Policy

http://www.fadv.com/global-presence/asia-pacific/japan/privacy-policy.aspx

- See more at: http://www.fadv.com/Privacy-Policy.aspx#sthash.e9t6rmxm.dpuf”