Consumer Information Privacy Policy
Introduction
Universal Background Screening (the “Company” or “Universal”) is a leading provider of background check solutions. We operate as a Consumer Reporting Agency (CRA) under the federal Fair Credit Reporting Act (FCRA) and as a licensed Private Investigator Agency located in the State of Arizona. Our services include criminal background checks, verifications, drug tests, physicals, and compliance management services.
Protecting consumer information is important to the Company. Universal (hereinafter collectively referred to as “we,” “us” or “our”) adheres to the federal Fair Credit Reporting Act (FCRA) and Drivers Privacy Protection Act (DPPA). When and where applicable, we also adhere to state laws related to consumer reports, consumer reporting agencies, credit reports, driver information and other personal information.
This Consumer Information Privacy Policy outlines our general policy and practices for protecting consumer information, including the collection and intended use of information, the sharing of information, and how the information is stored and destroyed. This policy applies to all consumer information received by the Company whether in electronic, paper or verbal format.
Purpose of Collection and Intended Use of Consumer Information
Universal collects consumer information for the purpose of generating a Consumer Report and/or an Investigative Consumer Report. A consumer is informed of the particular purpose for which Universal and/or our Client (the “end user” of a Consumer Report) collects and intends to use the information at the time the consumer completes a Background Check Notice, Acknowledgement and Authorization Form.
Information is collected for the purpose of conducting a background check for employment-related purposes, or for another purpose as authorized by the consumer. Individuals who wish to limit the use of their Personal Information, or who do not wish to be the subject of a Consumer Report and/or an Investigative Consumer Report, should not provide it to Universal and/or our Client, and should not complete the Background Check Notice, Acknowledgement and Authorization Form.
Sharing of Consumer Information
Universal does not sell or disclose consumer information to third parties for a purpose other than for which it was originally collected, except as stated within this policy. We limit the dissemination of consumer information to those with a legitimate business need and permissible purpose, or as otherwise authorized by the consumer. Consumers are hereby notified that their personal information may be disclosed to a third party in conjunction with an authorized background check. Consumers who wish to opt out from the sharing of their information should not provide their information to Universal and/or our Client, and should not complete the Background Check Notice, Acknowledgement and Authorization Form.
We may disclose consumer information: i) to our corporate affiliates or service providers as necessary or appropriate to provide the product or service requested by our Client; ii) to the extent necessary or appropriate to government agencies, advisors, and other third parties in order to comply with applicable laws or regulations, or if such action is necessary to protect the rights, property or legal claims of Universal, its affiliated companies, clients, individuals or the public; iii) in the event of an actual or contemplated transaction by which Universal or our assets are acquired by another company.
Information Storage and Disposal
Universal retains consumer information in a confidential manner. We take reasonable steps, including physical, electronic and operational measures, to protect the information from loss, misuse, unauthorized access, disclosure, alteration and/or destruction.
Part of our commitment to protecting consumer information is the proper disposal of the information to render it inaccessible, unreadable and/or unrecoverable. In compliance with current Federal Trade Commission guidelines, this may include (1) burning, pulverizing or shredding paper documents, (2) destroying or erasing electronic files and (3) utilizing the services of a reputable document destruction company.
Personal Information Disclosure: United States or Overseas
Universal Background Screening does not transfer personal information to third parties outside the United States or its territories, except in cases when such transfer is necessary to complete a criminal record check and/or employment, education, reference or professional license verification of information located outside of the United States or its territories. In such cases, only the minimal amount of information that is needed by the third party to complete that component of the background check is transmitted. When applicable, personal data is transmitted to third parties in accordance with EU & U.S. – Swiss Harbor Framework standards, as described in the Company’s Safe Harbor Privacy Policy.
Privacy Notice for California Residents
Preparation and Processing of Investigative Consumer Reports
Under California law, an “investigative consumer report” means a consumer report in which information on a consumer’s character, general reputation, personal characteristics, or mode of living is obtained through any means. The term does not include a consumer report or other compilation of information that is limited to specific factual information relating to a consumer’s credit record or manner of obtaining credit obtained directly from a creditor of the consumer or from a consumer reporting agency when that information was obtained directly from a potential or existing creditor of the consumer or from the consumer.
When preparing investigative consumer reports, Universal utilizes procedures and policies designed to comply with the Fair Credit Reporting Act (15 U.S.C. § 1681 et seq., as amended) and the California Investigative Consumer Reporting Agencies Act (Cal. Civ. Code § 1786 et seq.). Universal maintains a comprehensive written information security program which includes administrative, physical and technical safeguards that are designed to reasonably and appropriately protect the confidentiality, integrity and availability of confidential information.
Contact Information
Questions, comments, complaints or requests for assistance regarding the Company’s Consumer Information Policy or data collection and processing practices can be addressed to:
Universal Background Screening
Attn: Consumer Information Privacy Policy
Post Office Box 5920
Scottsdale, AZ 85261
Email: privacy@universalbackground.com
Phone: 1-877-263-8033 or 602-337-3060