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, compliance management services, and related technology solutions that support our clients’ hiring and compliance programs.

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.

Universal collects consumer information for the purpose of generating Consumer Reports and/or Investigative Consumer Reports. 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 for Consumer Reports and/or Investigative Consumer Reports at the time the consumer completes a Background Check Notice, Acknowledgement and/or Authorization Form, each as applicable.

In addition, with the consumer’s authorization, Universal may securely retain certain personal and demographic information submitted during the background screening process to:

• Prepopulate forms and fields within the consumer’s profile when the individual returns to use our client or candidate portal, reducing the need to re-enter data; and

• Facilitate future background screening services requested by our clients involving the same consumer, including to verify identity, link historical records, and streamline the screening process.

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 for their information to be retained for future use, may exercise their data subject rights as provided for by applicable law and described below, and may choose not to complete the Background Check Notice, Acknowledgement and Authorization Form.

By completing the Background Check Notice, Acknowledgement and Authorization Form, the consumer expressly authorizes Universal to retain certain personal and demographic information provided during the background screening process for the limited purposes of: (i) prepopulating fields within the consumer’s portal account for future access, and (ii) facilitating future background screenings requested by our clients involving the same consumer.

This authorization is voluntary and may be revoked at any time by submitting a written request to Universal’s Privacy Office (see Contact Information below). Upon revocation or upon the consumer’s request for deletion, Universal will remove the consumer’s retained profile data, subject to any legal or regulatory obligations requiring continued retention or permitting Universal’s retention despite the request.

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 all sharing of their information should not provide their information to Universal and/or our Client or complete the Background Check Notice, Acknowledgement and Authorization Form. Consumers may have additional opt out rights as described below.

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; and
iii) in the event of an actual or contemplated transaction by which Universal or our assets are acquired by another company.

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, improper disclosure, and/or unintentional alteration or destruction.

Consumer information retained for the purpose of prepopulating user accounts or facilitating future screenings is stored separately from active screening case files, maintained in encrypted form, and accessible only to authorized personnel with a legitimate business need.

We will retain such consumer profile information for up to five (5) years from the date of last consumer activity, unless the consumer requests earlier deletion.

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.

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 as permitted by applicable law.

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.

Consumers who are California residents may exercise their rights under the California Consumer Privacy Act (CCPA/CPRA) to request access to, deletion of, or correction of their retained personal information by contacting Universal as described below.

Questions, comments, complaints or requests for assistance regarding the Company’s Consumer Information Privacy Policy or data collection and processing practices can be addressed to:

Universal Background Screening
Attn: Consumer Information Privacy Policy
7720 N 16th St, STE 450
Phoenix, AZ 85020

Email: privacy@universalbackground.com
Phone: 1-877-263-8033 or 602-337-3060