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First Advantage

First Advantage Biometric Information Privacy and Record Retention Policy

Illinois Biometric Information Privacy Act, 740 ILCS Section 14/1 et seq.

First Advantage (hereafter the Company) has instituted the following biometric information privacy policy:

Biometric Data Defined:

As used in this policy, biometric data includes “biometric identifiers” and “biometric information” as defined in the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color. Biometric identifiers do not include information captured from a patient in a health care setting or information collected, used, or stored for health care treatment, payment, or operations under the federal Health Insurance Portability and Accountability Act of 1996.

“Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual. Biometric information does not include information derived from items or procedures excluded under the definition of biometric identifiers.

Purpose for Collection of Biometric Data:

The Company and its suppliers use biometric data solely for client candidate or employee identification and pre-employment or current screening FBI CJIS fingerprinting compliance purposes for our clients and Company candidates or First Advantage candidates or employees for which compliance with FBI CJIS fingerprinting is required.

Disclosure and Authorization:

To the extent that the Company or its suppliers capture, convert, store, share, or otherwise obtain biometric data relating to a candidate or employee, based on an individual’s biometric identifier relating to a client’s candidate or employee identification for pre-employment or current screening FBI CJIS fingerprinting compliance purposes for our clients and Company candidates or employees, the Company must first:

  1. Inform the candidate or employee in writing that the Company, its suppliers are collecting, capturing, or otherwise obtaining the employee’s biometric data, and that the Company is providing such biometric data to for internal First Advantage FBI CJIS Human Resource compliance purposes or its suppliers for candidate or employee FBI CJIS fingerprint background screening purposes;
  2. Inform the candidate or employee in writing of the specific purpose and length of time for which the employee’s biometric data is being collected, stored, and used; and
  3. Receive a written release signed by the candidate or employee (or his or her legally authorized representative) authorizing the Company and its suppliers to collect, store, and use the employee’s biometric data for the specific purposes disclosed by the Company, and for the Company to provide such biometric data to its suppliers.
  4. First Advantage, its suppliers, will not sell, lease, trade, or otherwise profit from employees’ biometric data; provided, however, that the Company’s suppliers time may be paid for products or services used by the Company that utilize such biometric data.


First Advantage will not disclose or disseminate any biometric data to anyone other than its suppliers of First Advantage’s providing fingerprint background screening products and services using biometric data without/unless:

  1. First obtaining written employee consent to such disclosure or dissemination;
  2. The disclosed data completes a financial transaction requested or authorized by the employee;
  3. Disclosure is required by state or federal law or municipal ordinance; or
  4. Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

Retention Schedule:

The Company shall retain employee biometric data only until, and shall request that its suppliers permanently destroy such data when, the first of the following occurs:

  • The initial purpose for collecting or obtaining such biometric data has been satisfied, such as the fingerprint background screening report has been received by First Advantage or its client or thirty days have passed pursuant to FBI CJIS Channeling requirements, the termination of the employee’s employment with the Company, or the employee moves to a role within the Company for which the biometric data is not used;
  • As contracted with the First Advantage Client or within 3 years of the candidate or employee’s last interaction with the Company.

Data Storage:

The Company shall use a reasonable standard of care to store, transmit and protect from disclosure any paper or electronic biometric data collected. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which the Company stores, transmits and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual or an individual’s account or property, such as names, fingerprints, employee identification numbers or social security numbers.

Contact Information:

If you have questions about this policy, or to request information relating to the First Advantage Biometric Information Privacy and Record Retention Policy, please contact:
First Advantage Corporation
Chief Global Compliance Officer

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