Prospective, Current, and Previous Employee Data Privacy Notice

Introduction

This Privacy Notice for Prospective, Current, and Previous Employees (“Workers” and “Notice”) applies to all individuals that reside in states or countries with a data privacy laws granting the type of rights described below.

Information We Collect

We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Worker or device (“Personal Information“). In particular, we may have collected the following categories of Personal Information from those Workers who are subject to this Notice within the last twelve (12) months:

Categories of Personal Information Which May be Collected

Identifiers and Demographic Data

This includes data like name, address, email, marital status, birth date, gender, educational data, etc.

Sensitive Data

This includes data like financial account numbers, SSN, medical data, biometric data, performance reviews, etc.

Transactional Data

This includes data you may share with us when you are acting in your capacity as a consumer instead of an employee. For example, when you buy our products or services.

Biometric Information

This includes information like ID badge photos, fingerprints used with time keeping systems, or security camera video footage of you.

Internet or Other similar network activity

You use First Advantage systems every day for your work. All the activity you have on these systems, from email to web browsing, is collected and used. This includes log-in details, software application usage, VoIP phone usage, and file share access.

Geolocation data

This can include location data we may collect as part of your use of a First Advantage issued smart phone, or GPS data collected when you use one of our fleet vehicles.

Sensory data

This is data which may or may not be related to you directly, as it is usually data coming from devices like security motion detectors or similar devices, as well as easily observable physiological information such as face or body temperature. However, if it is tied to other data, like key card access logs, it can become personal information.

Professional or employment-related information

This is all the data related to your employment with First Advantage, including but not limited to Personal Information related to individuals who receive benefits from First Advantage as a result of your status as a Worker with First Advantage. For example, it can include “right to work” documents, payroll and benefits data, medical leave data, or other kinds of information necessary for First Advantage to acquire, manage, and retain talent in its workforce.

Non-public education information

This is information related to your academic credentials such as what school you went to, what your GPA was, what activities or sports you did in school, or other data on your school transcripts.

Inferences First Advantage makes based on Personal Information

This includes information in performance reviews, any testing you may have undertaken, information related to succession planning, as well as predictive analytics related to your use of First Employer IT systems and networks.

Personal Information does not include:

Publicly available information from government records.
Deidentified or aggregated information.
Information excluded from the scope of respective data privacy laws

First Advantage obtains the categories of Personal Information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase (if any).
Indirectly from you. For example, from observing your actions as a Worker, from records of your use of First Advantage information technology, or from location-tracking enabled devices connected to First Advantage assets you may use as part of your regular employment related activities with First Advantage.
From independent third parties related to your eligibility for employment, or our ongoing management of our business.
Other Workers, as part of First Advantage’s management, evaluation, training, and discipline processes

Use of Personal Information

We may process or disclose the Personal Information we collect for one or more of the following business purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to apply for a job at First Advantage, or, request vacation time, or, in order to administer benefits, or to process payroll.
To provide, support, personalize, and develop our Worker population.
To managing the health and welfare risks (e.g. pandemic management) to our Workers, our clients, and the population generally
To provide you with support and to respond to your inquiries.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your Personal Information.
Disclosures made in an effort to prevent or halt violations of First Advantage policies, illegal activities, or as required by law.
Disclosures that we reasonably believe are necessary to defend against or prevent us from incurring liability to third parties.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

First Advantage is part of an international group of companies where certain services are provided centralized by one or more affiliates for the entire group or a part of it. We, therefore, reserve the right to share personal information with our direct and indirect affiliates for all purposes described above. Whenever we share Personal Data with affiliates, we request from them that they commit themselves to process Personal Data in line with this Notice only.

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. These third parties are “Service Providers” as defined by applicable law. We do not share Personal Information with any third parties, who are not Service Providers, where First Advantage may receive a financial benefit from such sharing.

We may also disclose your Personal Information to another company as part of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets to that company; or where required by First Advantage policy, law, or in response to valid legal process compelling disclosure.

Disclosures of Personal Information

In the preceding twelve (12) months, First Advantage has disclosed all of the categories of Personal Information as noted above, for the business purposes described above; and/or,

We disclose your Personal Information for a business purpose only to Service Providers, or, where required by law, or in response to valid legal process compelling disclosure.

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold Personal Information. The Company does not and will not sell Personal Information of Workers. Nor do we share Personal Information for the purposes of cross-contextual behavioral advertising.

Changes to Our Privacy Notice

First Advantage reserves the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on First Advantage’s website. We may also distribute the updated Notice in the manner we usually distribute other legally required notices.

Contact Information

If you have any questions or comments about this notice, the ways in which First Advantage collects and uses your information, please do not hesitate to contact either your HR representative or the First Advantage Legal Department. Under state level or country data privacy laws, you may have certain Data Subject Rights that you can exercise. For more information, see below:

Data Subject Rights Requests

Most privacy laws provide you a mechanism through which you can exercise certain rights (similar to those exercised in the United States under the FCRA, such as disputes and full-file disclosures) that empowers and enables you to check what personal data relating to you is being held and what is being done with it.

You may be entitled to exercise these rights available to you depending on the privacy laws in your country or state of residence.

Such rights relate to access, correction of your personal data and such other rights that may vary in different jurisdictions.

Types of Data Subject Requests

Right to be informed: A right to know how your personal data is being used. First Advantage will provide information and communicate to you in a clear, concise, and easily accessible form about the collection and processing of your personal data.
- Please refer to the First Advantage Global Privacy Center index at https://fadv.com/privacy-center/ where detailed information is available for each region for U.S. residents and Non-U.S. residents. You may refer to the applicable policy depending on the country of residence.
Right of Access: You may have the right to request details of your information that we hold including.:
- how your personal data is processed;
- categories of data collected;
- purpose of the processing;
- whom this data is disclosed to;
- duration of retention; and
- source from which the information was obtained if collected from a third party.
Right to Rectification: You may have the right to update your data and complete the incomplete data or correct any incorrect information held by us.
Right to be forgotten/Right of deletion: If provided for under local law, you may have the right to have your data deleted. This right is also called as right to be forgotten. You can request First Advantage to remove your personal data as governed by applicable law.
Right to Restrict processing: Right to mark your record to restrict any processing outside of what is legally or contractually required. In certain circumstances and if provided under local law, you may be enabled with a right to limit the processing of your personal data by FA.
Right to Data portability: If provided under local law, you can also request to move your personal data to another service provider.
Right to object to data processing activities: If provided under local law, you may request Data Controllers or Data Processors to stop using your data for marketing or other purposes unless they can provide a legitimate need for that processing.

How do we process your Requests?

When you submit a request to exercise your rights, it is routed to First Advantage’s compliance team via the regional email addresses (correlating with the region of your residence) listed below:

*Australia, New Zealand, Malaysia, Thailand, Indonesia, Brunei Darussalam, Cambodia, French Polynesia

**Bangladesh, China, India, Japan, Pakistan, Philippines, S. Korea, Singapore, Sri Lanka, Hong Kong, Taiwan, Vietnam, Bhutan, British Indian Ocean Territory, Kazakhstan, Macau, Mongolia, Nepal