Biometric Information Privacy Notice
The following notice applies the collection, use, and disclosure of biometric data via all First Advantage products and services subject to federal and state biometric privacy laws, including the Illinois Biometric Information Privacy Act, 740 ILCS Section 14/1 et seq.
This notice describes the biometric data handling practices of First Advantage and its subsidiaries, including STS SID LLC dba First Advantage Biometrics and First Advantage Infinite ID LLC dba PrintScan LLC, (hereafter the Company):
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. For example, a “Biometric identifier” is 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 for the purposes of providing background or identity services, including, without limitation: obtaining identity history reports from the Federal Bureau of Investigation (FBI) or other federal or state authorities, as requested by an employer or licensing body or a private individual, or what is permitted by federal, state or local law to receive FBI or state identity history reports for individual review, employment, identity or licensing purposes when applicable. We may also use this information as necessary to establish, exercise, or defend legal claims as permitted by applicable law.
Disclosure
First Advantage will not disclose or disseminate any biometric data to anyone other than the suppliers of First Advantage or the identified federal or state authorities providing fingerprint background screening products and services using biometric data without/unless:
- First obtaining written consent to such disclosure or dissemination;
- The disclosed data completes a financial transaction requested or authorized by the individual;
- Disclosure is required by state or federal law or municipal ordinance; or
- Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.
Company, its suppliers, will not sell, lease, trade, or otherwise profit from individual’s’ biometric data; provided, however, that the Company’s suppliers time may be paid for products or services used by the Company and the individual that utilize such biometric data.
Retention Schedule
The Company shall retain Individual’s 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 when 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 a Company client or individual, or within 3 years of the candidate or employee’s last interaction with the Company.
Data Storage
The Company shall use the standards prescribed by the FBI and/or other governing federal or state authorities for safeguarding biometrics. If the federal or state authority does not provide a standard, the Company shall use 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 Biometric Information Privacy Notice, please contact:
First Advantage Corporation
Email: FADVLegal@fadv.com