First Advantage Privacy Vision
First Advantage is committed to the responsible use of information and protecting individual privacy rights. First Advantage strives to provide services to businesses, consumers, non-profit organizations and government agencies that help reduce fraud, mitigate risk, facilitate more informed decisions, and make society safer, in ways that protect consumer privacy. We aspire to protect consumer privacy through the design of our products, by credentialing, monitoring, and auditing our customers as appropriate, and through other information security safeguards. We also strive to promote transparency through consumer education initiatives, privacy principles and policies, and appropriate opportunities for consumer choice, access, and correction with respect to personal information about the consumer.
Data Privacy Principles
The First Advantage Data Privacy Principles speak to the personally identifiable information including sensitive personally identifiable information, collected, maintained, used or disseminated in connection with services offered by First Advantage, or by its affiliates (all hereinafter “First Advantage”).
First Advantage applies these Principles to our domestic U.S. products and services where appropriate. In addition, other uses or disclosures may occur as required by applicable law, such as the Fair Credit Reporting Act and its state analogues (“FCRA”), the Driver’s Privacy Protection Act and its state analogues (“DPPA”), and the Gramm Leach-Bliley Act (“GLB”). If the law requires or upon request of law enforcement, or, if necessary, to prevent fraud or to protect our computer systems, these principles may not apply. First Advantage also, from time to time, may revise our Data Privacy Principles by posting changes on its Web site.
Security
Data security is a company imperative. First Advantage strives to protect personally identifiable information that we maintain or disseminate, including using appropriate administrative, physical, and technical safeguards, so it is not obtained by unauthorized individuals or used impermissibly.
Distribution of Personally Identifiable Information
First Advantage seeks to limit the distribution of personally identifiable information consistent with the nature and sensitivity of the information. In its services, First Advantage also strives to make available personally identifiable information from sources other than public records or publicly available information only to its authorized users or customers. Similarly, where applicable, First Advantage strives to restrict access to information in accordance with privacy laws such as the FCRA, the GLB, and the DPPA and comparable state statutes. In the case of public record information available to the general public (such as bankruptcy, liens, judgments, criminal records and Uniform Commercial Code filings) and publicly available information (such as telephone directory information or personal information available through widely available media), we may make this information available to the general public unless applicable law operates to limit our distribution of such information to authorized users.
If, upon investigation, First Advantage finds that personally identifiable information has been used or accessed inappropriately or unlawfully, First Advantage strives to take reasonable steps to stop the misuse or access, educate the user concerning the appropriate use of the information, and prevent similar future misuses. Such steps may include measures up to and including discontinuation of the user’s access to First Advantage information products and services, pursuit of other legal remedies, and the referral of misuse to the appropriate authorities.
Accuracy
First Advantage strives to accurately report information in its products. First Advantage also strives to accurately report information that it receives from its data sources. First Advantage recognizes, however, that reporting errors may occur and offers consumers opportunities, where applicable, to dispute and correct information that we report as discussed further in Access and Correction.
Protection of Social Security Numbers and Driver’s License Numbers
First Advantage strives to provide additional safeguards for sensitive personally identifiable information, such as Social Security numbers and driver’s license numbers. First Advantage strives to limit the availability and access to full Social Security Numbers (“SSNs”), Driver’s License Numbers and State Identification Numbers. First Advantage strives to protect the confidentiality of SSNs by limiting access to SSNs to certain legitimate and authorized users, such as: state, local and federal government entities; financial institutions; insurers; employers; creditors; debt collectors and other user types to which First Advantage may decide to provide such access. A limited number of public records may contain SSNs that are already available to the public and, if such public records are accessed through First Advantage services, our services may provide access to such SSNs. First Advantage prohibits the unlawful disclosure of SSNs. First Advantage also takes steps to limit the availability of Driver’s License Numbers (“DLNs”) and state identification card numbers.
Education
First Advantage strives to inform its employees, users and the general public about appropriate use of First Advantage products and services. First Advantage strives to inform its users and employees about:
- Privacy and security issues associated with First Advantage information products and services; and
- The responsible use of personally identifiable information.
First Advantage strives to inform the public about:
- The responsible use of personally identifiable information; and
- Measures First Advantage has undertaken to enhance consumer privacy; and choices available to consumers regarding information access and the ability to opt-out of certain products and services which utilize personally identifiable information.
Reputable Sources
First Advantage strives to acquire personally identifiable information from established, reputable sources in the government and private sectors. In support of this Principle, First Advantage takes reasonable steps to assess the reputation and reliability of its private sector data sources before incorporating personally identifiable information from the source into its products and services. First Advantage also strives to obtain assurances from its data suppliers that they have the legal right to license or sell the data to First Advantage.
Notice
First Advantage strives to make its Data Privacy Principles publicly known. First Advantage publicly posts these Data Privacy Principles.
Security;
Distribution of Personally Identifiable Information;
Accuracy;
Protection of Social Security Numbers and Driver’s License Numbers;
Education;
Reputable Sources;
Notice;
Choice;
Access and Correction;
Accountability;
Online Privacy;
Identity Theft; and
Compliance
Choice
First Advantage strives to allow customers to opt-out of the dissemination of personally identifiable information from certain First Advantage owned databases used solely for marketing our services to which customers have previously opted in.
Access & Correction
First Advantage strives to provide consumers with a central point of contact regarding their questions about First Advantage and its commitment to the responsible use of personally identifiable information. First Advantage strives to inform individuals about the nature of the public records, non-public information, and publicly available information that First Advantage makes available in its information products and services. First Advantage also strives, whenever practicable, to provide consumers, upon request, with meaningful opportunities to review personally identifiable information we maintain about them. First Advantage also strives, as appropriate and practicable, to provide opportunities for consumers to dispute and correct information by assisting them in identifying the potential information sources at which corrections should be made. First Advantage strives to direct individuals to the government and private entities that collect and maintain public records and publicly available information to correct any claimed inaccuracies found in that data, and to direct individuals to consumer reporting agencies where such agency is the source of the information about the individual and where the individual seeks to correct claimed inaccuracies found in that data.
Accountability
First Advantage supports accountability of information industry standards and practices, responsible and effective federal regulation of the data industry, and legislation governing the practices of all data providers. First Advantage also supports industry oversight and active engagement with the privacy community. First Advantage believes that strong privacy and information security protections are vital for an effective and trusted data industry.
Online Privacy
First Advantage strives to protect the privacy of personally identifiable information obtained over the Internet and strives to apply our Data Privacy Principles and evolving standards to the online environment.
Identity Theft
First Advantage strives to prevent the acquisition of information from its products and services for improper purposes, such as identity theft. First Advantage believes that it is important that individuals who may have had their sensitive personally identifiable information acquired by an unauthorized individual be notified as follows: Where an applicable law requires notice, First Advantage complies with the law. Where notification laws do not exist, First Advantage follows its Information Security Breach Response and Notification Policy, which provides that affected individuals will be notified when sensitive personally identifiable information owned or licensed by First Advantage is acquired by an unauthorized individual and whenever First Advantage has a reasonable basis to believe the breach has resulted in, or there is a significant risk that it will result in, identity theft to the consumer to whom the information relates.
Compliance
First Advantage will obtain assessments from a qualified, objective, independent third party, who uses procedures and standards generally accepted in the profession to assess First Advantage’s administrative, technical, and physical safeguards, as appropriate.