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SmartStart's Privacy Statement

 

Privacy Policy

As a consumer reporting agency governed by the federal Fair Credit Reporting Act (“FCRA”) among other applicable state and federal laws, SmartStart Employment Screening, Inc. (“SmartStart”) is committed to protecting your privacy.

This Privacy Policy covers SmartStart's web site, and SmartStart's practices for handling personal information provided to SmartStart over the Internet by the general public using SmartStart's publicly available web site. This Policy also covers personal information provided by SmartStart's clients, and their job applicants and employees (as well as other individuals who have given their written authorization for SmartStart's clients to conduct a background investigation on them), using SmartStart's online background screening solution that is accessible only through an access-restricted portion of SmartStart's web site. SmartStart will collect, store, and use personally identifiable information only in compliance with applicable laws, including the FCRA.


Collection of Information


When you browse SmartStart's publicly accessible web site, you do so anonymously. SmartStart collects personally identifiable information from you only if you choose to provide this information to us. In some instances, SmartStart may collect non-personal (e.g., aggregate or demographic) data through cookies. This information is used to better understand and improve the usability, performance and effectiveness of the SmartStart.com web site, as is further described below under "Cookies and Tracking Technology".


The types of personal information we may collect about you through our publicly accessible web site include the following (should you decide to provide such information to SmartStart): (a) contact and identifying information (e.g., name, address, e-mail address, phone and fax numbers, employer(s), job title) in connection with your expression of interest in receiving information about, or your registering for, SmartStart products or services, newsletters and conferences; (b) your resume information and employment application information in response to SmartStart job openings; and (c) any other personal information that you may voluntarily provide to us in an online form or through an e-mail.


Access to certain SmartStart web pages and online services is not available to the general public and requires a login code and password provided by SmartStart. Those web pages, and the information downloadable to and from those pages, are made available only to clients of SmartStart. On these web pages, SmartStart collects only information that the user voluntarily shares with SmartStart.


If you are using this web site to open an employment screening account with SmartStart, we collect the information requested on our account application form, including contact information and financial information (such as credit card number or billing information). This information is used for internal purposes, such as account establishment, billing, fulfillment of orders and customer service.


How We Use Your Personal Information


When your personal information is collected on SmartStart's publicly accessible web site, SmartStart will inform you at the point of collection of the purpose for the collection. SmartStart will use your personal information only in the way we specify when it is collected, unless you consent to a different use.


For example, SmartStart may use personal information submitted in an account application to set up and maintain your account. SmartStart also may use the personal information you provide to answer your questions and inquiries, to support SmartStart's own recruitment activities in response to your inquiries into SmartStart's job postings and to provide newsletters and other information (if any) that you have requested.


If you have provided your personal information over this web site in connection with a background screen ordered by SmartStart's client - SmartStart may use your personal information to perform your background screen for that client. SmartStart will not use your information to conduct a background screening investigation and create a report unless SmartStart's client has provided a certification required by the FCRA and any other applicable law.  In this certification, SmartStart's client certifies to SmartStart that it has a legally permissible purpose for ordering the background screen, and that it has, to the extent required by applicable law, obtained your informed consent to conduct the background screen.


Information Sharing and Disclosure


SmartStart does not sell or rent personal information to third parties. SmartStart will not disclose your personal information to a third party without your permission, except in connection with performing your background screen for SmartStart's client or as otherwise described in this Privacy Policy.


SmartStart may disclose personal information as necessary or appropriate in connection with any of the purposes for which we use personal information as described above in "How We Use Your Personal Information".

When SmartStart conducts a background screening investigation about you, SmartStart may disclose information that you submit through this web site to the SmartStart client that ordered a background screening investigation on you. SmartStart also may disclose your information to certain third parties as necessary to conduct the background investigation (such as educational institutions, prior employers, courts, law enforcement agencies and other persons or entities that may provide or verify information about you), as well as to a third-party representative or subcontractor authorized by SmartStart to assist in the background screening investigation. These third party representatives and subcontractors include service providers that help host or support the web site or otherwise provide technical assistance, court researchers and other data and service vendors. SmartStart transfers to these representatives and subcontractors only the personal information they need to deliver to SmartStart (for the benefit of SmartStart's client) the requested product or service. SmartStart prohibits these third parties from using that information for any other purpose. SmartStart requires that these parties maintain commercially reasonable measures to protect the confidentiality of your information.


SmartStart also may in good faith disclose personal information and any other additional information available to SmartStart for any of the following purposes: (i) investigate, prevent or take action regarding actual or suspected illegal activities or fraud, situations involving potential threats to the physical safety of any person, or violations of SmartStart's terms of use; (ii) respond to or defend against subpoenas, court orders, or other legal process; (iii) establish or exercise SmartStart's legal rights; or (iv) otherwise comply with applicable law.


SmartStart may acquire other businesses, and other businesses may acquire SmartStart. If that occurs, the information SmartStart collects may be one of the assets examined or transferred as part of the transaction. SmartStart will not permit another business to examine the information SmartStart has collected without a confidentiality agreement and only to the extent permitted by law. SmartStart will not transfer the information it has collected unless the recipient agrees to provide privacy protections equal to or exceeding those established by this Privacy Policy.


Cookies and Tracking Technology


SmartStart's web site may use the standard technology called a "cookie" to collect information about how you use the web site.


A cookie is a small data file that is transferred to your hard drive and used for record-keeping purposes. A cookie file can contain information such as the URL you came from, your computer's IP address (i.e., the Internet address of your computer) and domain type (e.g., .com or .org, etc.), your browser type, the country, state and telephone area code where your server is located, the pages of our site that were viewed during a visit, and any search terms that you entered on our site. This information is used for internal purposes only, and we do not link your URL or IP address to any personal information unless you have logged into our web site with a SmartStart account login and password.


If you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies, although it is possible that some areas of our web site will not function properly if you do so. In particular, you may be required to accept cookies in order to complete certain actions on SmartStart's web site.


Security


SmartStart is committed to protecting the personal information that SmartStart receives about consumers. While we cannot guarantee the security of that information, we take reasonable and appropriate measures to do so.  We utilize a combination of online and offline security technologies, procedures and organizational measures to help safeguard consumer information against loss, misuse, and unauthorized access, disclosure, alteration and destruction.


We employ Secure Socket Layer (SSL) data encryption when data is transmitted over the Internet to our web site. We have installed layered firewalls and other security technologies to help prevent unauthorized access to our systems. Strong password protection protocols are used on our computers, and employees are kept up-to-date on our security and privacy policies. The servers used to store consumer information are maintained in a secure environment with appropriate security measures.


Links


SmartStart's web site may provide links to third-party web sites. Please be aware that those third-party web sites are outside of our control and are not covered by this Privacy Policy. If you have questions about how another site uses your information, consult that site's privacy statement.


Your Ability to Review or Modify Personal Information, or Unsubscribe.


SmartStart strives to protect the quality and integrity of your personal information. If you have provided your personal information (such as zip code, phone, e-mail or postal address) to SmartStart while browsing SmartStart's publicly accessible web site, and wish to update such personal information (if any) that you have provided us, please e-mail us at service@ssesi.com. Also, if you wish to unsubscribe from any of our newsletters or other communications for which you have registered, you may e-mail us at service@ssesi.com. If you are a SmartStart client with a registered account, you may review (and update) your account information by logging into your account. If you are an individual on whom a SmartStart client has requested a background screening investigation, and have submitted personal information to SmartStart at the request of such client for purposes of procuring a background report, then you can review your SmartStart file in accordance with your file disclosure rights under the Fair Credit Reporting Act, California Civil Code Section 1786.22 and any other applicable state laws by contacting SmartStart's Customer Service Department at service@ssesi.com. You can review a summary of your consumer rights (including file disclosure rights) under the Fair Credit Reporting Act by accessing: http://www.ftc.gov/os/2004/11/041119factaappf.pdf.


Children Under Age 13


SmartStart does not offer services to children under the age of 13, and this web site is not directed to children under the age of 13. SmartStart does not knowingly collect information about children under the age of 13.


Personal Information Disclosure: United States or Overseas

Personal information submitted to SmartStart for a background screening investigation may at times be transferred outside of the United States in order to perform the background investigation. All personal information will be transmitted and stored in a secure manner in accordance with all applicable laws and the terms of this Privacy Policy.


Privacy Notice - Preparation and Processing of Investigative Consumer Reports  


This notice is provided to California residents. Under California law, an "investigative consumer report" is a consumer report containing information on a consumer's character, general reputation, personal characteristics, or mode of living. SmartStart compiles investigative consumer reports about individuals and provides them to business for background screening, tenant screening, and similar purposes.  


To obtain additional information about the privacy practices and policies of SmartStart in connection with its preparation and processing of investigative consumer reports, please contact: 


SmartStart Employment Screening, Inc.
Yohama "Joey" Guarino
Chief Compliance Officer/General Counsel/EVP of Human Resources
SmartStart Employment Screening Inc.
Phone: (813) 377-4343
Compliance@ssesi.com


For additional information about privacy or consumer reporting, visit the following web sites: 


Federal Trade Commission: www.ftc.gov 
Consumer Financial Protection Bureau: http://www.consumerfinance.gov/
Consumer Data Industry Association: www.cdiaonline.org 
Experian: www.experian.com/consumer/credit_education.html
Equifax: https://www.econsumer.equifax.com/consumer/landing.ehtml?^start=&companyName=PSHP1_hpg
TransUnion: http://www.transunion.com/corporate/personal/personal.page
California Office of Privacy Protection: www.privacy.ca.go


Changes to this Privacy Policy


SmartStart may revise this policy from time to time. If there is a material change to this Privacy Policy, we will post the revised policy at this location. SmartStart will not provide less privacy protection, without your consent, to information collected under a prior privacy policy. We encourage you to periodically review this Privacy Policy to be informed of how SmartStart is protecting your information.


If you have any questions regarding our privacy policy, you may contact us at:


SmartStart Employment Screening Inc.
Attn: Compliance Dept
29399 US 19 N - Ste 350  
Clearwater, FL 33761
compliance@ssesi.com


In accordance with California Civil Code § 1786.20, the representative named above will be able to assist you with additional information regarding our privacy practices and policies in the event of a compromise of your information.


EU-US Privacy Shield Privacy Policy


SmartStart Employment Screening, Inc. (“SmartStart”) receives certain personal information pertaining to an identified or identifiable individual or other personal information acquired by SmartStart pursuant to the performance of services at the request of clients for credential verification and employment screening purposes.  This EU-US Privacy Shield Policy applies to such personal information about an individual that is received by SmartStart from the European Union.  


Participation in the EU-US Privacy Shield


SmartStart Employment Screening, Inc. complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  SmartStart has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/


Smart Start has joined the EU Privacy Shield Program and complies with the EU – US Privacy Shield Principles as it relates to the collection, use and retention of personal information from European Union member countries.  SmartStart adheres to each of the Privacy Shield Principles with respect data received from the EU in reliance of the Privacy Shield: Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability as explained below.  


Notice


SmartStart collects and maintains data on individuals which it provides to its clients, employers or their agents, such as recruiters and staffing firms, for use in making employment-related decisions.  SmartStart informs you when it collects personal information about you including the purposes for which it collects and uses such personal information, how to contact SmartStart with any inquiries or complaints, the types of third parties to which it discloses the information and the choices and means offered to you for limiting its use and disclosure. Notice is provided in clear and conspicuous language either when you are first asked to provide personal information, or as soon thereafter, as is practicable, but in any event before SmartStart uses your personal information for a purpose other than that for which it was originally collected or processed and before it discloses it for the first time to a third party (other than to its agents). Information about how personal information is collected is below.  


The types of personal information and data that SmartStart Employment Screening collects pursuant to the EU-US Privacy Shield includes contact and identifying information such as name, date of birth, address, e-mail address, phone and fax numbers, employment history, job title(s), educational data, government-issued identification number, medical information, data relating to conviction(s) or commission of an offense(s), places of your residence, credit history and driving record.   


Choice


Your personal information and data will be collected and used by SmartStart only with your prior written authorization for purposes of performing a background screen for SmartStart’s client.  If you provide your personal information to us on this web site in connection with a background screen ordered by SmartStart’s client and have provided written authorization for SmartStart’s client to conduct a background, you consent to the collection of your personal information and to your personal information being disclosed to a third party, solely as specifically provided in this Privacy Policy and for the purpose(s) for which it was authorized by you.  If you do not want SmartStart to collect personal information about you, you can prevent the collection of your personal information by refusing to provide authorization when requested by SmartStart’s client in accordance with the Fair Credit Reporting Act or, if required, by other applicable law. 


If at any time after providing authorization for the collection and disclosure of your personal information, you wish to revoke the authorization provided.  You may do so in writing by sending notice of revocation to SmartStart's Customer Service Department at service@ssesi.com.  Your revocation does not signify that SmartStart will delete, erase or otherwise destroy the personal information it collected prior to the receipt of your notice of revocation, as applicable laws and compliance obligations require SmartStart to retain your file and information for a specified period of time.  However, SmartStart will no collect or disclose your personal information after it receives your written notice of revocation.  


SmartStart will give you the choice to opt out before it discloses personal information to a third party (not our agent) not authorized by you or uses personal information for any other purpose than that authorized by you or for purposes not compatible with the purposes for which it was collected and authorized by you.  However, if the personal information is considered “sensitive information” as defined in the Privacy Principles such as personal information specifying “medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual”, SmartStart will obtain your affirmative express consent to opt in, if such information is to be disclosed to a non-agent third party not authorized by you or used for a purpose other than those for which it was originally collected or subsequently authorized by you.


Onward Transfers (Transfer to Third Parties)


SmartStart may disclose your personal information it collects or receives through this web site (pursuant to the EU-US Privacy Shield) to the clients (including its authorized representatives) of SmartStart that ordered a background screening investigation on you.  It may also disclose your personal information to certain third parties as necessary to conduct the background investigation, such as educational institutions, prior employers, courts of law, law enforcement agencies and other persons or entities that may provide or verify information about you, as well as to a third-party representative or subcontractors authorized by SmartStart to assist in the background screening investigation. These third party representatives and subcontractors include service providers that help host or support the web site or otherwise provide technical assistance, court researchers and other data and service vendors.


SmartStart transfers to these representatives and subcontractors only the minimal personal information they need to deliver to SmartStart (for the benefit of SmartStart's client) the requested product or service.  SmartStart contracts with these third parties and prohibits them from using the information for any purpose other than the limited and specific purposes consistent with the consent provided by you and requires that they provide the same level of protection as the Privacy Shield Principles.  SmartStart will not disclose personal information unless these third parties maintain commercially reasonable measures to ensure the confidentiality, integrity and security of such information.


SmarStart’s may be required to in good faith disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements; to investigate, prevent or take action regarding actual or suspected illegal activities or fraud situations involving violations of SmartStart's terms of use; and to respond to or defend against subpoenas, court orders, or other legal process. Notwithstanding, any non-compliance with the Privacy Shield Principles will be limited to the extent necessary to meet the overriding legitimate interests furthered by such requests.


SmartStart may acquire other businesses, and other businesses may acquire SmartStart. If that occurs, the information SmartStart collects may be one of the assets examined or transferred as part of a transaction. SmartStart will not permit another business to examine the information SmartStart has collected without a confidentiality agreement and only to the extent permitted by law. SmartStart will not transfer the information it has collected unless the recipient agrees to provide privacy protections equal to or exceeding those established by the Privacy Shield Principles.


SmartStart is responsible for processing personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf.  In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, SmartStart is potentially liable.


Security


SmartStart is committed to protecting the personal information that SmartStart receives from the EU about you. While we cannot absolutely guarantee the security of that information, we take reasonable and appropriate measures to do so.  We utilize a combination of online and offline security technologies, procedures and organizational measures to help safeguard consumer information against misuse, loss, unauthorized access, disclosure, alteration and destruction.


We employ Secure Socket Layer (SSL) data encryption when data is transmitted over the Internet to our web site. We have installed layered firewalls and other security technologies to help prevent unauthorized access to our systems. Strong password protection protocols are used on our computers, and employees are educated on our security and privacy policies. The servers used to store consumer information are maintained in a secure environment with appropriate security measures.


Data Integrity and Purpose Limitation

SmartStart collects personal information from the EU and data that is relevant for the purposes for which it is to be used, consistent with the Privacy Shield Principles.  We process personal information in ways that are compatible with the purposes for which it has been collected (as provided in the Notice section) or subsequently authorized by you.  To the extent necessary for those purposes, SmartStart takes reasonable steps to ensure that EU personal information collected is accurate, complete, current, and reliable for its intended use. 


Access

You have the right to access, view, review and receive a copy of the personal information you have submitted to SmartStart, at the request of SmartStart’s client for purposes of procuring a background report, and the information SmartStart has collected and holds in your file in accordance with your file disclosure rights under the Fair Credit Reporting Act by contacting SmartStart's Customer Service Department at service@ssesi.com.  You have the right to request that SmartStart correct, amend, or delete the information, where it is inaccurate or has been processed in violation of the Principles, by contacting SmartStart’s Customer Service Department at service@ssesi.com.  You will be required to provide sufficient evidence of your identity to prevent the information from being released to the proper individual.  


Enforcement

In compliance with the EU-US Privacy Shield Principles, SmartStart commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union individuals with inquiries or complaints regarding this privacy policy should first contact SmartStart at:  

SmartStart Employment Screening
Compliance Dept.
29399 US 19 N – Suite 350
Clearwater, FL 33761
compliance@ssesi.com
813.377.4343


SmartStart has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

SmartStart is subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”).  SmartStart’s commitment to comply with the Privacy Shield Principles is enforceable by the FTC.

Under certain limited circumstances, (to determine unresolved claims) individuals may invoke as a “last resort” binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and European Commission.  

For Human Resource data, SmartStart will cooperate in investigations with the EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.


US-Swiss Safe Harbor


and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. SmartStart has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the Safe Harbor program, and to view SmartStart Employment Screening’s certification, please visit http://www.export.gov/safeharbor/

In compliance with the US-Swiss Safe Harbor Principles, SmartStart commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss citizens with inquiries or complaints regarding this privacy policy should first contact SmartStart Employment Screening at:


SmartStart Employment Screening
Compliance Dept.
29399 US 19 N – Suite 350
Clearwater, FL 33761
compliance@ssesi.com
813.377.4343

SmartStart has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.



Revised: August 30, 2016


 

 

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