Overview

First Priority Screening, Inc. has established policies and procedures dedicated to maintaining the privacy of personal information while providing its clients with the necessary information for making informed decisions involving background screening. In most cases, our clients represent current and or potential employers engaged in pre- or post-employment background screening on individuals who have provided consent to have their personal information released and used for background screening purposes. Individuals can also use First Priority Screening to access their background information by submitting personal information directly. First Priority Screening does not differentiate between company clients and individual clients and this privacy policy applies to both Individuals provide personal information to First Priority Screening for this purpose. This policy incorporates the practices of First Priority Screening as they pertain to data submitted by clients via the First Priority Screening Website, and to other information secured from third p arties and other sources in connection with delivering background screening information or results to our clients. All data is collected, stored and delivered in compliance with applicable law, including the Fair Credit Reporting Act (FCRA), the European Union Data Protection Directive and other local, state, and federal laws. Personal information about an employee will only be released to the entity or entities to whom the employee consented to receive such information. This information will not be released to any other individual and will not be used for any other purpose by First Priority Screening.

First Priority Screening also extends its privacy policies and procedures to residents of the Member States of the European Union and other countries where data protection policies are in place, with regard to data provided by such residents as part of First Priority Screening delivery of background screening services. These policies and procedures apply to data submitted to First Priority Screening by its clients or the employees and or prospective employees of its clients residing in Member States of the European Union or other countries where data protection policies are in place and First Priority Screening has registered with the appropriate data protection authority.

First Priority Screening Is Safe Harbor Compliant

First Priority Screening is aware of and recognizes the role we must take in securing and maintaining the privacy of personal data received, stored and delivered to our clients. We recognize that we have obligations as a consumer reporting agency under the Department of Commerce’s Safe Harbor provisions. Our compliance policies and procedures with regard to domestic Federal and State regulations have set the standard for compliance in the international market, including the European Union Data Protection Directive.

Non-Personal Information

First Priority Screening sometimes collects and stores non-personal data submitted by individuals that are neither clients nor employees or prospective employees of clients and are inquiring about services provided by First Priority Screening (e.g. contact inquiry section). This data is collected for market analysis purposes.

Personal Information

Data submitted to or retrieved from the First Priority Screening Website is subject to the following policies, procedures and principles:

Security

First Priority Screening data is transferred utilizing secure socket layer (SSL) technology and is User ID and Password protected. Our servers reside in a secure environment protected from unauthorized access, natural disaster, fire or other compromising conditions. All processes take place at co-located facilities in separate regions of the United States, so even in the event of a regional disaster; your personal data remains secure.

Use of Information

First Priority Screening clients provide personal information regarding their employees or prospective employees via our Website (www.FirstPriorityScreening.com) when placing an order for background screening services. Information provided may include but is not limited to residential history, personal history including name, date of birth, Social Security Number, Motor Vehicle Operator’s License Number, Professional License information, employment history, education and other credentials. First Priority Screening will use information provided by the client and subject of the order, along with any other information provided by third-parties, only for the execution of producing a background screening report for the client placing the order, and for no other purpose While executing orders for our clients, First Priority Screening may transfer personal information between our Website, our client and our client’s employee or prospective employee. First Priority Screening acts in compliance with the European Union Data Protection Directive and is registered with Data Protection Authorities in countries in which it does business. First Priority Screening will not process personal information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual. We reserve the right to employ other organizations or individuals as our subcontractors, to perform functions on behalf of First Priority Screening. These organizations and individuals will not share information with any third party, other than First Priority Screening subcontractors or clients.

Confidentiality

First Priority Screening will maintain the confidentiality of all personal information and will under no circumstances sell or distribute personal information to a third party, except as provided in this Privacy Policy or when required to do so by law. This Privacy Policy will survive the transfer of ownership of First Priority Screening, should such an event occur.

Retention

Pursuant to the FCRA, we must maintain any reports which we generate for a minimum period of five years. Reports generated using data collected in or originating from a European Union Member State shall not be kept longer than necessary for the purpose of meeting our obligations to our client and the law.

First Priority Screening maintains written or electronic copies of information received in conjunction with services rendered for a period of five years. Information is subsequently destroyed either electronically or mechanically.

Choice

Employees or prospective employees of our clients will be advised by their employer or prospective employer that a background check will be conducted. U.S. residents that do not want personal data made available to our client (current or prospective employers), should not submit the information in question to First Priority Screening via our client. EU residents or those residing in other countries with data protection authorities may choose not to submit personal information to First Priority Screening. Consent forms either from First Priority Screening or a consumer’s employer indicate the consumer agrees to provide personally-identifying information, and consent to First Priority Screening's use of that information in accordance with this privacy policy. With regard to sensitive information, EU residents will be given an affirmative choice whether to disclose the information to a third party or if the information will be used for a purpose other than its original purpose or the purpose authorized subsequently by the individual.

Access

As the subject of a consumer report, a consumer has the right to any reports First Priority Screening produces and maintains on him or her once every twelve months for United States residents. Consumers may contact First Priority Screening via the contact information below to obtain a report including this information, if such a report has been created. In accordance with this policy and our efforts to maintain the privacy of personal data, First Priority Screening requires proof of a consumer’s identity prior to delivering any personal information. Information will be mailed via U.S. Postal Service within 7 days of a consumer’s request, in the same format it was delivered to a consumer’s current or future employer. There will be no expense to a consumer for this information. Requests should be mailed to First Priority Screening, Inc., PO Box 952, Newfields, NH 03856-0952 and include a photocopy of a government issued ID (driver’s license, passport, etc.). EU residents or residents of other countries in which First Priority Screening is registered with data protection authorities, may contact First Priority Screening to ascertain if personal data about you is in our possession. A fee of not more than $12 USD may be charged to cover the expense of delivering this information. Any information identified will be forwarded within 30 days via standard delivery methods. If a consumer believes any information in First Priority Screening's possession is incorrect, he or she should contact First Priority Screening directly to discuss this with the support representative identified below.

Changes

If it is determined in the future that information will be used in a new and material way, First Priority Screening will notify all active clients via email 30 days in advance of any changes. Additionally, a notice will be posted on the Home Page of all active accounts advising current and new users of the pending change.

Our Commitment To Children’s Privacy

Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our website from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.

BBB OnLine Privacy Program

Your privacy is important to us. By participating in the Council of Better Business Bureau’s BBBOnLine Privacy Program, we have made a commitment to meet the program’s strict requirements regarding how we treat your information and have it verified by BBBOnLine. Further information about this program is available at www.bbbonline.org All BBBOnLine Privacy Program participants are required to work with the program's dispute resolution process. The Privacy Program will only accept complaints regarding the misuse of personally identifiable information by a website operator. For more information about the Privacy Program dispute resolution process visit www.bbbonline.org/privacy/dr.asp

Enforcement

First Priority Screening verifies that this policy is Safe Harbor compliant by using a self-assessment approach. First Priority Screening hereby states that this policy is accurate, comprehensive, prominently displayed, completely implemented and accessible and conforms to the Safe Harbor Principles. EU consumers who feel that their privacy may have been violated based on the Safe Harbor privacy principles should contact either: First Priority Screening directly, its independent recourse mechanism, BBO Online; or the European Data Protection Authorities directly. First Priority Screening agrees to cooperate with the European Data Protection Authorities in the investigation and resolution of complaints as well as comply with its advice. First Priority Screening has procedures in place for training its employees in its implementation of the Safe Harbor policy and taking corrective action if it is not followed as well as internal procedures for periodically conducting objective reviews of compliance with the above.

Accuracy

First Priority Screening will make every reasonable effort to ensure the accuracy of information delivered. First Priority Screening relies on other entities, including but not limited to courts, educational institutions, individuals and other sources for its information, and therefore cannot guarantee the accuracy or timeliness of information reported. This Privacy Policy may be modified or amended at any time without prior notice. Please review this Privacy Policy prior to contacting First Priority Screening with requests or questions.

First Priority Screening Contact

Tel. 1 (888) 831-7778