Overview
Screenpointe, 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 employment screening and background investigations. In most cases, our clients represent employers engaged in acquiring pre- or post-employment background reports on individuals who have provided consent to have their personal information released and used for employment purposes. This policy incorporates the practices of Screenpointe as they pertain to data submitted by applicants, clients, and other providers secured from third parties 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, and other local, state, and federal laws. Personal information about an applicant/employee will only be released to the entity or entities to whom the applicant/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 Screenpointe.

Choice

Employees or prospective employees of our clients will be advised by their employer or prospective employer that a background check will be conducted. Those that do not want personal data made available to our client (current or prospective employers) should not submit the information in question to Screenpointe via our client.

Use of Information
Screenpointe’s clients provide personal information regarding their employees or prospective employees when placing an order for background screening services. Information provided may include but is not limited to name, residential history, date of birth, social security number, employment history, education history, professional license information and other credentials, personal or professional reference contact information, and motor vehicle operator’s license number. Screenpointe 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, Screenpointe may transfer personal information between our website, our client and our client’s employee or prospective employee. Screenpointe 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 Screenpointe. These organizations and individuals will not share information with any third party, other than Screenpointe’s subcontractors or clients.

Our Commitment To Children’s Privacy
Protecting the privacy of children is especially important. For that reason, we never collect or maintain information at our website from those we actually know are under 16, and no part of our website is structured to attract anyone under 16.

Non-Personal Information
Screenpointe 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 Screenpointe (e.g. contact inquiry section). This data is collected for market analysis purposes.

Personal Information
Data submitted to or retrieved from Screenpointe is subject to the following policies, procedures and principles:
Confidentiality
Screenpointe 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 Screenpointe, Inc., should such an event occur.

Security
Screenpointe’s data is transferred utilizing secure socket layer (SSL) technology and is User ID and Password protected. For each order that is placed, we store the IP address which the order originates from. The login activity and IP address is logged with each login attempt. Sensitive information such as social security numbers and date of births are obscured on all reports that are accessible via the Internet. The network is protected by a firewall system and the operating system is audited on a regular basis to ensure the latest security patches are installed. Our servers are password protected and 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.

Retention

Pursuant to the FCRA, we must maintain any reports that we generate for a minimum period of five years. Screenpointe maintains written or electronic copies of information received in conjunction with services rendered for a period of seven years in a secure facility which is electronically and physically monitored 24/7/365. Information is subsequently destroyed by means of erasing and destroying electronic files, and pulverizing and shredding written or hard copy materials.

Access
As the subject of a consumer report, a consumer has the right to any reports Screenpointe produces and maintains on him or her once every twelve months. Consumers may contact Screenpointe 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, Screenpointe 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 Screenpointe, Attn: Applicant Services, 515 Executive Campus Drive, Suite 160, Westerville, Ohio 43082 and include a photocopy of a government issued ID (driver’s license, passport, etc.).

Accuracy
Screenpointe will make every reasonable effort to ensure the accuracy of information delivered. Screenpointe 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. If a consumer believes any information in Screenpointe’s possession is incorrect, he or she should contact Screenpointe directly to discuss this, or mail a letter of dispute outlining any inaccuracies to Screenpointe, Attn: Applicant Services, 515 Executive Campus Drive, Suite 160, Westerville, Ohio 43082 and include a photocopy of a government issued ID (driver’s license, passport, etc.)

Enforcement
Screenpointe verifies that this policy is Safe Harbor compliant by using a self-assessment approach. Screenpointe hereby states that this policy is accurate, comprehensive, prominently displayed, completely implemented and accessible and conforms to the Safe Harbor Principles. Screenpointe 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.

Changes
If it is determined in the future that information will be used in a new and material way, Screenpointe 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.

This Privacy Policy may be modified or amended at any time without prior notice. If you have questions or comments about this Privacy Policy, please send an email to info@screenpointe.com or in writing to: Screenpointe, Attn: Compliance Department, Screenpointe, 515 Executive Campus Drive, Suite 160, Westerville, Ohio 43082.