Global Verification Network Safe Harbor Privacy Policy

About Global Verification Network

Global Verification Network LLC (“Global Verification Network”) is a national provider of screening solutions. Our services include pre-employment and course of employment background checks, verifications, due diligence services, drug tests, occupational health testing, and screening program compliance management services.

Protecting consumer privacy is paramount to Global Verification Network. Global Verification Network (hereinafter collectively referred to as “Global Verification Network,” “we,” “us” or “our”) adheres to the Safe Harbor Agreement concerning the transfer of personal data from the European Union (“EU”) to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the “Safe Harbor Principles” or “Principles”) with respect to all such data. If there is any conflict between the policies in this privacy policy and the Safe Harbor Principles, the Principles shall govern.

This Safe Harbor Privacy Policy outlines Global Verification Network’s general policy and practices for implementing the Safe Harbor Principles, including the types of information we gather, its utilization and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all personal information received by Global Verification Network whether in electronic, paper or verbal format.

Statement of Certification to the U.S.-E.U. Safe Harbor and U.S.-Swiss Safe Harbor Frameworks

Global Verification Network complies with the U.S.-EU Safe Harbor Framework 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 European Union member countries and Switzerland. Global Verification Network has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Global Verification Network’s certification, please visit http://www.export.gov/safeharbor/

1. Notice

Individuals are informed of the purpose for which Global Verification Network and/or our Client (an individual’s current or prospective employer) collects and uses the individual’s Personal Information at the time they complete a Global Verification Network Disclosure & Consent form. Global Verification Network does not provide or disclose such information to third parties, other than its authorized agents, nor does it use or disclose the Information for a purpose other than for which it was originally collected. Individuals who wish to limit the use and disclosure of their Personal Information should not provide it to Global Verification Network and/or our Client, and should not complete the Disclosure & Consent Form.

2. Choice

Based on the nature of the services provided by Global Verification Network, certain Personal Information may be disclosed to our agents as part of the background check process, and to our clients in the form of a completed background check report. Individuals who wish to opt out from disclosure of their Personal Information to third parties should not provide it to Global Verification Network and/or our Client, and should not complete the Disclosure & Consent form. Global Verification Network does not provide or disclose such Information to any third parties, other than its authorized agents, nor do we use or disclose the Information for a purpose other than for which it was originally collected. Global Verification Network treats Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.

3. Onward Transfer to Third Parties

Individuals are hereby notified that their Personal Information may be disclosed to a third party, in conjunction with a background check duly authorized by the individual. Individuals who wish to opt out from any such transfers should not provide their Personal Information to Global Verification Network and/or our Client, and should not complete the Disclosure & Consent form. Global Verification Network coordinates with third parties to whom Personal Information may be disclosed, to confirm that such parties subscribe to the Safe Harbor Principles or are subject to laws providing the same level of privacy protection as is required by the Safe Harbor Principles and agree in writing to provide an adequate level of privacy protection.

4. Access

Global Verification Network will allow an individual to access their Personal Information and will allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.

5. Security

Global Verification Network takes reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Global Verification Network has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. However, Global Verification Network cannot guarantee the security of Information on or transmitted via the Internet.

6. Data Integrity

Global Verification Network processes Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Global Verification Network takes reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

7. Enforcement

Global Verification Network uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Safe Harbor Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using (an independent resource mechanism) as a third party resolution provider.

Amendments

This privacy policy may be amended from time to time consistent with the requirements of the Safe Harbor Framework. We will post any revised policy on this website.

Information Subject to Other Policies

Global Verification Network is committed to following the Safe Harbor Principles for all Personal Information within the scope of the Safe Harbor Agreement. However, certain information is subject to the policies of Global Verification Network that may differ in some respects from the general policies set forth in this privacy policy.

Contact Information

Questions, comments or complaints regarding Global Verification Network’s Safe Harbor Policy or data collection and processing practices can be mailed to:

Global Verification Network LLC
Attn: Safe Harbor Compliance Department
333 W Wacker Drive
Chicago, IL 60606

This information was last updated on October 2, 2014.

“Personal Information” or “Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to, a specific individual; and (4) can be linked to that individual. “Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.