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Global Investigative Services, Inc., (Global) understands
the importance of protecting our client's privacy and the
privacy of their applicants and employees. Personal information
such as name, address, phone number, email, and search results
are always kept private and confidential. We will never sell
or rent our clients or their applicants' personal information
to others. The information that we collect from our clients
are only used for the purposes of setting up their profile,
delivering our service, enhancing the operation of our web
site, and administering our systems. Third parties are used
to assist in delivering our service, to serve site content,
and to help administer customer emails. Only information that
allows them to do their job is provided and we require that
they abide by our privacy policies.
Our web-based system allows only approved clients access
to the system using an appropriate user name and password.
Before granting access to our system or correcting information
we will take reasonable steps to verify your identity. In
addition, we employ SSL data encryption when data is transmitted
over the Internet, and have installed highly effective firewalls
to prevent external "hacking" into our system. For each visitor
to our Web page, our Web server automatically recognizes the
consumer's domain name and IP address. We collect the email
addresses of those who communicate with us via email and
information volunteered by the consumer, such as survey information
and/or site registrations.
Links to third party web sites are provided solely as a convenience
to the visitor and our clients. Global is not responsible
for the content available on any other Internet sites linked
to our site whether the link has been established by us or
by a third party.
Global reserves the right to change the terms of use of our
site at any time. Users of the site will be bound by those
changes without the need for Global to provide any type of
notice to users of our site about the changes.
SAFE HARBOR PROVISIONS OF OUR PRIVACY POLICY
Global Investigative Services, Inc. is committed to protecting
the privacy of personal data that is gathered and maintained on
behalf of employers requesting consumer data inquiries. We certify
that we comply with the “Safe Harbor Principals” of the United States
Department of Commerce, in relation to personal data collected in the
European Commission’s Directive on Data Protection. Our adherence to
the seven Safe Harbor Principles is demonstrated below:
1. Notice
Prior to having Global Investigative Services, Inc. conduct employment
screening on a consumer, it is always disclosed to the consumer (as
prescribed by the Fair Credit Reporting Act, hereinafter "FCRA") that the
information they provided will be used to conduct employment screening for
the employer desiring to use it for employment related decisions (to
determine eligibility to hire, retain, promote, or reassign). Global
Investigative Services, Inc. contact information is included on the
authorization form in the event the consumer has any inquiries or complaints.
Global Investigative Services, Inc. collects information on individuals for
the purpose of providing the information to employers for employment related
decisions. Employers may also use this information to conduct employee
investigations where an employer has a suspicion of work related misconduct
or wrongdoing. The Human Resources and Security professionals within the
employer organization will also use this information. Prior to receiving
information from Global Investigative Services, Inc. and in accordance with
the FCRA, each employer must provide a certification to Global Investigative
Services, Inc. that it will only use Global Investigative Services, Inc.
services for employment purposes or other permissible purpose under the FCRA
and that it will comply with all applicable state and federal regulations and
obligations.
2. Choice
Global Investigative Services, Inc. affords individuals the opportunity to
choose whether their personal information will be disclosed to a third party
or will be used for a purpose incompatible with the purpose for which it was
originally collected or subsequently authorized by the individual. Therefore,
consumer data may be disseminated under these circumstances unless the consumer
explicitly “opts-out.” Where a consumer chooses to “opt-out,” the data is not
necessarily erased or deleted. Various laws require that the data be maintained
on file for a specified period of time for consumer protection purposes.
A consumer can “opt-out” by contacting Global Investigative Services, Inc. in
writing or by e-mail at the addresses listed below.
With respect to sensitive information, however, an individual must “opt-in” to
the disclosure of the information to a third party or to the use of this
information for a purpose other than its original purpose or that purpose
authorized subsequently by the individual. In other words, unless a consumer
chooses to provide explicit consent, a disclosure of sensitive information to
a third party or for an unauthorized purpose will not be made.
3. Onward Transfer (Transfers to Third Parties)
The information obtained by Global Investigative Services, Inc. is forwarded
only to an entity that has been specifically authorized by the consumer to
receive the data and only for the purpose described in the section under
"Notice." Global Investigative Services, Inc. takes reasonable steps to
ensure that any party that receives information will maintain and protect
the privacy and confidentiality of the information. (See the certification
portion described in the section under "Notice.") Any third party that
receives information from Global Investigative Services, Inc. has obtained
written authorization from the consumer and has disclosed to the consumer
the purpose of collecting this data. In addition, each client certifies
they will comply with the confidentiality clause in our Service Agreement
and is given a copy of the FTC's Notice to Users, which outlines their
obligations with respect to the use of this information.
4. Access
A consumer may request, in writing, access to all data collected and
maintained about him or her. Global Investigative Services, Inc. affords
the consumer a reasonable opportunity to correct, amend, or delete
information that is inaccurate or incomplete, except where the burden or
expense of providing access would be disproportionate to the risks to the
individual’s privacy, or where the rights of persons other than the
individual would be violated.
Pursuant to the United States federal Fair Credit Reporting Act, any
citizen of the United States may obtain a copy of their consumer report
free of charge. Global Investigative Services, Inc. reserves the right to
engage in reasonable efforts to confirm the identity of the individual
requesting the data to ensure the information is provided only to the
subject of the data.
Global Investigative Services, Inc. makes every effort to ensure that
the data we collect and store is as accurate as possible. We cannot
guarantee, however, that third parties are committed to making the same
efforts, and therefore, we deny any responsibility for the accuracy of
the data they provide.
5. Security
Global Investigative Services, Inc. takes all reasonable procedures to
protect personal and identifiable information from loss, misuse and
unauthorized access, disclosure, alteration and destruction. The service
utilizes SSL encryption to protect sensitive information online; we also
do everything in our power to protect user-information off-line. All of
our users' information, not just the sensitive information mentioned above,
is kept strictly confidential in our offices. Only employees who need the
information to perform a specific job are granted access to personally
identifiable information. Strong password protection protocols are used on
all computers. Furthermore, all employees are kept up-to-date on our
security and privacy practices. Finally, the servers that are used to store
personally identifiable information are kept in a secure environment, with
appropriate security measures.
6. Data Integrity
Background Information Services, Inc. takes reasonable steps to ensure that
data collected is accurate, complete, current, and reliable for its intended
use. We only collect data that is strictly necessary for the purposes listed
under the section entitled “Notice,” including (but not limited to) information
that is necessary to identify the consumer.
7. Enforcement
This service verifies adherence to the EU Safe Harbor Policy via in-house
verification by the management of this company. In addition, we provide an
independent recourse mechanism by which each individual's complaints and
disputes are investigated and resolved. All complaints and disputes that cannot
be resolved by the consumer and Global Investigative Services, Inc. can be
forwarded to the European Data Protection Authorities to handle the dispute
resolution process.
Furthermore, Global Investigative Services, Inc. is governed by FCRA regulations
as enforced by the U.S. Federal Trade Commission. Global Investigative Services,
Inc. is a member of the National Association of Professional Background Screeners
and strictly adheres to its professional standards, code of conduct, ethical
business practices, and its promotion of compliance with the Fair Credit Reporting
Act.
If you have any questions or comments regarding Global's
online privacy statement, you may contact us at the following:
Global Investigative Services, Inc.
1109 Spring Street Suite 401
Silver Spring, MD 20910
(800) 589-6595
Email - privacy@gispi.com
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