Total Insight Screening (“TIS”) is a Consumer Reporting Agency, as defined by the Fair Credit Reporting Act (15 U.S.C § 1681) (“FCRA”), of domestic information for processing background screening for employment or other permissible purposes under the FCRA or other applicable law.
(TIS) is committed to protecting the privacy of individuals who are the subject of a background check performed for employment purposes, tenant screening or other permissible purposes under the FCRA. TIS takes reasonable steps to ensure that personal information it collects and uses is relevant to its intended use, is accurate, complete, and current.
Collection and Use of Data
Types of Data Collected
TIS collects Personally Identifiable Information (“PII”) and other information in connection with our services. Such PII may include, but is not limited to:
- First name and last name
- Social Security Number
- Date of Birth
- Address, State, Province, ZIP/Postal code, City
- Email address
- Phone number
- Driver’s License Number
Prior to performing any background screening services TIS requires that employers must certify in writing that they will comply with The FCRA and all applicable state and federal laws. The certification also includes a stringent employer vetting process, validating business credentials and permissible purpose as well as a certification that employer will not attempt to obtain a background check without making the required disclosures to an applicant and without obtaining the applicant’s prior written consent on said forms, as well as informing the applicant of their rights by providing a copy of, or electronic access to, the Summary of Rights Under the Fair Credit Reporting Act. Employers must also consent to random audits by TIS to ensure proper consumer consent is being obtained.
Other data that may be collected to perform background checks
The specific type of consumer information that will be collected is driven by the type of background check ordered by the employer, but in addition to PII may include:
- Right to work/work permit information
- I-9 information
- Education history and qualifications
- Employment history
- Personal and Professional references
- Professional qualifications and/or licenses with professional bodies
- Publicly sourced information
- Criminal history
- Financial information such as credit history, bankruptcy or financial judgements (when applicable and permitted by law)
- Appearance on global sanctions or terrorist watch lists
- Driving Record Information
In addition to the information described above, additional information may be required per individual states or jurisdictions which may include but not limited to:
- Special authorization forms required by a government entity
- Academic documents such as diplomas and transcripts
- Application forms
- Driving Record State releases
- Any additional requirements will be communicated by TIS and reason for the document explained
Use and Disclosure of Data
TIS collects PII from applicant information entered in our system by employers to perform background checks. That PII is then used to perform background screening searches which include but are not limited to criminal record databases, public records and other necessary third parties as permitted by law.
In order to perform background checks or other permissible services, TIS may use PII to verify an individual’s identity, perform address history searches, perform business due diligence and for other business-related purposes. We may share PII with:
- Our clients (employers or other entities with legally permissible purposes)
- Researchers working on our behalf
- State and federal government authorities or law enforcement agencies
- Other persons and entities as in the good faith belief that such action is necessary to comply with a court order, legal obligation, to prevent or investigate possible wrongdoing in connection with our service, or to protect against legal liability. Personally Identifiable Information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without consent, other than for the express purposes outline previously.
Additionally, TIS will not send PII outside of the U.S. unless an international search is performed by an employer or other entity with a permissible purpose who has obtained the consent of the consumer/applicant.
While most work is performed by our employees or authorized personnel who access personal information directly from our systems and whose activities are under our direct control, we use third-party service providers, such as court researchers, for certain specialized tasks and services we perform for our clients.
Retention of Data
TIS does not maintain a commercial database of consumer information.
Destruction of consumer information is in accordance with the FTC’s disposal requirements.
Security of Data
TIS has taken appropriate steps to ensure the security of PII from loss, misuse, disclosure, unauthorized access, alteration or untimely destruction. We implement a variety of physical, electronic and administrative procedures to safeguard the information we collect. Access to PII is restricted to individuals who need it to perform work functions. Existing protection includes the screening of all TIS employees, not just those handling data, as well as electronic and physical protective measures to guard the data. We require our contracted service providers to protect PII and all clients are subject to a due diligence investigation to confirm that they are a legitimate business before they are allowed access to our system to order background checks.
All supplied sensitive information is transmitted via Secure Socket Layer (SSL) technology and then protected by AES base64 encoded 128-bit encryption of data. Data is only accessible by those authorized with special access rights to such systems, and who are required to keep the information confidential.
Our servers and offices are located within a locked and alarmed facility which is regularly monitored to prevent unauthorized access to our premises.
Our employees access data through secure virtual desktop interfaces and our online interfaces are encrypted, password-protected and monitored. All employees are trained annually on data protection security best practices and policies, including the locking of computer screens when stepping away from their desk and a ‘clean desk’ policy that requires all sensitive information to be locked away when not being processed, even if the employee only leaves their desk for a very short time. Managers and supervisors do ‘walk throughs’ multiple times per day to ensure compliancy.
Physical documents that contain sensitive data or personal identifying information are retained for 30 days in a locked file, then placed in locked shred bins for later disposal, following FTC disposal requirements. Electronic records remain accessible by key employees.
Upon proper identification, consumers who are the subject of a background check have the right to access and receive a free copy of the report (containing PII) and including any records TIS used to conduct their background check. And, upon proper identification, TIS will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete, following all laws regarding the handling and disputing of consumer information. Instructions for disputing a background check are posted on our website and may also be obtained by calling our Compliance Department at 1-800-795-0994 or emailing us at firstname.lastname@example.org. You may also write to us using the mailing address in the Contact Us section of this policy.
- By email: email@example.com
- By phone: 1-800-795-0994
- By mail: Compliance, Total Insight Screening, 15614 Dr MLK Jr Blvd., Dover, FL 33527