CREDIT INVESTIGATORS USA, INC
America's Best Tenant Screening!
Scope and Application
o non-personally identifiable information;
o the name, title, business address and/or telephone number of an employee of an organization;
o other information about an individual that is publicly available.
collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.
consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of CREDIT INVESTIGATORS . Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.
disclosure: Making personal information available to a third party.
employee: An employee of or independent contractor to CREDIT INVESTIGATORS.
personal information: Information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization, and does not include descriptive, factual information about an organization.
respondent: A member of the public who provides personal information to CREDIT INVESTIGATORS in the course of a survey conducted by CREDIT INVESTIGATORS . For example, a respondent is an individual who discloses personal information to CREDIT INVESTIGATORS in the course of a residential, employment or personal reference.
third party: An individual or organization outside of CREDIT INVESTIGATORS .
use: The treatment, handling, and management of personal information by and within CREDIT INVESTIGATORS or by a third party with the knowledge and approval of CREDIT INVESTIGATORS .
The Ten Principles of Privacy
Principle 1 - Accountability
CREDIT INVESTIGATORS is responsible for personal information under its control and shall designate one or more persons who are accountable for CREDIT INVESTIGATORS’s compliance with the following principles.
CREDIT INVESTIGATORS is responsible for personal information in its possession or control and shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.
Principle 2 - Identifying Purposes for Collection of Personal Information
CREDIT INVESTIGATORS shall identify the purposes for which personal information is collected at or before the time the information is collected.
CREDIT INVESTIGATORS collects personal information from the public only for the following purposes:
* to complete a transaction initiated by the consumer.
* to understand respondent opinions to establish suitability for tenancy or employment.
* to meet legal and regulatory requirements.
Further reference to “identified purposes” mean the purposes identified in this Principle.
CREDIT INVESTIGATORS shall specify orally, electronically or in writing the identified purposes to the respondent at or before the time personal information is collected in a survey. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within CREDIT INVESTIGATORS who can explain the purposes. An applicant signed release will also be provided upon request.
When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the respondent will be acquired before the information will be used or disclosed for the new purpose.
CREDIT INVESTIGATORS may provide affiliates or other third parties with information from an applicant for these purposes:
(a) Credit Reports
(b) Criminal Reports
(c) DMV Reports
(d) Drug Testing
(e) I-9 Reports
Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, for pre employment use. Knowledge and consent of an individual is also required before collecting any financial data. The gathering of criminal data for non employment use does not require a signed consent.
Principle 4 - Limiting Collection of Personal Information
CREDIT INVESTIGATORS shall limit the collection of personal information to that which is necessary for the purposes identified by CREDIT INVESTIGATORS. CREDIT INVESTIGATORS shall collect personal information by fair and lawful means.
CREDIT INVESTIGATORS collects personal information about an individual only if individuals have consented to such collection and only from those sources provided by the individual.
Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information
CREDIT INVESTIGATORS shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
CREDIT INVESTIGATORS may disclose a respondent’s personal information to:
* client of CREDIT INVESTIGATORS where the respondent has consented to such disclosure;
* a third party engaged by CREDIT INVESTIGATORS to perform functions on its behalf;
* a public authority or agent of a public authority if, in the reasonable judgment of CREDIT INVESTIGATORS , it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or
* a third party or parties, where the respondent consents to such disclosure or disclosure is required or permitted by law.
Only CREDIT INVESTIGATORS’s employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about respondents.
CREDIT INVESTIGATORS shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where a respondent may have to be re-contacted for purposes of clarifying responses to a survey, or to seek additional responses, CREDIT INVESTIGATORS shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.
CREDIT INVESTIGATORS shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.
Principle 6 - Accuracy of Personal Information
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
Personal information used by CREDIT INVESTIGATORS shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a respondent.
CREDIT INVESTIGATORS shall update personal information about respondents and employees as necessary to fulfill the identified purposes or upon notification by the individual.
Principle 7 - Security Safeguards
CREDIT INVESTIGATORS shall protect personal information by security safeguards appropriate to the sensitivity of the information.
CREDIT INVESTIGATORS shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.
CREDIT INVESTIGATORS shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
All of CREDIT INVESTIGATORS’s employees with access to personal information shall be required to respect the confidentiality of that information.
CREDIT INVESTIGATORS makes use of Secure Socket Layer (SSL) encryption as well as password protected identifying information. In addition safeguards are taken to insure that information stored by computers, servers, and databases are protected by secure firewall technology, and the highest level of encryption.
Principle 8 - Openness Concerning Policies and Procedures
CREDIT INVESTIGATORS shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.
CREDIT INVESTIGATORS shall make information about its policies and procedures easy to understand, including:
* the means of gaining access to personal information held by CREDIT INVESTIGATORS ;
* a description of the type of personal information held by CREDIT INVESTIGATORS , including a general account of its use; and
* a description of what personal information is made available to related organizations (e.g. subsidiaries).
Principle 9 – Individual Access to Personal Information
Upon request, CREDIT INVESTIGATORS shall inform an individual of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate. A summary of major rights under the FCREDIT INVESTIGATORS is available upon request.
Upon written request to the Privacy Officer, CREDIT INVESTIGATORS will inform an individual of the existence, use and disclosure of his/her personal information and shall be given access to that information.
In certain situations, CREDIT INVESTIGATORS may not be able to provide access to all the personal information that it holds about a respondent. For example, CREDIT INVESTIGATORS may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, CREDIT INVESTIGATORS may not provide access to information if disclosure would reveal confidential commercial information.
Principle 10 - Challenging Compliance
CREDIT INVESTIGATORS shall maintain procedures for addressing and responding to all inquiries or complaints from its respondents regarding CREDIT INVESTIGATORS’s handling of personal information.
CREDIT INVESTIGATORS shall, on written request, inform its respondents about the existence of these procedures as well as the availability of complaint procedures.
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CREDIT INVESTIGATORS USA, INC
America's Best Tenant Screening!
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