Privacy Policy

Effective date: 12/13/2022

This Privacy Policy (“Privacy Policy” or “Policy”) describes how the National Center for Safety Initiatives, LLC, including its affiliates, (“NCSI” or “we” or “our”) collects, uses, discloses, and processes personal information in connection with NCSI’s website https://solutions.ncsisafe.com (“Website” or “Site”), products and services (the “Services“). Our Privacy Policy was developed as an extension of our commitment to provide the highest quality of products and services for the purpose of furthering our mission of protecting children and other vulnerable populations. As a consumer reporting agency governed by the Fair Credit Reporting Act (“FCRA”) and other applicable state and federal laws, NCSI is committed to protecting the privacy of our customers.

Please note that by using NCSI’s Site and Services, you are agreeing that you have read and agree to this Policy. 

NCSI offers a wide range of Services to employers, businesses and individuals, including background check and identity verification services. For example, we provide criminal record, education, motor vehicle record, and credit screening services to employers, services to individuals to run background checks on themselves, and volunteer background checks for businesses that want to screen current or prospective participants.

The information we collect and how we use it will depend on how you interact with us. See the definitions below to determine which type of user you are:

Client

Organization (or its end users acting on its behalf) that use the Services

Candidate

Individual about whom a Client requests and/or NCSI provides a background check

Website Visitor

Visitor to the Website

1. Information We Collect

NCSI collects information in a variety of ways:

Information You Submit to Us

NCSI collects personal information submitted directly to NCSI via our Site or by email, such as information needed to produce a background check report. NCSI also collects personal information including name, email address and general business information provided in contact requests, in browser chats, and/or with NCSI agents. NCSI may maintain records of communications submitted through the Site.

If you are a Client, we may also collect your address, login information, phone number, payment information, order details, and other information you may provide to us in connection with using our Services.

Automatically Collected Information

When Candidates, Clients or Website Visitors visit www.ncsisafe.com or use the Services, we may collect certain information, including, without limitation, which pages are visited, what is downloaded, the domains our visitors came from (e.g. "aol.com" or "google.com") and the addresses of sites visited immediately before coming to our site. NCSI may also collect certain information through the use of "cookies." Cookies are bits of electronic information that a web site can transfer to a visitor's hard drive to help tailor and keep records of his or her visit to the site. Cookies help web site operators improve the site's content to better suit its visitors. NCSI may use cookies to help provide you with a better experience on our site. NCSI uses Google Analytics, a web analytics service provided by Google, Inc. ("Google") with respect to only the public pages of our website. Google Analytics uses cookies to help us analyze how the public pages of the Web site are used. The information generated by the cookie about use of the public pages of the website (including your IP address) will be transmitted to and stored by Google. We and Google will use this information for the purpose of evaluating use of the public pages of the website, compiling reports on website activity for website operators and providing other services relating to Site activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You may refuse the use of cookies by selecting the appropriate settings on the browser; however, please note that if you do this you may not be able to use the full functionality of this Site.

Specific information for Candidates:

If you are a Candidate, NCSI collects additional information from third parties, including public records and properly authorized private records. Prior to our collecting any personal information to complete Services, you sign a form to say it is okay. How we use your personal information depends on the Services the Client requests. The table below explains the categories of information we may collect about you and the purposes for which we may use them:

Type of Information

Purposes of Use

 

 Source(s) of Information

Name(s) (current, former and alias)

Used to identify you. NCSI cannot complete Services without this information.

You or our Client

Public Records

Credit/consumer reporting agencies

Third parties that we contact in course of performing Services

Date of birth

Used to identify you as a unique individual for our performance of Services.

You or our Client

 

Contact information

Used to contact you if needed for performing Services or complying with our Client’s instructions and our legal obligations.

You or our Client

 

Address history

Some Services require several years of address history to complete or pull all relevant records.

You or our Client

Public records

Documents to prove identity or address

Some Services require this information, as records we may need to retrieve from third parties are often associated with a government identity number. 

Your or our Client

Public records

 

Sex/gender

Some Services require a sex or gender to complete.

You or our Client

 

Government-issued identity numbers (e.g. Social security number, driver’s license number

Some Services require this information and it is needed to retrieve these records from third parties are often associated with a government identity number.

You or our Client

Criminal history and police records

Some clients wish to review criminal history as part of their screening program.

You or our Client

Law enforcement

Government agencies

Courts and court runners

Public records

Employment history

Some clients want to verify employment over a certain period of time.

You or our Client

Current or past employers

References you have provided

Education history

Some clients want to verify education history over a certain period of time.

You or our Client

Educational institutes you have attended or referenced

Volunteering history

Some clients want to verify volunteering activity over a certain period of time.

You or our Client

Organizations you have referenced

Credit history

Some clients want to obtain financial or identity information found in a credit file.

Credit/Consumer reporting agencies

Government agencies

Public Records

Professional credentials, designations, memberships, sanctions or reprimands

Some clients want to verify professional standing or the existence of professional sanctions or reprimands.

You or our Client

Professional organizations you have referenced

Public Records

The personal information listed above is illustrative and is not meant to be an exhaustive list. The Client that initiates your background check may choose to add additional questions which may require you to disclose additional personal information in addition to what is included above. For more information about what information is being collected and why, please speak with the organization that requested the Services.

2. How We Use Your Information

NCSI uses your information as follows: 

  • To Provide the Site to all users
  • To Perform Services: NCSI uses collected information to perform Services for Candidates and Clients. These services include producing background check reports, providing access to background check reports, providing certain analytics related to background check reports, and providing certain product functionality relating to use of background check reports. 
  • To Communicate with You: NCSI uses collected information to communicate with Clients and Website Visitors about the Services, such as by phone, mail, email, in-browser chat, or SMS regarding the status of certain requested Services, to provide updates on changes or modifications to the Services, and to facilitate the delivery of information authorized or required through the Services. Where appropriate, NCSI may send Clients product announcements and special promotions from NCSI or our business partners..
  • Day to Day Business Operations: NCSI uses collected Client information for its day to day business operations, such as to administer your account, to process billing and payment information, manage preferences and troubleshoot problems, and personalize the content that Clients see based on personal characteristics or preferences.
  • To Meet Legal and Compliance Requirements:  NCSI may use the collected information: i) to comply with any applicable procedures, laws, and regulations, subpoenas, governmental requests or legal process; ii)  in connection with a legal investigation, if in our good faith opinion such is required or permitted by law; iii) to protect the rights, property or safety of NCSI, our Candidates, our Clients, or third parties; (iv) to prevent fraud or abuse of NCSI or our users; or (v) to perform a task carried out in the public interest.
  • To Provide Security: NCSI uses collected information to create Client account credentials, to verify identity prior to granting access to account information, to validate against existing information maintained by NCSI, to protect against duplicate or unauthorized account creation, to secure the Site and Services, and to address fraud, abuse or safety concerns of NCSI, our Clients or Candidates, including investigation of complaints or suspected fraud or wrongdoing.
  • To Improve our Systems and Services: NCSI uses collected information from Website Visitors to continuously improve system functionality through quality assurance checks and audits, to troubleshoot problems, and to verify, improve, or maintain the quality or safety of our services. NCSI may use information it collects about its Website Visitors internally to statistically analyze Site usage, customize our Site's content and layout, and improve our Site's content and our product and service offerings.
  • As otherwise permitted by law.

In addition, we may use anonymized Client and Website Visitor information without limitation, including sharing with third parties. This includes anonymized, pseudonymized, aggregated, or de-identified information about Candidates, Clients, and Website Visitors.

3. How We Share Your Information

We disclose information to respond to legal requirements or requests, enforce our policies, and protect the rights, property and safety of NCSI. Such information will be disclosed in accordance with applicable laws and regulations.

We provide information to service providers under contract who help with our business operations.

We disclose information to law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Website user to legal liability. In such events, we will disclose information that we believe to be relevant and necessary to the investigation or inquiry.

In the event we are engaged in or contemplating a merger or other corporate acquisition with another business entity, personal information may be disclosed to and would likely be acquired by the other business entity. We may, without your consent, access and disclose your personal information, any communications sent or received by you, and any other information that we may have about you as may be permitted or required by law, regulation, rule or court order pursuant to requests from governmental, regulatory or administrative agencies or law enforcement authorities; or to prevent, investigate, identify persons or organizations potentially involved in activity that appears to us to be illegal or we believe may expose us to legal liability. Additionally, we may disclose personal information in situations that we believe to be emergencies involving potential threats to the physical safety of any person or property if we believe that the information in any way relates to that threat.

If you are a Candidate, your personal information may be shared for the business purpose of completing Services and in compiling a consumer report about you in accordance with the FCRA and other applicable law. NCSI may share your information with:

  • The Client who initiated the background check, and who is authorized by you to receive the results of the background check.
  • Affiliates and service providers who assist us in completing the background check
  • Any third parties that we need to contact to collect or validate your personal information or as required by law.

If you are a Website Visitor, we may also share information as disclosed in the “Online Analytics and Advertising” section below.

4. Online Analytics and Advertising

Analytics

We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Online Advertising

The Site may allow third-party advertising technologies to place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you to assist in the delivery of relevant advertising about the Services on other websites you visit and other services you use.

We neither have access to, nor does this Privacy Policy govern, the cookies or other tracking technologies that may be placed on the device you use to access the Services by such non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs. To opt-out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. Please note that these opt-outs apply per device, so you will have to opt-out for each device through which you access our Services.

Notice Concerning Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, which is why we describe a variety of opt-out mechanisms above. However, we do not currently recognize or respond to browser-initiated DNT signals. Learn more about Do Not Track.

5. California Residents

For California resident Website Visitors, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). Please note, however, that information we collect about Candidates for the purpose of delivering our Services to Clients is governed by FCRA and is exempt from the CCPA and is not covered in this section.

Throughout our Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about Website Visitors. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect as defined by California law. Depending upon the types of Services you use, the categories we collect are: Identifiers (such as name and email address); internet or other network or device activity (such as browsing history or app usage); location information; user-generated content; inference data about you; and other information that identifies or can be reasonably associated with you.  Please see “The Information We Collect” for more information.

We use the above categories of information that we collect from you and others in the ways described above, under “How We Use Your Information”

Depending on the circumstances, we may share any of the above categories of information we collect with: business partners to provide you with services that you request; service providers; other parties, including government entities, when required by law or to protect our users and services; and with your consent or in connection with a corporate transaction. In addition, we share device information and identifiers and internet or other network or device activity with entities that provide advertising and functionality.  For more information, please see “How We Use Your Information” and “How We Share Your Information”

CCPA “Sale” of Information

The CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. The CCPA defines “sale” broadly potentially to include allowing third parties to receive certain information such as cookies, IP address and/or browsing behavior in order to enable us to market our Services to you on other websites or apps.

We do not share your information for such purposes (to the extent this is considered a sale). 

California Privacy Rights

For California resident Website Visitors, the CCPA allows you (or an authorized agent acting on your behalf) to make certain requests related to your personal information. Specifically, the CCPA allows you to request us to:

  • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information. Such information is also set forth in this Privacy Policy.
  • Provide access to and/or a copy of certain personal information we hold about you.
  • Delete certain personal information we have about you.
  • Provide you with information about the financial incentives that we offer to you, if any.

The CCPA further provides you with the right not to be discriminated against (as provided in applicable law) for exercising your rights. As noted above, certain information, including any background check data regulated by the FCRA, may be exempt from such requests under California law. We will take reasonable steps to verify your identity before responding to a request. In doing so, we may request information from you so that we can match data you provide with data we maintain. If you would like further information regarding your legal rights under California law or would like to exercise any of them, or if you are an authorized agent making a request on a user’s behalf, please contact us at compliance@ncsisafe.com and include “CCPA Consumer Request” in the subject.

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

6. Third Party Links and Sites

No, please remember that when you use a link to go from www.ncsisafe.com to another web site, this Privacy Policy does not apply.Your browsing and interaction on any other web site, including sites which have a link on www.ncsisafe.com, is subject to the rules and policies of that site. Please read over those rules and policies before proceeding.

7. Your Choices

Subject to any restrictions under applicable laws, we may send periodic promotional or informational emails to Clients. You may opt out of such communications by clicking the unsubscribe link in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.

8. International Considerations

This Site and Services are operated from the United States. By providing information to us through the Services, you are consenting to the transfer of that information to be processed and used in accordance with the terms of this Privacy Policy. Although we do not directly transfer/disclose any personal information to third parties outside of the United States, when an international background check is requested, personal information may be used or transferred to NCSI service providers who in turn transfer personal information to service providers outside the United States from which personal information must be collected or verified to fulfill services requested by our Client. International background checks are conducted with the consent of the individual.

9. Children’s Data

While one of our goals is to protect children, this Site is not intended to be used by children. Persons under the age of 13 are not authorized to use the Site and NCSI does not knowingly solicit or collect information about children under 13 years of age.

10.  How We Protect Your Information

We maintain organizational, technical, and physical safeguards to help protect the information we collect and use. These safeguards vary depending upon a variety of factors including the sensitivity of the information we collect and use. Despite all reasonable practice, no security method is infallible.

11. How Long We Keep Your Information

NCSI will retain collected information in accordance with applicable laws and agreements between NCSI and its Clients and affiliates.

12. Changes to the Privacy Policy

We reserve the right to amend this Privacy Policy at any time to reflect changes to our practices or the law. We will make the revised Privacy Policy accessible through a link on the bottom of our Site. Please check back periodically for updates.

The date on the top of the Privacy Policy tells you when it was last updated. If we make material changes to the way we collect or use your information, you will be provided with appropriate notice by our posting the updated Privacy Policy on this website, and providing notice in accordance with legal requirements. Any changes to this Privacy Policy will become effective when the revised Privacy Policy is posted. By continuing to use our Site following any changes to this Privacy Policy, you acknowledge you have read and understand the updated Privacy Policy, and you understand that we will collect, use, and share your information as stated therein.

13.   Contact Us

NCSI takes privacy matters very seriously. If you have any questions, comments, or concerns about our Privacy Policy please contact NCSI at compliance@ncsisafe.com.