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Text Content

 * Careers
 * Clients
 * My Background Check
 * Canada - EN
   Canada - FR UK United States Netherlands Germany Australia Singapore India
   China Malaysia Philippines Hong Kong (SAR)

 * Services
   
   
   GENERAL SCREENING
   
    * Background Screening Solutions
    * Criminal Record Checks
    * Criminal Record Re-check
    * Covid-19 Vaccine Collection
    * Driver Abstracts
    * Enhanced Police Information Check
    * Global Background Check
    * Identity Cross-Check
   
   
   GENERAL SCREENING
   
    * Quebec Criminal Court Search
    * Reference Checks
    * Signed Police Certificate
    * Social Media Search
    * Sterling API
    * Tenant Screening
    * Positions of Trust
   
   
   GENERAL VERIFICATIONS
   
    * Identity Verification Overview
    * Verifications Options
   
   
   BACKCHECK 2.0 VERIFICATIONS
   
    * Sterling Identity Verification
   
   
   MYBACKCHECK VERIFICATIONS
   
    * Contractor Credentialing
    * Verifiable ID Badge
   
   
   INDIVIDUAL
   BACKGROUND CHECKS
   
    * Personal Criminal Record Check
   
   
   FINANCIAL & BUSINESS
   
    * Credit Bureau Inquiries
   
   
   SERVICES OVERVIEW
   
    * Explore All Services

 * Industries
   
   
   INDUSTRIES WE SERVE
   
    * Construction
    * Consulting Firms
    * Energy & Utilities
    * Financial & Business Services
    * Gig Economy
    * Government & Public Sector
    * Healthcare
   
    * Insurance
    * Logistics and Warehouse
    * Manufacturing and Agriculture
    * Mining
    * Police Services
    * Real Estate
    * Retail
   
    * Staffing Services
    * Small Businesses
    * Telecommunications
    * Transportation
    * Volunteer & Not-for-Profit
   
   
   FEATURED BLOG
   
   
   Background Check Trends to Watch For In 2023
   Read the blog
 * Integrations
 * Resources
   
   
   BLOG
   
   Insightful industry perspective written by Sterling Backcheck experts and
   global partners
   
   
   LEARNING RESOURCES
   
   E-books, whitepapers, and more to help you grow and scale your business
   
   
   CANDIDATE FAQS
   
   Your top screening and background check questions, answered
   
   
   CLIENT FAQS
   
   Your top screening and background check questions, answered
   
   
   EVENTS & WEBINARS
   
   Upcoming and on-demand webinars and events
   
   
   CUSTOMER STORIES
   
   Hear what customers say about Sterling Backcheck in their own words
   
   
   COMPLIANCE HUB
   
   Gain insight on important resources to increase your understanding on
   creating a compliant screening policy
   
   
   FEATURED WEBINAR
   
   
   Re-Screening Your Workforce in 2021
   Learn More
 * About Us
   About Sterling Backcheck
   Discover core values upon which Sterling Backcheck was built and the
   difference that’s making our world a safer place
   
   Our Leadership
   Behind every great company is a great leadership team. Get to know our
   executive team and key senior leaders
   
   News
   See what’s trending in Sterling Backcheck news: Recent press releases,
   breaking industry news, and featured media pieces
   
   Careers
   At Sterling Backcheck, enjoy a career with meaning and purpose. View open
   positions and gain insight into our people and culture
   
   
   
   FEATURED VIDEO
   
   
   How Sterling Backcheck Runs Background Checks
   Learn More

 * Client Login
 * Contact Us
 * 


My Background Check
Client Login


SERVICES


GENERAL SCREENING

 * Background Screening Solutions
 * Criminal Record Checks
 * Criminal Record Re-check
 * Covid-19 Vaccine Collection
 * Driver Abstracts
 * Enhanced Police Information Check
 * Global Background Check
 * Identity Cross-Check
 * Quebec Criminal Court Search
 * Reference Checks
 * Signed Police Certificate
 * Social Media Search
 * Sterling API
 * Tenant Screening
 * Positions of Trust


GENERAL VERIFICATIONS

 * Identity Verification Overview
 * Verifications Options


BACKCHECK 2.0 VERIFICATIONS

 * Sterling Identity Verification


MYBACKCHECK VERIFICATIONS

 * Contractor Credentialing
 * Verifiable ID Badge


INDIVIDUAL
BACKGROUND CHECKS

 * Personal Criminal Record Check


FINANCIAL & BUSINESS

 * Credit Bureau Inquiries


SERVICES OVERVIEW

 * Explore All Services


INDUSTRIES

 * Construction
 * Consulting Firms
 * Energy & Utilities
 * Financial & Business Services
 * Gig Economy
 * Government & Public Sector
 * Healthcare
 * Insurance
 * Logistics and Warehouse
 * Manufacturing and Agriculture
 * Mining
 * Police Services
 * Real Estate
 * Retail
 * Staffing Services
 * Small Businesses
 * Telecommunications
 * Transportation
 * Volunteer & Not-for-Profit

Integrations


RESOURCES

 * BLOG
 * LEARNING RESOURCES
 * CANDIDATE FAQs
 * CLIENT FAQs
 * EVENTS & WEBINARS
 * CUSTOMER STORIES
 * COMPLIANCE HUB


ABOUT US

 * About Sterling Backcheck
 * Our Leadership
 * News
 * Careers

Canada - EN
Canada - FR UK United States Netherlands Germany Australia Singapore India China
Malaysia Philippines Hong Kong (SAR)

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PRIVACY STATEMENT – SERVICES FOR CLIENTS






QUICK SUMMARY

WHAT PERSONAL INFORMATION WE COLLECT AND WHY

We collect personal information that our client instructs us to collect. For
more information about what information is being collected and why, please speak
with the organization that requested the services.

WHO WE SHARE YOUR PERSONAL INFORMATION WITH AND WHY

We share your personal information with the client that requested it, any third
party that we need to contact to collect or validate your personal information,
and service providers that we use to complete services and manage our
infrastructure.

WHAT WE DON’T DO WITH YOUR PERSONAL INFORMATION

We don’t sell or disclose your personal information to governments, marketing or
advertising services, other clients, or anyone else except as outlined in this
statement or required by law.

PRIVACY MISSION STATEMENT

Sterling Backcheck is committed to the protection of individual privacy rights.
We hold ourselves to the highest legal and ethical standard for compliance and
strive to be a privacy champion in the human resources technology industry. We
value the trust our clients, colleagues and suppliers place in us, and we work
to maintain that trust by building privacy protection into everything we do.

PERSONAL INFORMATION DISCLOSURE: UNITED STATES OR OVERSEAS

Personal information collected from people in the United States may be
transferred outside of the United States as follows:

 * To Sterling’s affiliate operations centers in the Philippines and India for
   service fulfillment.
 * To third parties from which personal information must be collected or
   verified to fulfill services requested by our client (for example, if our
   client asks for a criminal record check in Brazil, personal information will
   be transferred to the organization in Brazil that provides police
   certificates).
 * To contractors that provide country- or region-specific services, where our
   client has requested those services (for example, if our client asks for an
   education verification in Japan, personal information may be transferred to a
   company in Asia with expertise in verifying Japanese education history in the
   Japanese language).

For more information about cross-border transfers of personal information,
scroll down to Section 9 below, “Do we transfer personal information between
countries?”


TABLE OF CONTENTS

 1.  Scope of application
 2.  Why do we collect personal information and what types of personal
     information do we collect?
 3.  How do we use cookies?
 4.  When, why and how do we communicate personal information outside of
     Sterling?
 5.  How do we ensure your personal information is accurate?
 6.  Do we engage in automated decision-making or profiling using personal
     information?
 7.  Do we conduct research using personal information?
 8.  How long do we keep personal information?
 9.  Do we transfer personal information between countries?
 10. Do we participate in the EU-U.S. and Swiss-U.S. Privacy Shield Framework?
 11. How do we protect personal information?
 12. How can you choose how and whether we collect and use your personal
     information?
 13. How can you access or correct your personal information, request that it be
     deleted, or ask for it to be transferred to another organization?
 14. How can you make a complaint about how we have handled your personal
     information or responded to a request to exercise your rights?
 15. Contact Information
 16. Glossary


1   SCOPE OF APPLICATION

This statement applies to the collection and processing of personal information,
which means information about an identifiable individual (you) that Sterling
Backcheck (Sterling, we or us) collects in the course of providing services to
our clients. This statement does not apply to personal information we collect
about our clients or users of our marketing web sites. For information about
privacy in these contexts, click here. It also does not apply to the collection
and processing of personal information about our employees or contractors. For
information about privacy in the context of doing work for Sterling, click here.


2   WHY DO WE COLLECT PERSONAL INFORMATION AND WHAT TYPES OF PERSONAL
INFORMATION DO WE COLLECT?

We collect personal information in the course of several business activities.
Select and expand the section for the activity that applies to you to understand
that activity, the personal information we collect for it, how we use that
personal information, and our legal basis for doing so.

TO PROVIDE BACKGROUND CHECK, ONBOARDING AND OTHER SERVICES TO OUR CLIENTS.





Our primary function is as a service provider to our clients. We conduct the
following types of services:

 * Background screening before and during employment, volunteer or contractual
   relationships;
 * Collection, validation and storage of onboarding and other human resources
   documents;
 * Due diligence research for investments, acquisitions, directorships and other
   business relationships.

When we provide services to clients, our client is generally responsible for the
following aspects of collection and processing of personal information:

 * determining which personal information we collect and how we use it;
 * establishing a legitimate basis to collect and process personal information
   and ensuring that the collection and processing complies with applicable law;
 * if appropriate, ensuring that you are notified of, or provide consent for,
   the collection and processing of your personal information in accordance with
   applicable law;
 * complying with any legal obligations it may have as the entity that controls
   or owns the personal information.

And we are generally responsible for the following aspects of collection and
processing of personal information:

 * carrying out the services requested by our client in accordance with its
   instructions;
 * storing and protecting personal information in our custody according to our
   client’s instructions;
 * complying with any legal obligations we may have as a data processor,
   custodian, service provider or similar under applicable law.

When we provide services to a client, collection of your personal information is
done in accordance with our client’s instructions. For more information, please
contact the client.

Review the list below to see the types of personal information we collect from
or on behalf of our clients, along with an explanation for why we collect them
and where we get them.

FIGURE 1: TYPES OF PERSONAL INFORMATION COLLECTED TO PROVIDE SERVICES TO CLIENTS

Type of information Reason for collection Source(s) Name(s) (current and former)
This is how we identify you. If we do not know who you are, we cannot provide
services. Former names may be needed to conduct a complete background check, as
old records may be held under a former name.
 * You or our client
 * Public records
 * Credit/consumer reporting agencies
 * Third parties that we contact in the course of performing services.

Date of birth* Along with your name, this serves to identify you as a unique
individual, and is often required to perform services.
 * You or our client

Photograph If our client asks us to create a profile or ID card for you
following a background check, we may collect a photograph. Some services require
us to collect a photo ID, which also contains a photograph.
 * You or our client

Contact information In most cases, we need to know how to get in touch with you.
This may include your mailing address, email address or telephone number. If we
collect these while providing services for a client, we will use them only to
provide those services and comply with our client’s instructions and our legal
obligations. We will not contact you for any other reason.
 * You or our client

Address history Some services, especially criminal record and credit checks,
require several years of address history to complete.
 * You or our client
 * Credit/consumer reporting agencies
 * Public records

Documents to prove identity or address We may be asked by our client to verify
your identity, or we may be required to do so to complete services. If so, we
may collect ID cards or other documents you provide.
 * You or our client
 * A third party that collects your documents or verifies your identity for the
   purpose of transferring that information to us.

Sex or gender* Some services require a sex or gender to complete.
 * You or our client

Government-issued identity numbers (e.g. Social Security Number, Social
Insurance Number, National Insurance Number, driver’s license number)* Some
services require this information, as records we need to retrieve from third
parties are often associated to a government identity number. This may include
criminal records, credit files, employment history or driving records.
 * 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 or other government agencies
 * Courts or court runners
 * Public records

Credit or bankruptcy history* Some clients wish to obtain financial or identity
information found in a credit file with a credit bureau or in public record
information.
 * Credit/consumer reporting agencies
 * Government agencies
 * Public records

Employment history Some clients wish to verify employment or activity history
over a certain period of time.
 * You or our client
 * Your current or past employers or their recordkeeping service providers
 * Agencies that placed you with your current or past employers
 * References you have provided

Education history Some clients wish to verify education or activity history over
a certain period of time.
 * You or our client
 * Educational institutions you have attended or their recordkeeping service
   providers for educational institutions you have attended
 * Government education authorities in jurisdictions where you have attended
   school
 * References you have provided

Volunteering history* Some clients wish to verify volunteering or activity
history over a certain period of time.
 * You or our client
 * Organizations with which you have volunteered or their recordkeeping service
   providers
 * References you have provided

Travel history Some clients wish to verify activity history over a certain
period of time.
 * You or our client
 * References you have provided

Professional credentials, designations, memberships, sanctions or reprimands
Some clients wish to verify standing as a certain type of professional,
participation or completion of professional development courses, or the
existence of professional sanctions or reprimands.
 * You or our client
 * Professional organizations with which you have been associated, or their
   recordkeeping service providers.
 * Public records
 * References you have provided

Opinions about you Some clients wish to conduct reference interviews.
Additionally, opinions may be provided during verifications of employment or
volunteering.
 * You or our client
 * Your current or past employers or their recordkeeping service providers
 * Agencies that placed you with your current or past employers
 * References you have provided

Appearance on government watch or sanctions lists* Some clients wish to check
for presence on government watch or sanctions lists.
 * Law enforcement or other government agencies

Civil court records Some clients wish to review litigation history in civil
court.
 * Courts
 * Court information aggregators
 * Public records
 * Credit/consumer reporting agencies

Health information, including drug test results* Some clients wish to test for
drugs or other health conditions.
 * You or our client
 * Drug testing laboratories following sample collection for this purpose.
 * Medical professionals following a consultation for this purpose.

Eligibility to work Some clients wish to verify potential employees’ legal
status in the jurisdiction where they operate.
 * You or our client
 * Government agencies

Tax information* Some clients wish to use our services to collect tax documents
from their employees.
 * You or our client

Driving records Some clients wish to check driver’s license validity and driving
history.
 * You or our client
 * Government agencies

Directorship and corporate governance history Some clients wish to verify
current or past involvement with corporations as a director or officer.
 * You or our client
 * Public records
 * Corporations with which you have had previous involvement.

Place of birth* Some services require a place of birth to complete.
 * You or our client.

Other public record information Some clients wish to search various other public
record sources for information.
 * You or our client
 * Government agencies
 * Public records

Telephone call recordings We monitor some phone calls for quality assurance and
training purposes.
 * You.

Your opinions about your experience with Sterling We may occasionally seek your
feedback about your interactions with us to improve the quality of our service
 * You.

*Items marked with an asterisk may be considered sensitive or may be subject to
special protections in some places. They will not be collected in every case.
They will not be collected where prohibited by law, and where permitted, they
will only be collected and used in accordance with applicable law.







TO TRACK USAGE AND SECURITY OF OUR SECURE PLATFORMS.





Our sites use cookies. For more information on cookies, please see the section
entitled ‘How do we use cookies?’

Information about your activity on our secure platforms, including SterlingONE,
Screening Direct, Workforce Direct, BackCheck, eConsent, Verified Volunteers,
myBackCheck.com and others, is collected to ensure the integrity and security of
our systems and data in our custody, and is used to audit system access and
investigate suspicious activity.

Collection of personal information for security purposes is done based on our
legitimate interest and legal obligation to ensure personal information in our
custody is protected.

The following types of information, some of which may be personal information,
are logged when you access our secure platforms:

 * IP address;
 * location;
 * login credentials for our systems;
 * dates, times, and length of session;
 * access to and modification of data;
 * browser type and version.

REUSE OF PERSONAL INFORMATION FOR NEW PURPOSES

We will not reuse personal information for a new purpose other than the original
one(s) for which it was collected, unless one or more of the following is true:

 * the new use is compatible with the original one, meaning you should
   reasonably expect it;
 * we have notified you of the new use and given you an opportunity to object to
   it; or
 * the new use is otherwise permitted or required by law.










3   HOW DO WE USE COOKIES?

Cookies are pieces of information shared between your web browser and a website.
Cookies enable the website to collect information about your activities and
provide you with a faster and easier experience for the user. When you access
our site, we ask for your consent to use cookies.

There are different kinds of cookies with different functions:

 * Session cookies: these are only stored on your computer during your web
   session. They are automatically deleted when the browser is closed. They
   usually store an anonymous session ID allowing you to browse a website
   without having to log in to each page. They do not collect any information
   from your computer.
 * Persistent cookies: a persistent cookie is one stored as a file on your
   computer, and it remains there when you close your web browser. The cookie
   can be read by the website that created it when you visit that website again.
 * First-party cookies: the function of this type of cookie is to retain your
   preferences for a particular website for the entity that owns that website.
   They are stored and sent between Sterling’s servers and your computer’s hard
   drive. They are not used for anything other than for personalization as set
   by you. These cookies may be either Session or Persistent cookies.
 * Third-party cookies: the function of this type of cookie is to retain your
   interaction with a particular website for an entity that does not own that
   website. They are stored and sent between the Third-party’s server and your
   computer’s hard drive. These cookies are usually Persistent cookies.

Our service platforms, which we use to collect information from you and our
clients, do not use third-party cookies. They may use first-party session
cookies to track your use of the sites and first-party persistent cookies to
remember any preferences you select, such as your location.

The major browsers have attempted to implement the draft “Do Not Track” (“DNT”)
standard of the World Wide Web Consortium (“W3C”) in their latest releases. As
this standard has not been finalized, our sites are not compatible with DNT and
so do not recognize DNT settings.

We use cookies for the following purposes:

WHERE STRICTLY NECESSARY

These cookies are essential in order to enable you to move around the site and
use its features, such as accessing secure areas of the site. Without these
cookies, services such as viewing certain areas of the site or using web forms
cannot be provided. These cookies do not gather information about you that could
be used for marketing or remembering where you have been on the internet.

PERFORMANCE

These cookies collect information about how visitors use a site, for instance
which pages visitors go to and if they get error messages from web pages. These
cookies do not collect information that identifies a person, as all information
these cookies collect is anonymous and is used to improve how our site works.

FUNCTIONALITY

These cookies allow our site to remember choices you make (such as your language
or the region you are in) and provide enhanced features. These cookies can also
be used to remember changes you have made to text size, font and other parts of
web pages that you can customize. They may also be used to provide services you
have requested such as viewing or commenting on content on the site. The
information these cookies collect is usually anonymized.

Please consult your web browser’s ‘Help’ documentation or visit
www.aboutcookies.org for more information about how to turn cookies on and off
for your browser.


4   WHEN, WHY AND HOW DO WE COMMUNICATE PERSONAL INFORMATION OUTSIDE OF
STERLING?

TO COMPLETE SERVICES

The services we provide frequently require us to find or validate personal
information with third party sources. To do so, we need to provide your personal
information to allow the third party to find records about you. We generally
provide the information that is required by the third party in the format and
through the transmission method of the third party’s choosing. This may involve
transmitting information through a web site, phone call, email, fax, letter or
in person.

When we provide services to a client, communication of your personal information
is done in accordance with our client’s instructions. For more information,
please contact the client.

TO PROVIDE RESULTS TO OUR CLIENT

When we provide services to a client, we transmit personal information back to
that client. This is done through our secure web platforms and occasionally by
phone, email, fax or mail.

TO ENGAGE SERVICE PROVIDERS

While most of our work is done 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 for certain
specialized tasks. These tasks include storage of data, information technology
support, and some services we perform for our clients.

It would be impractical to list all service providers here, so we have listed
types of service providers instead of individuals or organizations. To
understand which service providers may receive your personal information,
contact us.

When we provide services to a client, use of service providers is done in
accordance with our client’s instructions. For more information, please contact
the client.

Expand the list below to see which types of service providers we use, the
purposes for which we use them and the types of personal information we may
transfer to them.

FIGURE 2: SERVICE PROVIDERS





Service provider Types of information Purposes for transfer Data storage and
delivery providers All personal information in our custody Secure data storage
and delivery IT support services Personal information in our custody with which
we require technical support Technical support Other companies that provide
services similar to ours Personal information required to complete services
Provision of services in locations where we do not operate and overflow support
when necessary Court runners Personal information required to conduct court
record searches Provision of court record services Drug testing labs Personal
information required to set up and carry out drug screening Provision of drug
screening services Police services Personal information required to conduct
police record searches Provision of police record services Translation services
Personal information we have received in a language other than that which is
used to provide the services for which it was collected Provision of services in
the language required by our client Survey services Your opinions about our
services Conducting surveys









IN EXCEPTIONAL CIRCUMSTANCES

We may be asked to communicate personal information to law enforcement agencies,
national security agencies, courts or other public bodies in any jurisdiction
where we are subject to the law, regardless of where personal information is
stored. If we receive a production order, warrant, subpoena or other enforceable
demand, we will comply as required by law. If we receive a request to provide
information voluntarily, we will consider your interests, our business
interests, the interests of our clients, public safety implications and our
legal obligations prior to deciding whether to communicate personal information.
In any case where the information in question was collected from or on behalf of
a client, we will consult with the client before proceeding unless prohibited by
law.

We may proactively communicate personal information to law enforcement or other
third parties if necessary to investigate or report a violation of the law or a
contractual agreement, or if otherwise appropriate and permitted by law.


5   HOW DO WE ENSURE YOUR PERSONAL INFORMATION IS ACCURATE?

Much of the personal information we collect comes directly from you, in which
case you are in control of its accuracy. Our processes for collecting and
transcribing personal information are automated to the greatest extent possible
and are subject to rigorous quality controls. Information that is found to be
inaccurate, either through our own audits or following your request for
correction, is updated.


6   DO WE ENGAGE IN AUTOMATED DECISION-MAKING OR PROFILING USING PERSONAL
INFORMATION?

We do not make decisions about you, automated or otherwise, and do not attempt
to analyze or predict your behavior, preferences, interests, health or other
personal characteristics. However, we may carry out automated processing on our
client’s instructions. For more information about automated processing of
personal information on behalf of a client, please contact the client.


7   DO WE CONDUCT RESEARCH USING PERSONAL INFORMATION?

No. We maintain historical statistical data in anonymized, aggregate format for
research and analysis.


8   HOW LONG DO WE KEEP PERSONAL INFORMATION?

We keep personal information that was collected from or on behalf of a client
for as long as the client asks us to keep it, or as long as we need to keep it
to comply with our legal obligations. To understand how long we will store your
personal information, please contact us or the client on whose behalf we
collected it. We do not delete personal information unless instructed to do so
by our client.


9   DO WE TRANSFER PERSONAL INFORMATION BETWEEN COUNTRIES?

Yes. We store personal information in Canada (for data on our BackCheck,
eConsent, SterlingONE Canada and myBackCheck.com platforms) and in the United
States (for data on all other platforms, including third-party providers). Our
employees and contractors access personal information through virtual desktop
interfaces in the United States, Canada, the United Kingdom, India and the
Philippines. We also use service providers in various other countries, usually
to collect or translate information from that service provider’s country or
region that we require to provide services.

If your personal information is subject to European Union (EU) or Swiss law, it
may be transferred outside of the EU or Switzerland based on one or more of the
following legal mechanisms:

 * Relevant authorities have issued a decision that personal information will
   benefit from an adequate level of protection in the country to which it is
   transferred. This is the case for Canada and, under the EU-U.S. and
   Swiss-U.S. Privacy Shield Framework, Sterling Backcheck entities in the
   United States. This is not the case for India or the Philippines.
 * We have signed contractual clauses with our client that are deemed by the
   relevant authority to ensure adequate protection of personal information.
 * You have provided your consent for us to transfer personal information
   outside of the EU or Switzerland to allow us to carry out services for you or
   on behalf of a client.

In all cases, we ensure that appropriate safeguards are in place to ensure the
protection of your personal information. For more information about these
safeguards, please contact us.


10   DO WE PARTICIPATE IN THE EU-U.S. AND SWISS-U.S. PRIVACY SHIELD FRAMEWORK?

Yes. Sterling Infosystems Inc. and its U.S. affiliates and subsidiaries
operating under the brand name of Sterling Backcheck (listed below under
“Privacy Shield Covered Entities”) comply with the EU-U.S. Privacy Shield
Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S.
Department of Commerce regarding the collection, use and retention of personal
information transferred from the EU and Switzerland to the United States.
Sterling has certified to the Department of Commerce that it adheres to the
Privacy Shield Principles. Sterling remains responsible for personal information
that is communicated to third parties for processing as described in the section
entitled “When, why and how do we communicate personal information outside of
Sterling?” If there is any conflict between the terms in this statement and the
Privacy Shield Principles, the Privacy Shield Principles will prevail. To learn
more about the Privacy Shield program and to view our certification, please
visit https://www.privacyshield.gov. The Federal Trade Commission has
jurisdiction over Sterling’s compliance with Privacy Shield.

PRIVACY SHIELD COVERED ENTITIES





 * Abso, Inc.
 * American Background Information Services, Inc.
 * Bishops Services, Inc.
 * Data Quick Direct, Inc.
 * EmployeeScreen IQ, Inc.
 * Screening International LLC
 * Sterling Credit Screening, Inc.
 * Sterling Infosystems Ohio, Inc.
 * Sterling Protective Systems, Inc.
 * Talentwise, Inc.
 * The Premier Company, dba Tandem Select
 * Unisource Screening & Information, Inc.
 * Verified Person, Inc.










11   HOW DO WE PROTECT PERSONAL INFORMATION?

We have advanced security measures in place to secure and protect your personal
information, such as internal and external firewalls, monitoring and alert
systems to prevent and detect intrusion attempts, and 128-bit encryption of data
both in transit and at rest. Our servers are located within a securely managed
infrastructure, and undergo multiple reviews by independent auditors. Our
employees access data through secure virtual desktop interfaces, and our online
interfaces are encrypted, password protected and monitored.

We employ equally rigorous physical security policies to prevent physical access
to our premises. Our servers and offices, including personal information in hard
copy form, are kept in access-controlled and monitored environments.

All of our employees have been carefully screened and undergone thorough
security and privacy training. We restrict access to your personal information
to individuals who need it to perform their work functions. Our operations,
customer service, account management, finance, quality, vendor management and
compliance teams may have regular access to your information and employees in
other departments may access it occasionally as required to provide services,
communicate with you and fulfill our legal obligations.

We also enter into contractual agreements with service providers with which we
may need to share your personal information, which require them to protect your
personal information to the same level as we do, and allow us to audit their
compliance with those obligations.


12   HOW CAN YOU CHOOSE HOW AND WHETHER WE COLLECT AND USE YOUR PERSONAL
INFORMATION?

Providing your information to us is voluntary. The list below explains how to
make choices about the collection and use of your personal information for
various purposes, and the consequences of your choice not to provide your
personal information.

Whenever our legitimate basis for collecting and using personal information is
your consent, you can withdraw or modify your consent for future collection or
use of your personal information at any time, and we will explain the
consequences of doing so.

If we use your personal information for sales or marketing purposes, you can ask
us to stop at any time and we will do so.

FIGURE 3: CHOICES ABOUT COLLECTION AND USE OF PERSONAL INFORMATION





Purpose for collection How to exercise choice Consequences Providing services to
a client Do not provide your personal information to us directly, and speak with
the client to understand your options. If we have already collected your
personal information, contact us. We will not complete services about you on
behalf of our client, or we will stop completing them if we have already
started. Our own tracking on our web sites Do not use our web sites. You will
not view our web content or be able to provide your personal information through
a web interface.










13   HOW CAN YOU ACCESS OR CORRECT YOUR PERSONAL INFORMATION, REQUEST THAT IT BE
DELETED, OR ASK FOR IT TO BE TRANSFERRED TO ANOTHER ORGANIZATION?

At any time, you can request access to your personal information, request that
any inaccuracies be corrected, and request that comments or explanations be
added to records about you.

You can also ask about:

 * whether and why we have your personal information;
 * how we got your personal information;
 * what we have done with your personal information;
 * to whom we have communicated your personal information;
 * where your personal information has been stored, processed or transferred;
 * how long we will retain your personal information, or how that retention
   period will be determined; and
 * the safeguards in place to protect your information when it is transferred to
   third parties or third countries.

Finally, you can ask us not to collect or use your personal information for
certain purposes, you can ask us to delete your personal information, or you can
ask us to provide your personal information to a third party.

We may refer any of these requests to our client if your personal information
was collected on behalf of that client.

Depending on which laws apply to your personal information, we or our client may
only be able to do some of these things for you. If you request one of these
things and we refuse to do it, we will explain your legal rights, the reason for
our refusal and any recourse you may have.


14   HOW CAN YOU MAKE A COMPLAINT ABOUT HOW WE HAVE HANDLED YOUR PERSONAL
INFORMATION OR RESPONDED TO A REQUEST TO EXERCISE YOUR RIGHTS?

We commit to investigating and resolving complaints about our collection or use
of your personal information. To make a complaint, contact us.

FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA AND SWITZERLAND





If you are in Europe, you should contact our UK office to resolve your
complaint, regardless of which of our companies the complaint is about. If you
are not satisfied with our resolution of your complaint, you may complain to the
Information Commissioner’s Office. We commit to cooperating with the panel
established by the EU data protection authorities (DPAs) or the Swiss Federal
Data Protection and Information Commissioner (FDPIC) and comply with the advice
given by the panel or the FDPIC with regard to personal information transferred
from the EU or Switzerland. For the purposes of the Privacy Shield, we are
subject to the investigatory and enforcement powers of the Federal Trade
Commission. In some conditions, you may be able to invoke binding arbitration to
resolve your complaint where your personal information has been transferred to
and processed in the United States.







FOR UNITED STATES RESIDENTS





If you are not satisfied with our resolution of your complaint, you can make a
privacy complaint to the Federal Trade Commission or you can make a consumer
reporting complaint to the Consumer Financial Protection Bureau. You may also be
able to make a complaint to your state’s Attorney General or similar office.







FOR CANADIAN RESIDENTS





If you are not satisfied with our resolution of your complaint, you may be able
to make a complaint to one of the following regulatory agencies. Upon resolution
of your complaint, we will let you know which of these, if any, may apply to
your situation.

 * Office of the Privacy Commissioner of Canada
 * Office of the Information and Privacy Commissioner of Alberta
 * Office of the Information and Privacy Commissioner for British Columbia
 * Commission d’accès à l’information du Québec





FOR RESIDENTS OF OTHER COUNTRIES





Please contact us to understand how to make a complaint.












15   CONTACT INFORMATION

UNITED STATES

Head of Privacy

1 State Street Plaza New York, NY 10004 USA

privacy@sterlingts.com

1-800-899-2272

CANADA

Head of Privacy

Suite 200-19433 96th Avenue Surrey, BC V4N 4C4 CANADA

privacy@sterlingts.com

1-800-455-5671

EUROPEAN ECONOMIC AREA AND SWITZERLAND

Data Protection Officer

8th Floor, Alexandra House 1 Alexandra Road

Swansea SA1 5ED UK

privacy@sterlingts.com

+44 (0)1792 478838

Information Commissioner’s Office Registration Number: Z9745943

ALL OTHER COUNTRIES

Head of Privacy

1 State Street Plaza New York, NY 10004 USA

privacy@sterlingts.com

+1 604 881 2011


16   GLOSSARY

Anonymized means that sufficient information has been removed from personal
information so that it can no longer be associated with an identifiable
individual.

Client means an organization that contracts with us to perform background
screening or onboarding services.

Consumer means an individual acting in his or her personal capacity.

Individual or you means the individual that personal information is about.

Personal information means information about an identifiable individual.

Processing, handling or use means anything we do with personal information.

Profiling means automated use of your personal information to analyze or predict
things like your performance at work, creditworthiness, reliability and conduct.

Sterling Backcheck, Sterling, we or us means Sterling Infosystems, Inc. and all
of its subsidiaries and affiliates.

Services means the human resources technology services we provide to our clients
and consumers, including background screening and onboarding services.

Service provider means a company engaged to process personal information on
behalf of another company.

Third party means a person or organization that is neither you nor us.



Published: September 18th, 2017


VERSION HISTORY

Revision Date Available Statement April 23, 2018 Current version September 8,
2017 Click to download this version August 10, 2017 Click to download this
version

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