Privacy Policy: Marketing
Welcome to HireRight’s privacy notice. HireRight respects your privacy and is committed to protecting personal data about you. This privacy notice will inform you as to how we look after personal data about you when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This Privacy Notice relates only to how we handle personal data for marketing purposes. If you are a candidate or employee of a HireRight Client or of HireRight itself please go to https://www.hireright.com/legal/privacy-policy to read the Privacy Notice applicable to your situation.This Privacy Notice was last updated on 31 December 2019.
Important information and who we are
Through this Privacy Notice, we intend to give you information on how HireRight collects and processes personal data about you through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service, or take part in a competition.This website is not intended for children and we do not knowingly collect data relating to children.It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.HireRight is made up of different legal entities, details of which can be found at https://www.hireright.com/about-us/offices. This privacy notice is issued on behalf of the HireRight Group so when we mention “HireRight”, "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the HireRight Group responsible for processing your data.In Europe we have appointed a data protection officer (“DPO”) and in the United States of America we have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please make contact using the details set out below.
How can you contact HireRight about privacy?
For the eastern hemisphere (Europe, Africa, the Middle East, Asia, Australia, and the Pacific): HireRight Limited | For the western hemisphere (USA, Canada, Latin America): HireRight LLC or General Information Solutions LLC |
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Email:
| Email:
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Postal Address: Data Protection Officer, HireRight, Gun Court, 70 Wapping Lane, London, E1W 2RD, United Kingdom | Postal Address: Data Protection Manager, HireRight, 100 Centerview Drive, Suite 300, Nashville, TN 37214, United States |
You have the right to make a complaint at any time to any relevant authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority, so please contact us in the first instance.
How might HireRight change its privacy policies?
HireRight may revise the policies that this Privacy Notice describes from time to time. If there is a material change to the policies that this Privacy Notice describes, we will post the revised notice at this location. HireRight will not provide less privacy protection, without your consent, to information collected under a prior set of privacy policies. We encourage you to periodically review this Privacy Notice to be informed of how HireRight is protecting your information.
What data will HireRight collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, and user name or similar identifier.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Characteristic Data includes date of birth and sex.
Commercial Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Organization Data includes your title and the organization you represent.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from personal data about you but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with personal data about you so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.We do not collect any of the following:
Information covered by California Civil Code section 1798.80 except to the extent identified in some category above;
Biometric information;
Audio, visual, thermal, olfactory, or similar information;
Electronic information except to the extent identified in some category above;
Geolocation data, except to the extent that it is Technical Data or Profile Data;
Professional or employment-related information, except for Organization Data;
Education information; or
Information about criminal convictions or offenses.
What happens if you do not provide your personal data?
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will inform you if this is the case at the time.
How does HireRight collect your data?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Financial, , Characteristic, Commercial, Profile, Communications, and Organization Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you do any of the things listed below. Additionally, we may generate Commercial, Profile, Usage, and Communications Data from those interactions:
apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see the section below related to cookies for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources that may be located within the EU, as set out below:
Technical Data from the following parties:
analytics providers, such as Google, based outside the EU;
website personalization providers
advertising networks, such as Double-click, based outside the EU; and
Identity, Contact, and Characteristic Data from the following parties:
search information providers
publicly availably sources
data brokers or aggregators
social media lead generation companies.
lead generation companies
Contact, Financial and Commercial Data from the following parties:
Payment and delivery services
Once collected how does HireRight use personal data?
HireRight collects personal data for various purposes. Most commonly, we will use personal data about you in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
In the USA, in a manner consistent with your consent.
In the next section of this Privacy Notice you will find further information in respect to the circumstances in which we use personal data and the lawful basis we rely upon.Except in the United States, we do not generally rely on consent as a legal basis for processing personal data about you, other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting the email address shown in contact details above.
What information does HireRight process for what lawful basis?
We have set out below, in a table format, a description of all the ways we plan to use personal data about you, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.Note that we may process personal data about you for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us (at the email address shown in contact details above) if you need details about the specific legal ground we are relying on to process personal data about you where more than one ground has been set out in the table below.In the table below, the following terms have the following meanings:Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process personal data about you for our legitimate interests. We do not use personal data about you for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.Comply with a legal or regulatory obligation means processing personal data about you where it is necessary for compliance with a legal or regulatory obligation that we are subject to.Consent means processing personal data about you in accordance with your express, written consent to do so.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
To register you as a new customer | Identity Contact Characteristic Organization | Performance of a contract with you In the USA, consent |
To process and deliver your order including: Manage payments, fees and charges Collect and recover money owed to us | Identity Contact Financial Commercial Communications Organization | Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) In the USA, consent |
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey | Identity Contact Characteristic Profile Usage Communications Organization | Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) In the USA, consent |
To enable you to partake in a prize draw, competition or complete a survey | Identity Contact Characteristic Profile Usage Communications | Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) In the USA, consent |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Contact Technical Organization | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation In the USA, consent |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Identity Contact Characteristic Profile Usage Communications Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) In the USA, consent |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Technical Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) In the USA, consent |
To make suggestions and recommendations to you about goods or services that may be of interest to you | Identity Contact Characteristic Technical Usage Profile | Necessary for our legitimate interests (to develop our products/services and grow our business) In the USA, consent |
How does HireRight control using personal information for marketing purposes?
We provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Characteristic, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share personal data about you with any company outside the HireRight group of companies for marketing purposes.
Opting out
You can ask us or third parties to (a) stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or (b) to update personal data about you that you have provided us by emailing us (at the email address shown in contact details above) at any time.Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the Services you contract us to perform.
California notice
The following is information organized in a way that the California Consumer Privacy Act requires us to supply. It only applies to you if you live in California. This table shows whether, in the 12 months before we posted this Privacy Notice, whether we sold any personal information in the categories below or disclosed it for a business purpose.
Category | Sold? | Disclosed? |
|---|---|---|
Identity Data | No | Yes, to our service providers |
Contact Data | No | Yes, to our service providers |
Financial Data | No | Yes, to our service providers |
Characteristic Data | No | Yes, to our service providers |
Commercial Data | No | Yes, to our service providers |
Technical Data | No | Yes, to our service providers |
Profile Data | No | Yes, to our service providers |
Usage Data | No | Yes, to our service providers |
Communications Data | No | Yes, to our service providers |
Organization Data | No | Yes, to our service providers |
Additionally, California law defines the term “sell” to include any disclosure of personal information in exchange for anything of value. Depending on how this law is interpreted, it could include a situation in which we provide your information to another organization so that it can do something with the information for us. Because we receive the benefit of that processing, which is of value to us, any such relationship might be the sale of personal data. Therefore, we hereby notify you that we may sell personal data about you.
What happens if there is a change in the purpose of processing?
We will only use personal data about you for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by email (at the email address shown in contact details above).If we need to use personal data about you for an unrelated purpose, we will inform you and we will explain the legal basis which allows us to do so.Please note that we may process personal data about you without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Does HireRight disclose personal data to third parties?
We may have to share personal data about you with the parties set out below for the purposes set out in the table above about how we plan to use personal data about you.
Internal parties, meaning other companies in the HireRight Group acting as joint controllers or processors. For further information please see
https://www.hireright.com/contact-us/offices
.
External parties, meaning:
Providers or IT and system administration services based US, Canada, and the EU, acting as processors (under EU, UK, and Swiss law) or service providers (under California law).
Professional advisers (including lawyers, bankers, auditors and insurers) based globally who provide consultancy, banking, legal, insurance, and accounting services, acting as acting as processors or joint controllers (under EU, UK, and Swiss law) or as service providers or third parties (under California law).
Tax authorities, regulators, and other authorities based globally who require reporting of processing activities in certain circumstances, acting as processors or joint controllers (under EU, UK, and Swiss law) or as service providers or third parties (under California law).
Specific third parties or service providers such as DemandDrive lead generation, and carefully selected marketing agencies.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use personal data about you in the same way as set out in this privacy notice.
We employ procedures to require all third parties to respect the security of personal data about you and to treat it in accordance with the law. We do not grant permission for our third-party service providers to use personal data about you for their own purposes and only grant permission for them to process personal data about you for specified purposes and in accordance with our instructions.
Does HireRight provide links to third party websites?
HireRight's web site may provide links to third-party web sites. Please be aware that those third-party web sites are outside of our control and are not covered by this Privacy Notice. If you have questions about how another site uses your information, consult that site's privacy statement.
Does HireRight use cookies?
HireRight's web site may use the standard technology called a "cookie" to collect information about how you use the web site.A cookie is a small data file that is transferred to your hard drive and used for record-keeping purposes. A cookie file can contain information such as the URL you came from, your computer's IP address (i.e., the Internet address of your computer) and domain type (e.g., .com or .org, etc.), your browser type, the country, state and telephone area code where your server is located, the pages of our site that were viewed during a visit, and any search terms that you entered on our site. This information is used for internal purposes only, and we do not link your URL or IP address to any personal information unless you have logged into our web site with a HireRight account login and password. In addition, HireRight’s web site does not allow other parties to collect personally identifiable information about an individual consumer’s online activities over time and across different Web sites when a consumer uses the HireRight web site.If you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies, although it is possible that some areas of our web site will not function properly if you do so. In particular, you may be required to accept cookies in order to complete certain actions on HireRight's web site. HireRight’s web site does not currently recognize “do not track” signals transmitted by web browsers.To find out more, please go to https://www.hireright.com/legal/cookie-policy to view the cookie policy.
What security measures does HireRight use?
HireRight is committed to protecting the personal information that HireRight receives. While we cannot guarantee the security of that information, we utilize a combination of online and offline security technologies, procedures and organizational measures to help safeguard consumer information against loss, misuse, and unauthorized access, disclosure, alteration and destruction.We employ Secure Socket Layer (SSL) data encryption when data is transmitted over the Internet to our web site. We have installed layered firewalls and other security technologies to help prevent unauthorized access to our systems. Strong password protection protocols are used on our employees’ computers, and employees are regularly trained on our security and privacy policies. The servers used to store consumer information are maintained in a secure physical environment with appropriate physical security measures.
Does HireRight transfer personal data within its group companies and outside the European Economic Area (the “EEA”)?
HireRight is a global business providing global services. As such HireRight will share personal data about you within the HireRight Group. This will involve transferring your data outside the EEA.Whenever we transfer personal data about you out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer personal data about you to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see
European Commission: Adequacy of the protection of personal data in non-EU countries
.
Where we use certain service providers or for transfers within the HireRight Group, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see
European Commission: Model contracts for the transfer of personal data to third countries
.
Please contact DPO@Hireright.com if you want further information on the specific mechanism used by us when transferring personal data about you out of the EEA.
How long is personal data retained for?
We will only retain personal data about you for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data about you, the purposes for which we process personal data about you and whether we can achieve those purposes through other means, and the applicable legal requirements.
What are your rights?
Under certain circumstances, you have rights under data protection laws in relation to personal data about you. Please see below for specific rights that may apply to your location.If you wish to exercise any of the rights set out above, please contact us as set out in the contact details above.You will not have to pay a fee to access personal data about you (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive and if the law allows us to do so. Alternatively, we may refuse to comply with your request in these circumstances.We may need to request specific information from you to help us confirm your identity and ensure your right to access personal data about you (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we intend to inform you and keep you updated.
What rights do you have in the European Union, the United Kingdom, and Switzerland?
You have the right to:Request access personal data about you (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.Request erasure of personal data about you. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove personal data about you where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase personal data about you to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.Object to processing of personal data about you where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing personal data about you for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.Request restriction of processing of personal data about you. This enables you to ask us to suspend the processing of personal data about you in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.Request the transfer of personal data about you to you or to a third party. We will provide to you, or a third party you have chosen, personal data about you in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.Withdraw consent at any time where we are relying on consent to process personal data about you. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
What rights do you have in California?
The California Consumer Privacy Act provides you certain rights if you are a California resident. But the CCPA also has exceptions. Generally, our business falls within those exceptions, and the CCPA does not apply. But if you want disclosure or correction of information that we hold about you within these parts of our business (e.g., we did a background check about you), you can still request a disclosure or reinvestigation from us under the federal Fair Credit Reporting Act. For information about that, please refer to our Candidate Notice available at https://www.hireright.com/legal/privacy-policy/us-candidate-policy.You have the following rights if you are a California resident:
You have the right to request us to disclose information that we have collected about you, including the general categories of information, the categories of sources from which we collected the information, the purpose for collecting or selling that information, the categories of third parties with whom we share the information, and the specific pieces of information we have collected.
If we sell personal information or disclose it for a business purpose, you also have the right to request the categories of third parties to whom we sold your information or disclosed your information for a business purpose (by category of personal information in each case).
You have the right to request to opt-out of our sale of personal data about you.
You have the right to be free of retaliation for exercising your rights under the CCPA.
You may make a request by emailing us at HireRightPrivacy@hireright.com.In either case, you must include the following information: your full name; all physical addresses we may have associated with you; all email addresses we may have associated with you; all telephone numbers we may have associated with you; all employers we may have associated with you. If you are requesting that we disclose, correct, or delete specific personal data information to you (as opposed to disclosing categories of personal data), you must also provide a legible image of a government-issued ID. You may hide the identification number and photo from that ID, but you must not hide the name or address shown on it. We will use the information you supply to identify relevant information in our systems. If you want us to disclose the information to an agent, you must say so in writing and provide us with the mailing address of the agent.