Western Reporting Background Screening Services

Detailed Privacy Policy

Scope and Application

The ten principles that form the basis of The WESTERN REPORTING Privacy Policy are interrelated and WESTERN REPORTING shall adhere to the ten principles as a whole. Each principle must be read and understood by each Customer Service Representative employed by WESTERN REPORTING. The commentary in The WESTERN REPORTING Privacy Policy has been drafted to reflect personal information issues specific to WESTERN REPORTING.
The scope and application of The WESTERN REPORTING Privacy Policy are as follows:
  • The WESTERN REPORTING Privacy Policy applies to personal information collected, used, or disclosed by WESTERN REPORTING in the course of commercial activities.
  • The WESTERN REPORTING Privacy Policy applies to the management of personal information in any form whether oral, electronic or written.
  • The WESTERN REPORTING Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by WESTERN REPORTING :
  • non-personally identifiable information;
  • the name, title, business address and/or telephone number of an employee of an organization;
  • other information about an individual that is publicly available.
  • The application of The WESTERN REPORTING Privacy Policy is subject to the requirements and provisions of the Fair Credit Reporting Act

Definitions

Scope and Application

collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

Consent:

Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of WESTERN REPORTING . Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.

Disclosure:

Making personal information available to a third party.

Employee:

An employee of or independent contractor to WESTERN REPORTING.

Personal Information:

Information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization, and does not include descriptive, factual information about an organization.

Respondent:

A member of the public who provides personal information to WESTERN REPORTING in the course of a survey conducted by WESTERN REPORTING.
For example, a respondent is an individual who discloses personal information to WESTERN REPORTING in the course of a residential, employment or personal reference.

Third Party:

An individual or organization outside of WESTERN REPORTING.

use:

The treatment, handling, and management of personal information by and within WESTERN REPORTING or by a third party with the knowledge and approval of WESTERN REPORTING.

The Ten Principles of Privacy

Principle 1 - Accountability
WESTERN REPORTING is responsible for personal information under its control and shall designate one or more persons who are accountable for WESTERN REPORTING’s compliance with the following principles.

Responsibility for compliance with the provisions of the WESTERN REPORTING Privacy Policy rests with the WESTERN REPORTING Privacy Officer who can be reached by e-mail at customerservice@westernreporting.com or by mail at 8789 S. Highland Dr. Ste. #300 Sandy, UT 84093. Other individuals within WESTERN REPORTING may be delegated to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.

WESTERN REPORTING is responsible for personal information in its possession or control and shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.

Principle 2 - Identifying Purposes for Collection of Personal Information
WESTERN REPORTING shall identify the purposes for which personal information is collected at or before the time the information is collected.

WESTERN REPORTING collects personal information from the public only for the following purposes:

to complete a transaction initiated by the consumer.
to understand respondent opinions to establish suitability for tenancy or employment.
to meet legal and regulatory requirements.

Further reference to “identified purposes” mean the purposes identified in this Principle.

WESTERN REPORTING shall specify orally, electronically or in writing the identified purposes to the respondent at or before the time personal information is collected in a survey. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within WESTERN REPORTING who can explain the purposes. An applicant signed release will also be provided upon request.
When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the respondent will be acquired before the information will be used or disclosed for the new purpose.

WESTERN REPORTING may provide affiliates or other third parties with information from an applicant for these purposes:

(a) Credit Reports
(b) Criminal Reports
(c) DMV Reports
(d) Drug Testing
(e) I-9 Reports

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, for pre employment use. Knowledge and consent of an individual is also required before collecting any financial data. The gathering of criminal data for non employment use does not require a signed consent.
Principle 4 - Limiting Collection of Personal Information
WESTERN REPORTING shall limit the collection of personal information to that which is necessary for the purposes identified by WESTERN REPORTING. WESTERN REPORTING shall collect personal information by fair and lawful means.

WESTERN REPORTING collects personal information about an individual only if individuals have consented to such collection and only from those sources provided by the individual.

Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information
WESTERN REPORTING shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

WESTERN REPORTING may disclose a respondent’s personal information to:

client of WESTERN REPORTING where the respondent has consented to such disclosure;

a third party engaged by WESTERN REPORTING to perform functions on its behalf;

a public authority or agent of a public authority if, in the reasonable judgment of WESTERN REPORTING , it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or
a third party or parties, where the respondent consents to such disclosure or disclosure is required or permitted by law.

Only WESTERN REPORTING’s employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about respondents.

WESTERN REPORTING shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where a respondent may have to be re-contacted for purposes of clarifying responses to a survey, or to seek additional responses, WESTERN REPORTING shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.

WESTERN REPORTING shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Principle 6 - Accuracy of Personal Information
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Personal information used by WESTERN REPORTING shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a respondent.

WESTERN REPORTING shall update personal information about respondents and employees as necessary to fulfill the identified purposes or upon notification by the individual.

Principle 7 - Security Safeguards
WESTERN REPORTING shall protect personal information by security safeguards appropriate to the sensitivity of the information.

WESTERN REPORTING shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.

WESTERN REPORTING shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

All of WESTERN REPORTING’s employees with access to personal information shall be required to respect the confidentiality of that information.

WESTERN REPORTING makes use of Secure Socket Layer (SSL) encryption as well as password protected identifying information. In addition safeguards are taken to insure that information stored by computers, servers, and databases are protected by secure firewall technology, and the highest level of encryption.

Principle 8 - Openness Concerning Policies and Procedures
WESTERN REPORTING shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.

WESTERN REPORTING shall make information about its policies and procedures easy to understand, including:

the title and address of the person or persons accountable for WESTERN REPORTING ’s compliance with its Privacy Policy and to whom inquiries and/or complaints can be forwarded;
the means of gaining access to personal information held by WESTERN REPORTING ;
a description of the type of personal information held by WESTERN REPORTING , including a general account of its use; and
a description of what personal information is made available to related organizations (e.g. subsidiaries).

Principle 9 – Individual Access to Personal Information
Upon request, WESTERN REPORTING shall inform an individual of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate. A summary of major rights under the FWESTERN REPORTING is available upon request.

Upon written request to the Privacy Officer, WESTERN REPORTING will inform an individual of the existence, use and disclosure of his/her personal information and shall be given access to that information.

In certain situations, WESTERN REPORTING may not be able to provide access to all the personal information that it holds about a respondent. For example, WESTERN REPORTING may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, WESTERN REPORTING may not provide access to information if disclosure would reveal confidential commercial information.

Principle 10 - Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for WESTERN REPORTING’s compliance with the WESTERN REPORTING Privacy Policy.

WESTERN REPORTING shall maintain procedures for addressing and responding to all inquiries or complaints from its respondents regarding WESTERN REPORTING’s handling of personal information.

WESTERN REPORTING shall, on written request, inform its respondents about the existence of these procedures as well as the availability of complaint procedures.
The person or persons accountable for compliance with the WESTERN REPORTING Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

WESTERN REPORTING shall investigate all complaints concerning compliance with its Privacy Policy. If a complaint is found to be justified, WESTERN REPORTING shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. The respondent shall be informed of the outcome of the investigation regarding his or her complaint.

For more information regarding the WESTERN REPORTING Privacy Policy, please contact the WESTERN REPORTING Privacy Officer by email at customerservice@westermreporting.com or by mail at 8789 S. Highland Dr. Ste. #300 Sandy, UT 84093.

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