First Advantage Beijing and First Advantage Zhuhai (“FA,” “our”, “us” or “we”) provide background screening services for the purposes of and at the direction of their clients to assist them in considering individuals for employment, changes in the level of responsibility and other circumstances where an employee or prospective employee’s background is relevant.
This policy outlines FA’s personal information handling practices. If you reside in the People’s Republic of China (“China”), the following provisions provide additional information in relation to applicable data privacy laws in China (including the Personal Information Protection Law of China (“PIPL”)).
Types of personal information we collect
Under the PIPL, “personal information” means any information, whether recorded in electronic or another format, that relates to an identified or identifiable natural person, excluding anonymised information. “Sensitive personal information ” means personal information that, if leaked or if used illegally, is likely to cause harm to a natural person’s personal dignity or endanger his or her personal safety or the safety of his or her property.
We collect different types of personal information depending on how you interact with us. If we are conducting background screening, the personal information we collect will depend on the type of background screening we are performing and the location where you live. The kinds of personal information that we collect about you may include:
- Identifying information – such as your name, gender, photograph and date of birth.
- Contact information – such as your postal address, email address and telephone number.
- Background-check information – such as your employment history, reference information, education, professional qualifications, residency, immigration status, claims, judgments, insolvency, current and previous directorships, character and personal reputation (including social media information).
- Usage information – information we collect when you use our website, such as server log information (your IP address, browser type, operating system, browser language, time zone, access times and any referring addresses).
- Other information – this includes information about any products or services that we provide using your information, communications with you (including any messages you send us) and other information you voluntarily provide to us.
FA may collect your sensitive personal information, such as:
- Financial information – such as credit card, bank account or other payment details.
- Background-check information – such as sanctions, criminal records, and medical assessments.
How we collect your personal informationWe collect personal information about you:
- directly from you, including as part of background screening, when you submit a query or request to us or when you apply for a job with us;
- from our clients, including where we are engaged to periodically screen a client’s employees or contractors;
- when we are engaged to provide background screening services:
- from third parties who are entitled to disclose that information to us, such as government agencies, law enforcement bodies, publicly available records, public registries, court or tribunal records, insolvency registers, educational institutions, current and/or previous employers, regulatory and licensing bodies and medical assessment providers; and
- from public sources, such as social media and through search engine searches; and
- by tracking your use of our website.
How we use your personal information
We collect and process your personal information, including sensitive personal information, only for the following purposes (and to the extent directly relevant to the purposes of processing):
- to verify your identity when you are dealing with us;
- to enable us to provide our products and services to you or one of our clients, including our background screening services;
- to answer your queries and requests;
- to comply with our legal and regulatory obligations;
- to assess, maintain, upgrade and improve our products and services;
- to carry out education and training programs for our staff;
- to manage and resolve any legal or commercial complaints or issues; and
- to keep you informed about our activities, including by sending out newsletters.
Subject to your consent, we may from time to time use your personal information in order to send you marketing materials about products or services that we think you may be interested in (including in some cases products and services that are provided by a third party). You can opt-out of receiving marketing communications from us by contacting us at firstname.lastname@example.org or following the “unsubscribe” link in the communication.
We may also use your information for other purposes if you ask or tell us to do so.
If the purposes are modified, FA will take the necessary measures as required by applicable laws, including obtaining separate consent.
We may process your personal information for the purposes set out above if one of the following applies:
- with your prior consent to the processing for one or more specific purposes as set out in the above;
- processing of your personal information is necessary to conclude or perform a contract to which you are a party;
- processing is necessary for compliance with any statutory duties or legal obligations;
- processing is necessary in order to, in an emergency, to protect the lives, health or property of natural persons;
- your personal information has been made public by you or has otherwise been lawfully made public, the processing is done pursuant to the PIPL and the extent the processing is reasonable; or
- the processing is done in other circumstances provided for in applicable laws or administrative regulations.
Who we share your personal information with
We may share personal information about you with:
- our clients when we report back to them after we complete a background check on you;
- your representatives, advisers and others you have authorised to interact with us on your behalf;
- our staff who need the information to discharge their duties;
- related entities within our corporate group;
- our business partners, agents and service providers;
- prospective purchasers of all or part of our business or shares in our company or a related entity;
- professional advisers who we engage to provide advice on our business;
- government authorities who ask us to disclose that information, or to other people as required by law; and
- third parties who we use to help us provide our background screening services, such as government agencies, law enforcement bodies, educational institutions, current and/or previous employers and medical assessment providers
Before sharing your personal information with any such recipients, we will, where required by applicable law, notify you of the name and contact details of the recipients, the purposes and means of processing and provision of the personal information, and the types of personal information to be provided and shared, and, where required by applicable law, obtain your prior consent to the sharing of personal information.
To the extent that we share your personal information with any recipient that is based outside of China, we will obtain your prior consent before sharing such personal information.
We will only share and transfer your personal information for specific and definite purposes pursuant to the principles of lawfulness, fairness, necessity and good faith, and only share and transfer the personal information to the extent necessary for the specific purposes you are informed of.
Please contact us using the contact details set out below for a complete list of: (a) our affiliates and subsidiaries that may process your personal information (as well as more related details); and (b) third party suppliers and vendors that may process your personal information (as well as more related details).
How we store and protect your personal information
We use various secure computer systems located both within and outside of China to store your personal information. Our employees located outside China may undertake various components of background checks. As a result, we may transfer your personal information to our affiliates located in countries including Australia, Canada, India, the Netherlands, New Zealand, the Philippines, the USA or the UK.
We retain personal information only as long as it is required and in conformance with our client’s requirements. Our client, as the personal information processor, determines the data retention period. Certain legal requirements and/or government bodies may also require us to retain your personal information for a minimum or maximum period of time. In the absence of such predefined periods and unless otherwise prohibited by applicable law, we will delete your personal information two years from the date of completion of the background screening check.
We store personal information for as long as it is needed for the purpose for which it was collected, or as required by law. We generally store the personal information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers. Sometimes we also keep hard copy records of this personal information in physical storage facilities. We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats.
Please contact FA for a complete list of: (a) our affiliates and subsidiaries that may process your personal information (as well as more related details); and (b) third party suppliers and vendors that may process your personal information (as well as more related details).
We ensure that our staff are aware of and properly trained in their obligations for managing your privacy. We limit access to personal information to those of our employees who require access in order to carry out their job responsibilities.
The PIPL provides certain rights to individuals based in China. These include rights of: knowing about and deciding on the processing of your personal information; access to and making copy of your personal information; correction and supplement of inaccurate or incomplete personal information; portability; withdrawal of consent with future effect; deletion; and requesting explanations of the rules governing the processing of your personal information.
You can make exercise your rights by contacting us below.
How you can contact us
If you have questions or concerns about FA’s privacy practices or to exercise any of your rights and choices as described in this policy, please contact us at email@example.com.
Changes to this Additional Information Notice
We may change this policy from time to time as described in this section so it accurately reflects our practices and legal requirements. You should check back regularly to stay informed of our privacy practices. When making any such changes, we will, if required by applicable law, notify you of such changes and obtain your prior consent.