This Privacy Policy covers Global Investigative Services, Inc. (Global) web site, and Global’s practices for handling personal information provided to Global over the Internet by the general public using Global’s publicly available web site. This Policy also covers personal information provided by Global’s clients, and their job applicants and employees (as well as other individuals who have given their written authorization for Global’s clients to conduct a background investigation on them), using Global’s online background screening solution that is accessible only through an access-restricted portion of Global’s web site. Global will collect, store, and use personally identifiable information only in compliance with applicable law, including the FCRA.

Collection and Use of Information

Global is a consumer reporting agency. It is required by the Fair Credit Reporting Act, 15 U.S.C. §1681 et seq. (“FCRA”) to maintain the confidentiality of all consumer information.

Global obtains information on an individual consumer only upon the request of a user who has a permissible purpose under the FCRA to request information on that consumer in order to provide consumer reports. The FCRA requires a user for employment purposes to certify to Global that it has a permissible purpose for the report and has obtained the written consent of the consumer to request information before Global can supply the requested information. The user must submit to reasonable audits by Global to confirm that it is, in fact, obtaining such consents. All users must certify that they have a permissible purpose to request a report such as credit, insurance, and renting an apartment.  Our customers agree to keep your information confidential and secure.

Global does not maintain a commercial database of consumer information.

Personal Information Disclosure, United States or overseas.  We do not send consumer information outside of the United States or its territories for any purpose other than to deliver a report to an end user.  Of course, if information is sought from outside of the United States, the information is gathered in that country and then transmitted to us here in the United States where it is treated as any other consumer information.

Any information gathered on any consumer may only be provided to the user authorized by the consumer or permitted by the FCRA or similar state law to receive the information.  We cannot and do not share, sell or distribute consumer information with or to any third party other than the requesting party thereof.  Any consumer, upon proper identification, has the right under the FCRA to request us to furnish to the consumer any and all information we may have on that consumer.   The consumer has the right to dispute the accuracy or completeness of any information contained in the consumer’s file.

However, we may be required, upon receipt of a court order to release the information in civil litigation, or as otherwise required by law, to disclose information regarding a consumer to law enforcement agencies.

If you have any questions regarding our policy, you may contact our Chief Policy Officer at:

Email: privacy@gispi.com
Telephone: 800-589-6595
Mailing Address: 1700 Rockville Pike, Suite 230, Rockville, MD 20852

Global cannot and does not share, sell or distribute consumer information with or to any third party other than the requesting party thereof. Any consumer, upon proper identification, has the right under the FCRA to request that Global furnish to the consumer any and all information it may have on that consumer. The consumer has the right to dispute the accuracy or completeness of any information contained in the consumer’s file. The consumer’s rights under the FCRA may be obtained by contacting Global or going to the CFPB website at: http://files.consumerfinance.gov/f/201410_cfpb_summary_your-rights-under-fcra.pdf. However, Global may be required, upon receipt of a court order to release the information in civil litigation or as otherwise required by law, to disclose information regarding a consumer to law enforcement agencies.

Other privacy initiatives and procedures include, but are not limited to:

● Access to confidential consumer information is limited within Global to those who have a need to know the information: obtaining and transmitting information on the consumer or those dealing with a consumer request for information or consumer disputes.

● Global’s computer terminals, file cabinets, fax machines, trash bins, desktops, etc. are secure from unauthorized access.

● Global maintains a secure network to safeguard consumer information from internal and external threats.

● Any backup data is maintained in an encrypted form.

● Global maintains records on all requests for information and identifies each user who requested information on a consumer.

● Employees are prohibited from “browsing” files or databases without a business justification.

● Destruction of consumer information follows the Federal Trade Commission’s requirements that the information be unreadable upon disposal.

Internet Information

When you visit Global’s web site, we may collect general Internet data, including your domain name, the web page from which you entered our site, which of our web pages you visited, and how long you spend on each page. To collect this information, when you visit our Web Site, a “cookie” may be set on your computer. Cookies contain information that allows our web servers to recognize you whenever you visit. We utilize cookies to record session information, passwords, and the profile of subscribed clients at a site in order to provide better service when visitors return to our site. We use the information we collect to study how this site is used, so that we may improve and enhance your experience on our web site. We also use persistent cookies. A persistent cookie remains on your computer after you close your browser or turn off your computer.

If you reject cookies, you may still use our site, 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 Global’s web site. We do not provide this information to outside parties other than for such reasons. No personal information is stored in cookies.

The use of cookies by our service providers is not covered by our privacy policy. We do not have access or control over these cookies. Our service providers and partners use session ID and persistent cookies to make it easier for you to navigate our site.

Information You Provide

When you provide information through this web site, we use it only for the business transaction for which it was collected. Based on the nature of your transaction with us, you may provide to us certain personal information such as first and last name; home address, or other physical address; an email address (so we may contact you); a telephone number; a social security number; or certain other information, such as date of birth, employment information, schools attended, licenses held and other information as required to process your transaction collectively. In general, we will use the information collected from you for the purpose for which you provided such information. We will not release your information to third parties except as necessary for us to process your transaction.

Information Sharing

We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell your personal information to third parties.

We may provide your personal information to companies that provide services to help us with our business activities such as criminal searches and employment verification. These companies are authorized to use your personal information only as necessary to provide these services to us.

We may also disclose your personal information:

• as required by law, such as to comply with a subpoena, or similar legal process

• when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request

• if Global is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information,

• to any other third party with your prior consent to do so

User Access and Choice

If your personal information changes, or if you no longer desire our newsletters or similar marketing services, you may correct, update, amend or delete/remove it by making the change on our member information page or by contacting us by email, telephone or postal mail at the contact information listed below. We will respond to your request to access within 30 days.

Global will retain your information for as long as your account is active or as needed to provide you our marketing services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Protection of Your Information

We maintain physical, electronic, and procedural safeguards to guard the information you provide to us. Our products and/or services online are transmitted through a secured socket layer (SSL) transmission. Further, we have security protocols and measures in place to protect the PII we maintain about you from unauthorized access or alteration. These measures include internal and external firewalls, physical security and technological security measures, and encryption of certain information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us by emailing, calling, or writing to us at the address below.

Personal Information Disclosure: United States or Overseas

Personal information submitted to Global for a background screening investigation may at times be transferred outside of the United States in order to perform the background investigation specifically when Global is attempting to verify your credentials or professional history during times you were in another country outside of the United States. All personal information will be transmitted and stored in a secure manner in accordance with the terms of this Privacy Policy.

Links to 3rd Party Sites

Our Site includes links to other Web sites whose privacy practices may differ from those of Global. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

Changes to This Policy

Global may revise or update this privacy policy on occasion if to reflect changes to our practices. If we make any material changes we will provide notification through the Company’s website prior to the change taking effect. You should refer back to this page for the latest information and the effective date of any changes.

Information Related to Data Collected through Global Investigative Services, Inc.

Global collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes.

Service Provider, Sub-Processors/Onward Transfer

Global may transfer personal information to companies that help us provide our services. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients

Access to Data Controlled by our Clients

Global has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Global’s Client (the data controller). If the Client requests Global to remove the data related to our marketing services and/or newsletters, we will respond to their request within 30 business days.

Data Retention

Global will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Global will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

PRIVACY SHIELD PROVISIONS OF OUR PRIVACY POLICY

Global Investigative Services, Inc. is committed to protecting the privacy of personal data that is gathered and maintained on behalf of employers requesting consumer data inquiries. Global Investigative Services, Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We certify that we comply with the EU-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 European Union to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principals. To learn more about the Privacy Shield program, and to view Global Investigative Services, Inc.’s certification, please visit http://www.privacyshield.gov//.

Global Investigative Services, Inc. also complies with the European Union General Data Protection Regulation.

Global Investigative Services, Inc. has certified that we adhere to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement, as well as supplemental principals.

1. Notice

Prior to having Global Investigative Services, Inc. conduct employment screening on a consumer, it is always disclosed to the consumer (as prescribed by the Fair Credit Reporting Act, hereinafter “FCRA”) that the information they provided will be used to conduct employment screening for the employer desiring to use it for employment related decisions (to determine eligibility to hire, retain, promote, or reassign). Global Investigative Services, Inc. contact information is included on the authorization form in the event the consumer has any inquiries or complaints. Global Investigative Services, Inc. collects information on individuals for the purpose of providing the information to employers for employment related decisions. Employers may also use this information to conduct employee investigations where an employer has a suspicion of work related misconduct or wrongdoing. The Human Resources and Security professionals within the employer organization will also use this information. Prior to receiving information from Global Investigative Services, Inc. and in accordance with the FCRA, each employer must provide a certification to Global Investigative Services, Inc. that it will only use Global Investigative Services, Inc. services for employment purposes or other permissible purpose under the FCRA and that it will comply with all applicable state and federal regulations and obligations.

2. Choice (Opt-out of Sensitive Information)

Global Investigative Services, Inc. affords individuals the opportunity to choose whether their personal information will be disclosed to a third party or will be used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by the individual. Therefore, consumer data may be disseminated under these circumstances unless the consumer explicitly “opts-out.” Where a consumer chooses to “opt-out,” the data is not necessarily erased or deleted. Various laws require that the data be maintained on file for a specified period of time for consumer protection purposes.

A consumer can “opt-out” by contacting Global Investigative Services, Inc. in writing or by e-mail at the addresses listed below.
With respect to sensitive information, however, an individual must “opt-in” to the disclosure of the information to a third party or to the use of this information for a purpose other than its original purpose or that purpose authorized subsequently by the individual. In other words, unless a consumer chooses to provide explicit consent, a disclosure of sensitive information to a third party or for an unauthorized purpose will not be made.

3. Onward Transfer (Transfers to Third Parties)

The information obtained by Global Investigative Services, Inc. is forwarded only to an entity that has been specifically authorized by the consumer to receive the data and only for the purpose described in the section under “Notice.” Global Investigative Services, Inc. takes reasonable steps to ensure that any party that receives information will maintain and protect the privacy and confidentiality of the information. (See the certification portion described in the section under “Notice.”) Any third party that receives information from Global Investigative Services, Inc. has obtained written authorization from the consumer and has disclosed to the consumer the purpose of collecting this data. In addition, each client certifies they will comply with the confidentiality clause in our Service Agreement and is given a copy of the FTC’s Notice to Users, which outlines their obligations with respect to the use of this information.

4. Security

Global Investigative Services, Inc. takes all reasonable procedures to protect personal and identifiable information from loss, misuse and unauthorized access, disclosure, alteration and destruction. The service utilizes SSL encryption to protect sensitive information online; we also do everything in our power to protect user-information off-line. All of our users’ information, not just the sensitive information mentioned above, is kept strictly confidential in our offices. Only employees who need the information to perform a specific job are granted access to personally identifiable information. Strong password protection protocols are used on all computers. Furthermore, all employees are kept up-to-date on our security and privacy practices. Finally, the servers that are used to store personally identifiable information are kept in a secure environment, with appropriate security measures.

5. Data Integrity

Global Investigative Services, Inc. takes reasonable steps to ensure that data collected is accurate, complete, current, and reliable for its intended use. We only collect data that is strictly necessary for the purposes listed under the section entitled “Notice,” including (but not limited to) information that is necessary to identify the consumer.

6. Access

A consumer may request, in writing, access to all data collected and maintained about him or her. Global Investigative Services, Inc. affords the consumer a reasonable opportunity to correct, amend, or delete information that is inaccurate or incomplete, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated.

Pursuant to the United States federal Fair Credit Reporting Act, any citizen of the United States may obtain a copy of their consumer report free of charge. Global Investigative Services, Inc. reserves the right to engage in reasonable efforts to confirm the identity of the individual requesting the data to ensure the information is provided only to the subject of the data.

Global Investigative Services, Inc. makes every effort to ensure that the data we collect and store is as accurate as possible. We cannot guarantee, however, that third parties are committed to making the same efforts, and therefore, we deny any responsibility for the accuracy of the data they provide.

7. Recourse, Enforcement and Liability

In compliance with EU-US Privacy Shield Principles, Global investigative Services, Inc. commits to resolve consumer complaints about our privacy and our collection or use of your personal information by means of in-house verification by the management of this company. In addition, we provide an independent recourse mechanism by which an individual’s complaints and disputes are investigated and resolved. EU individuals with complaints and inquiries regarding this privacy policy should first contact Global Investigative Services, Inc. at the following:

Global Investigative Services, Inc.
1700 Rockville Pike, Suite 230
Rockville, MD 20852
301.589.0088
Email: privacy@gispi.com
Website: www.gispi.com

In the case, Global Investigative Services, Inc. processes human resources data concerning residents in the European Economic Area, we fully commit to cooperation with the countries’ Data Protection Authorities (DPA’s).

Therefore, if Global Investigative Services, Inc. is unable to satisfactorily resolve a question or complaint regarding our privacy practices, you may raise your concern to the attention of your DPA, which will establish a panel to investigate and resolve complaints brought under the Privacy Shield. Global Investigative Services, Inc. will fully comply with the advice given by data protection authorities and take necessary steps to remediate any non-compliance with the Privacy Shield Principles. To this end, Global Investigative Services, Inc. has engaged the United States Council for International Business (http://www.uscib.org/privacy-shield/) to act as a trusted third party dispute resolution provider to cover any operating costs should an individual bring a complaint to the EU Data Protection Authorities.

Many countries around the world have laws to protect ‘personal data’; that is, information about identified or identifiable individuals. In the course of researching and verifying information from the sources described above, Global Investigative Services, Inc. and any of its agents will process personal data, some of which may have a high degree of sensitivity. However, both Global Investigative Services, Inc. and any of its agents, are familiar with and make every effort to comply with all applicable data privacy laws, including, in particular, the European Union’s General Data Protection Regulation (‘GDPR’).

Global Investigative Services, Inc. is an independent data processor and any of its agents are either independent data processors or data controllers (not joint processors or controllers), each with their own respective legal responsibilities with respect to their processing of personal data.

As described above, Global Investigative Services, Inc. and any of its agents will process personal data for pre-employment background screening and related purposes. The report produced by Global Investigative Services, Inc. and any of its agents will generally contain personal data about the subject, and it is shared with the client also known as the end user and controller.

For the purposes of GDPR, Global Investigative Services, Inc. and any of its agents process personal data on the basis that it is necessary for the purposes of the legitimate interests pursued by the client, Global Investigative Services, Inc. and any of its agents. The legitimate interests of Global Investigative Services, Inc. and any of its agents include the provision of a pre-employment background checking services to commercial organizations to ensure the suitability, integrity and reliability of individuals such organizations wish to employ in positions of responsibility where such personal qualities are important.

Global’s Information Security Policy is in line with our industry standards and has been evaluated and approved during our accreditation process. Our policy describes some of the specific data security controls that Global has implemented and, by publishing the information, legally obligates us to maintain the high standard of data security that’s described in the Policy.

Our Information Security Policy can be found here /information-security-policy

Furthermore, Global Investigative Services, Inc. is governed by FCRA regulations as enforced by the Consumer Financial Protection Bureau. Global Investigative Services, Inc. is a member of the National Association of Professional Background Screeners and strictly adheres to its professional standards, code of conduct, ethical business practices, and its promotion of compliance with the Fair Credit Reporting Act.

Global Investigative Services, Inc reserves the right to change their policy from time to time, consistent with the Privacy Shield Principles