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VettFirst Security is committed to protecting the privacy of our clients, of visitors to our Web Site, and of the individuals (“consumers”) with respect to whom we conduct background screens at our clients’ request. As a consumer reporting agency governed by the U.S. federal Fair Credit Reporting Act (“FCRA”), among other applicable laws, VettFirst Security strives to maintain the confidentiality, integrity, and security of personal information that VettFirst Security obtains.

VettFirst Security has joined the U.S. – European Union “Safe Harbor” program and the U.S. – Swiss Safe Harbor Program with respect to personal information collected from consumers who reside in the European Union and Switzerland. VettFirst Security complies with the U.S. – EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as established by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. VettFirst Security adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement as explained more fully in the following policy. To learn more about the Safe Harbor program, and to view VettFirst Security’ certification, please visit the U.S. Department of Commerce’s Safe Harbor Website at http://www.export.gov/safeharbor/.

Notice

VettFirst Security receives personal information about consumers from its clients. VettFirst Security’ clients certify to VettFirst Security that (a) to the extent required by applicable law, they have obtained the consumer’s consent to share this information with VettFirst Security for purposes of conducting a background screen on the consumer, (b) they are requesting a background screen for employment or other purposes permitted under the FCRA or other applicable law, and (c) they will use the results of VettFirst Security’ background screening only for legally permissible purposes, such as hiring, promotion, and discharge decisions.

VettFirst Security conducts background screens only in compliance with the FCRA or other applicable law. Through its background screens, VettFirst Security obtains about a consumer, and provides to its client, information as requested by VettFirst Security’ client and consistent with the consumer’s authorization. The information that is collected about the consumer may include, but may not be limited to, history of arrests and/or convictions, credit history, employment history, educational history, places of residence, and driving records. Pursuant to the terms of its contract with its client, VettFirst Security uses this information to prepare a report that meets its clients’ needs.

VettFirst Security will not use the information collected about a consumer for any other purpose without first giving the consumer an opportunity to opt out from such use. If the information is “sensitive” information as defined in the Safe Harbor Privacy Principles (i.e., personal information specifying medical or health conditions, racial or ethnic origin, political opinions or philosophical beliefs, trade union membership or information concerning the sex life of the individual), VettFirst Security will use the information for an incompatible purpose only if the consumer affirmatively authorized that use.

Choice

VettFirst Security collects information about consumers only if VettFirst Security’ client has, to the extent required by applicable law, certified to VettFirst Security that the consumer has affirmatively consented to such collection. Consumers who do not want VettFirst Security to collect information about them can choose to prevent collection by refusing to sign the notice and authorization form presented by their prospective or current employer in accordance with the FCRA or, if required, by other applicable law. Consumers who wish to revoke their consent to VettFirst Security’ collection of information about them can do so at any time by sending written notification to VettFirst Security at (803) 233-2170 (inside the US and Canada) or to the contact information for VettFirst Security listed on the notice and authorization form signed by the consumer.

The revocation does not mean that information already collected will be erased or deleted. Various laws and compliance obligations require that VettFirst Security maintain the data on file for a period of time. However, the consumer’s data will not be further disclosed after VettFirst Security receives a revocation. After revocation of consent, VettFirst Security also will not use the information for any purpose other than maintaining for compliance purposes an internal record of having performed the background screen as of such date.

Onward Transfer (Transfers to Third Parties)

VettFirst Security generally will disclose the information obtained on a consumer only to (a) the VettFirst Security client whom the consumer has authorized to receive the information (and its designated representatives), and (b) a third-party representative or subcontractor of VettFirst Security authorized to receive such information (e.g., service providers that help host or support VettFirst Security’ web site, or that otherwise provide technical assistance; court researchers; and other providers of professional services). VettFirst Security shares information with these third parties only for the purposes described in the “Notice” section of this Policy.

VettFirst Security takes reasonable steps to safeguard personal information disclosed to its representatives and subcontractors. VettFirst Security will disclose only the minimum personal information necessary to deliver to VettFirst Security (for the benefit of VettFirst Security’ client) the requested product or service. Before making such disclosures, VettFirst Security ascertains that the third-party is subject to the European Union Data Protection Directive or requires by written agreement that the third party provide at least the same level of privacy protections as is required by the relevant Safe Harbor Privacy Principles. In addition, VettFirst Security will disclose consumer information to these third parties only if they will maintain commercially reasonable security measures to protect the confidentiality, integrity and security of that personal information.

VettFirst Security also may in good faith disclose personal information and any other additional information available to VettFirst Security, for any of the following purposes: (i) to investigate, prevent or take action regarding actual or suspected illegal activities or fraud; situations involving potential threats to the physical safety of any person; or violations of VettFirst Security’ terms of use; (ii) to respond to subpoenas, court orders, or other legal process; (iii) to establish or exercise VettFirst Security’ legal rights; or (iv) otherwise to comply with applicable law.

VettFirst Security may acquire other business, and other businesses may acquire VettFirst Security. If that occurs, the information VettFirst Security collects may be one of the assets examined or transferred as part of the transaction. VettFirst Security will not permit another business to examine the information VettFirst Security has collected without a confidentiality agreement and only to the extent permitted by law. VettFirst Security will not transfer the information it has collected unless the recipient agrees to provide privacy protections equal to or exceeding those established by this Privacy Policy.

Access

VettFirst Security permits all consumers to inspect, and/or to receive a copy of, the information that VettFirst Security has collected about them in accordance with the FCRA or other applicable law. Consumers also may request that VettFirst Security correct, amend or delete inaccurate information about them. For security purposes, VettFirst Security will require verification of the consumer’s identity.

Security

VettFirst Security is committed to protecting the personal information that VettFirst Security receives about consumers. 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 Website. 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 computers, and employees are kept up-to-date on our security and privacy policies. The servers used to store consumer information are maintained in a secure environment with appropriate security measures.

Data Integrity

In accordance with applicable law, VettFirst Security takes reasonable steps to ensure that the information VettFirst Security collects is accurate, complete, current, and reliable for its intended use. VettFirst Security cannot be responsible for errors that exist within public court records or within records of other consumer reporting agencies, such as the national credit bureaus, and therefore cannot act as a guarantor of the information. Consumers who wish to dispute the accuracy of information that VettFirst Security maintains about them can do so by calling (803) 233-2170, or by e-mailing VettFirst Security at customerservice@selectdatasolutionsllc.com. For security purposes, VettFirst Security will require verification of the consumer’s identity.

Enforcement

VettFirst Security conducts in-house verification of its compliance with the Safe Harbor Privacy Principles. You can submit a complaint directly to VettFirst Security about its privacy practices by contacting (803) 233-2170.

In compliance with the US-EU and US-Swiss Safe Harbor Principles, VettFirst Security commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact VettFirst Security at (803) 233-2170.

VettFirst Security has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the American Arbitration Association.

If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by VettFirst Security, please visit the American Arbitration Association web site at www.adr.org for more information and to file a complaint.

Complaints involving human resources data as defined by the Safe Harbor may alternatively be submitted to the European Union Data Protection Authorities.

Contact Information

If you have any questions regarding our privacy policy, please contact us at:
VettFirst Security, Inc.
2712 Middleburg, Dr. Suite 224.
Columbia, SC 29204
Attn: Privacy Officer
Effective Date: November 8, 2015

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