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PRIVACY POLICY - SCREENING SERVICES

This policy outlines how Paragon Human Resources & Recruitment (“Paragon”) processes your personal data.

Paragon is required under data protection legislation to notify you of the information contained in this privacy notice.  We may update this notice at any time.

WHY DO WE COLLECT PERSONAL INFORMATION?

We will use your personal data that you supply to us, including sensitive data, solely for the purpose of providing background screening services on behalf of our clients (your employer).

Paragon processes your personal data on the basis of our client’s (your employer) legitimate interest, that it is necessary for progressing the above purpose and the performance of any resulting contract, and also due to Paragon’s legal obligations.

WHAT INFORMATION IS COLLECTED?

Type of Information

Reason for Collection

Source(s)

Name(s)

(current and former)

This is how we identify you. If we do not know who you are, we cannot provide services. Former names may be needed to conduct a complete background check, as old records may be held under a former name.

  • You or our client
  • Credit/consumer reporting agencies
  • Third parties that we contact in the course of performing services

Date of birth*

Along with your name, this serves to identify you as a unique individual, and is often required to perform services.

  • You or our client
  • Third parties that we contact in the course of performing services

Place of birth*

Some services require a place of birth to complete.

  • You or our client
  • Third parties that we contact in the course of performing services

Marital status

Credit check services require this information to complete.

  • You or our client
  • Third parties that we contact in the course of performing services

Contact information

In most cases, we need to know how to get in touch with you. This includes your email address and telephone number. We will only use these to provide screening services and comply with our client’s instructions and our legal obligations. We will not contact you for any other reason.

  • You or our client
  • Third parties that we contact in the course of performing services

Address history

Criminal record and credit check services require several years of address history to complete.

  • You or our client
  • Credit/consumer reporting agencies
  • Third parties that we contact in the course of performing services

Documents to prove identity or address

We may be asked by our client to verify your identity, or we may be required to do so to complete services. If so, we may collect passports or other documents you provide.

  • You or our client
  • Third parties that we contact in the course of performing services

Criminal history and police records*

Some clients wish to review criminal history as part of their screening programme.

  • You or our client
  • Third parties that we contact in the course of performing services
  • Law enforcement or other government agencies

Credit or
bankruptcy history*

Some clients wish to obtain financial or identity information found in a credit file with a credit bureau.

  • You or our client
  • Credit/consumer reporting agencies
  • Government agencies
  • Third parties that we contact in the course of performing services

Employment history

Some clients wish to verify employment or activity history over a certain period of time.

  • You or our client
  • Your current or past employers or their record keeping service providers
  • Employment agencies that placed you with your current or past employers
  • References you have provided

Education history

Some clients wish to verify education or activity history over a certain period of time.

  • You or our client
  • Educational institutions you have attended or their recordkeeping service providers
  • Government education authorities in jurisdictions where you have attended school
  • Third parties that we contact in the course of performing services
  • References you have provided

Professional credentials, designations, memberships, sanctions or reprimands

Some clients wish to verify standing as a certain type of professional participation or completion of professional development courses, or the existence of professional sanctions or reprimands.

  • You or our client
  • Professional organisations with which you have been associated, or their record keeping service providers
  • References you have provided

Appearance on government watch or sanctions lists*

Some clients wish to check for presence on government watch or sanctions lists.

  • Third parties that we contact in the course of performing services
  • Law enforcement or other government agencies

 

*Items marked with an asterisk may be considered sensitive or may be subject to special protections in some places. They will not be collected in every case. They will not be collect where prohibited by law, and where permitted, they will only be collected and used in accordance with applicable law.

RETAINING YOUR DATA

We keep personal information collected from or on behalf of a client for as long as the client asks us to keep it, or as long as we need to keep it to comply with our legal obligations. To understand how long we will store your information, please contact us or the client on whose behalf we collect it. We do not delete personal information unless instructed to do so by our client.

We hold your personal data in a combination of secure computer storage facilities and paper-based files with appropriate levels of security against unauthorised or unlawful access/ processing.

SAFEGUARDING THE SHARING OF PERSONAL DATA

The pre-employment screening services we provide require us to find out or validate your personal information with third party sources to allow the third party to find records about you. Recipients could include; Paragon and client technology providers, credit checking agencies, government bodies and third parties that you provide us, such as your referees.

We generally provide the information required by the third party in the format and through the transmission method of the third party’s choosing. This may involve transmitting information through a website, phone call, email, fax, letter or in person.

When we provide services to a client, we transmit personal information back to that client. This is done through our secure EEA-based web platforms and occasionally by phone, email, fax or mail. Paragon ensures technical and organisational measures to safeguard your data.

Your personal data will be mainly processed by Paragon within the European Economic Area (EEA). Some client processes may require information to be transferred to and processed in countries outside the EEA only where they are necessary as part of our services, i.e. places where you have previously lived/ studied/ worked, where permitted by law.

Paragon do not share any information collected other than as previously stated.

KNOW YOUR RIGHTS

Under certain circumstances, by law you have the right to:

Request a copy of the information that we hold about you.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.   In the instance such data has been provided by a third party, we will provide you with the contact details to directly request correction.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing of your personal information.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party.

You have the right to notify the Isle of Man Information Commissioner of any complaints.

HOW TO CONTACT PARAGON

Please contact us if you have any queries regarding this policy. You can reach us via our client (your employer), or directly by sending an email to hello@paragon.co.im or by writing to us at St Georges Chambers, 1 Hill Street, Douglas, Isle of Man, IM1 1EF.

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