Privacy Policy


Last updated: April 2025
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I. NOTICE STATEMENT

A. Overview

ISB Global Services (“ISB Global Services”, “we”, “ours, “us”) is committed to respecting your privacy and protecting your personal information, which is why we have implemented a privacy program and appointed a Privacy Officer.

The purpose of this Notice is to inform you of how we collect, use, disclose, retain, share and protect your personal information, and how you can contact us if you have queries about our management of your personal information.

To provide you and our end clients (including, without being limited to prospective and current employers, insurers, and insurance agencies, each a “End Client”) with quality services, including background check services, insurance services, and other products and services described on our website (the “Services”) we need to have access to certain personal information about you. We make sure that our employees and subcontractors manage this information with all the necessary discretion and diligence in compliance with the legal and regulatory requirements in force.

By engaging us to provide Services, by completing and submitting a consent form for the release of your personal information (a “Consent Form”) or by otherwise submitting personal information to us in a manner compliant with applicable laws and regulations, you accept the terms of this Notice, and consent to our use, collection, disclosure and retention of personal information as described in this Notice.

B. Compliance with legal obligations

Canada:

We respect the privacy of all individuals who provide personal information to us. We are committed to complying with the applicable privacy legislation in each jurisdiction where we do business. In Canada, this includes the federal Personal Information Protection and Electronic Documents Act and all applicable provincial privacy laws regulating the private sector.

Please note that we do not voluntarily collect information from persons under the age of 16.

United States:

The California Consumer Privacy Act and comparable state-level comprehensive data privacy laws similar in states such as Colorado, Montana, New Hampshire, New Jersey, Oregon, Rhode Island, Utah, and other states provides their residents with certain privacy protections.

However, these Data Privacy Laws typically do not apply to ISB Global Services because it’s governed by the federal Fair Credit Reporting Act (FCRA), as consumer reporting agency. Your rights under the FCRA can be found here: https://www.isbglobalservices.com/my-background-check/fair-credit-reporting-act-summary/

Children’s Online Privacy Protection Act Compliance

We are compliant with the requirements of COPPA (Children’s Online Privacy Protection Act), because we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed at people who are at least 13 years old or older.

We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us.

If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

C. Changes and updates

We may revise this Notice from time to time. If we make any material changes, we will notify you by publishing an updated Privacy Policy on the ISB Global Services website.


II. PERSONAL INFORMATION

We define “personal information” as any information about an identifiable individual, or that taken alone or combined with other data, allows an individual to be identified. Personal information does not include business contact information such as your name, title, business address or telephone number.


III. COLLECTION OF PERSONAL INFORMATION

A. Types of personal information collected

The personal information we collect is necessary to provide you or our End Client with the requested Services. This includes, but is not limited to:

  • contact information such as your name, address, email, or phone number;
  • identification information, such as your social security number, social insurance number, driver’s license number, passport number, birth certificate, date of birth, place of birth, gender, nationality and citizenship status;
  • education and employment information, including with respect to your educational background, training courses and diplomas, employment history, past and current titles, employers, associations and references;
  • financial and insurance information, including annual income, credit score, credit history, insurance coverage and claims history;
  • public and criminal records information, including information available by federal, provincial or local governments, courts, law enforcement agencies and other governmental agencies such as legal proceedings, court records, drivers abstract and bankruptcy registrations;
  • health information, including medical records and other information regarding an accident, disability or injury;
  • digital content such as photos, videos, or audio files; and
  • Any other personal information provided.

We only collect sensitive personal information reasonably necessary for the Services or for other uses specified in this Notice if we have a signed consent from the individuals to whom the sensitive information relates or if the information is necessary or required for another legal reason provided under applicable privacy or other legislation.

B. How we collect personal information

We collect personal information directly from you when you submit a Consent Form or when you contact us or share any personal information with us.

It is also in the very nature of our Services to collect personal information about you from a variety of other independent or third-party sources, with your consent, including credit reporting agencies, screening and recruitment agencies, insurers and insurance agencies, federal, provincial or local governments, courts, law enforcement agencies and other governmental agencies, past and current employers, employment references, hospitals and other healthcare facilities, publicly available sources (including social media), contractors, service providers and business partners (“Third-Party Sources”).


IV. PURPOSES OF COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

We collect, use, and disclose personal information for the purposes identified at the time of collection or as permitted or required by law. This includes, but is not limited to, the following purposes:

  • Establishing and managing our relationship with you and our End Client;
  • Providing the Services (the nature of which is indicated in your Consent Form or as otherwise disclosed at the time of collection) to you and our End Client;
  • Investigating any complaints made by you or responding to any requests to exercise your rights described in this Notice; or
  • Conducting development and research to ensure that we maintain the highest standard of security, to understand our End Clients’ requirements and to improve our service offer;
  • Enabling business development and marketing, more precisely to inform current and End Clients about our new services;
  • Any other purpose to which you have consent or that is permitted or required by any applicable laws and regulations.

ISB Global Services is a consumer reporting agency (“CRA”) operating in accordance with the requirements of the Fair Credit Reporting Act (“FCRA”) and collects, uses and discloses your personal information in accordance with the guiding principles set forth in the FCRA.


V. LIMITATION OF THE COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

We strive to limit the collection, use and disclosure of personal information to what is strictly required to fulfill the purposes for which it is collected. In certain circumstances, we may need to collect personal and sensitive information to comply with our legal obligations. We will not disclose or use your personal information for any other purpose unless you consent to such or as required by law.

We may use your personal information if it is necessary to prevent or lessen a serious threat to public health or public safety or if the use of the information is necessary for law enforcement or for the conduct of proceedings before any court or tribunal.


VI. CONSENT

A. Primary purposes

Except where expressly authorized under applicable laws and regulations, we will always obtain your consent prior to the collection, use or disclosure of your personal information.

With regards to personal information collected, used or disclosed for our Services, your consent will be expressed through your completed Consent Form, which will indicate the types of Services provided.

Please note that you have the right to refuse to provide us with your consent. You also have the right, subject to reasonable notice and applicable legal or contractual restrictions, to withdraw your consent regarding the use of your personal information already collected by contacting our Privacy Officer. The refusal to consent or withdrawal of your consent may prevent us from providing or continuing to provide you or the End Client with our Services.

B. Marketing and secondary purposes

We may also ask for your consent for secondary purposes, for example for development and marketing purposes. As mentioned above, we will ask for your consent in this regard. In addition, your consent for secondary purposes may be withdrawn at any time, without affecting the rendering of our Services to you or the End Client.

With your consent, we may also contact you to inform you about products, services, events and resources which we think would be of particular interest to you. If you opt out of receiving further communications from us, we will take steps to ensure you do not receive any such further information from us in future.

C. Providing third-party personal information to us

If, at any time, you provide us with personal information or other information about an individual other than yourself, you warrant to us that you have that individual’s consent, including where applicable any other necessary consent to provide such information for the purpose specified and for us to treat such information in accordance with this Notice. We may need to ask for written proof of consent from that individual when necessary.


VII. PERSONAL INFORMATION DISCLOSURE

To provide you with our Services, we may need to disclose the personal information we collect about you. All such disclosures will be conducted in accordance with applicable laws and regulations.

We will never, by any means, sell or exchange your personal information for payment. We will not disclose personal information to third parties for the purpose of third-party direct marketing.

We may disclose your personal information in the following circumstances:

A. End Clients

It is the very nature of our Services (including our background check services, insurance services and identity verification services) to disclose certain personal information about you to the End Client (including prospective employers, insurance agents, etc.) as required by the applicable Services.

B. Third-Party Sources

To the extent required by the applicable Services, we will need to disclose certain personal information about you to Third-Party Sources (as defined in Section III of this Notice) in order to conduct the verifications and obtain any additional personal information required as part of such Services.

C. Employees and service providers

To provide the Services, certain of our employees with a need to know will have access to your personal information. All such employees will be advised of the personal and confidential nature of your personal information and be bound by reasonable confidentiality obligations.

Additionally, we may disclose your personal information to individuals or entities that assist us to deliver our services, such as our contractors, agents or service providers. These third parties may change from time to time and include technology and internet service providers and data storage or processing services providers. Where it is necessary for personal information to be provided to a third party in connection with the provision of a service to us, we will take reasonable steps within our power to prevent the unauthorized use or unauthorized disclosure of personal information.

D. Other permitted disclosures

Only to the extent allowed by the applicable laws and regulations, we may also disclose your personal information under the following circumstances:

  • when you have expressly consented to such disclosure;
  • when you would reasonably expect us to use or disclose your personal information in a certain way;
  • when the disclosure is one of the purposes in connection with which the information was obtained or is directly related to the purposes in connection with which the information was obtained;
  • when the source of the information is a publicly available publication and, in the particular circumstances, it would not be unfair or unreasonable to disclose the information;
  • when authorized or required to do so by a court or under applicable laws or regulations (for example, a subpoena), or where requested by a government agency;
  • where we consider a company or an individual may be engaged in fraudulent activity or other deceptive practices of which a governmental agency should be made aware;
  • when disclosure is reasonably necessary for a law enforcement-related activity.


VIII. TRANSFER OF PERSONAL INFORMATION ABROAD

Most of our Canadian Services will be performed by our employees who are currently located in Ontario and Quebec (Canada). Our American services will be performed by our employees located in the United States. However, certain End Clients, Third-Party Sources or other service providers (including those listed in Section VII of this Notice) or third parties may be located in other jurisdictions. Some of our third-party service providers are based outside Quebec (Canada), notably across North America.

Accordingly, it is possible that some of your personal information may be transferred to places other than your province, territory, state or country of residence. In such case, we will ensure that your personal information is transferred to countries that provide adequate protections for your personal information, or that your personal information is adequately protected by appropriate technical, organizational, contractual, or other lawful means. When required by applicable laws and regulations, we will conduct an impact assessment prior to such transfers to identify and mitigate any risk of harm to individuals.

You acknowledge and agree to such international data transfers with respect to personal information of the nature described above.


IX. PERSONAL INFORMATION RETENTION

Personal information is retained for as long as necessary for the purposes set out in this Notice. After such time, any personal information held by us will be destroyed, deleted or made anonymous. Unless we are required to retain your personal information for a longer period to ensure that we comply with our legal, tax or regulatory obligations, the following retention periods will apply:

  • ISB retains personal information for a period of three (3) years. The personal information collected from Third-Party Sources for the purposes of our Services will be retained for a period of 3 years;
  • All other personal information that has been collected will be retained for a period no longer than six (6) years from the time of collection, subject to applicable legal and regulatory requirements


X. SAFEGUARDS

We maintain physical, electronic, and procedural safeguards to guard and protect your personal information. To learn more about our security measures, please consult our Information Security web page, https://www.isbglobalservices.com/information-security/.

In the event of a data breach involving a loss or unauthorized access to or misuse of your personal information, we will report such breach to you and any relevant authority as required by law.


XI. YOUR RIGHTS

Depending on applicable laws and regulations of your jurisdiction, you might have the right to obtain access to, rectification or erasure of your personal information, the right to withdraw your consent (if any), the right to be informed of a decision based exclusively on an automated processing automated decision (if any), the right not to be discriminated against, the right to restrict and to object to the use and processing of your personal information by us, or the right to data portability by, namely, receiving a copy of all personal information that we have about you in a structured, commonly used and machine-readable format.

A. Making a request

To exercise any of these rights (to the extent available), please submit your request to us by writing to the Privacy Officer as set forth in Section XIII of this Notice. Depending on the right being exercised, we will inform you of the procedure to follow, the processing time (delay of response) and the information needed. We will endeavor to process your request within one (1) calendar month from the date your request is received. We will inform you if this timeframe is not achievable and extend this timeframe as permitted by applicable law. We may need to verify your identity before processing your request.

Unless we are required or permitted by applicable laws and regulations to refuse to do so, we will, on request, provide you with details of the personal information we have collected about you or update and rectify your personal information in accordance with your request. Where we are also required by the applicable law to provide further information about the use or disclosure of your personal information, we will do so upon your request.

B. Exceptions

If we refuse to provide you with access to, or to rectify or erase, your personal information as requested or otherwise meet your requests, we will notify you accordingly. Where appropriate, we will provide you with the reason(s) for our decision and the mechanisms available to complain about the refusal. We may exercise such refusal if your personal information is not retrievable, the request is frivolous or vexatious, providing access or otherwise meeting your request is reasonably likely to pose a serious threat to the safety of an individual or the public or for any other reason supported by applicable laws and regulations.


XII. PERSONAL INFORMATION MANAGEMENT PROGRAM

In order to protect your personal information, we have put in place policies, practices and procedures relating to the management of the personal information we hold.

These internal policies and procedures govern the collection, use, disclosure, retention and destruction of personal information, as well as complaint handling, information security and data governance. These policies and practices also provide the framework for the implementation of privacy impact assessments, as well as the prevention of and response to potential privacy incidents.


XIII. PRIVACY OFFICER

We have delegated the management of the privacy program to the Privacy Officer. The Privacy Officer is responsible for the internal management and oversight of our privacy program and can be reached at:

Privacy Officer
ISB Global Services
100 Stone Rd W Unit #203
Guelph, ON N1G 5L3
1.800.609.6552
[email protected]

It is also the responsibility of the Privacy Officer to provide you with the necessary support in the event of a question, complaint or request relating to the protection of personal information.

In the event that you have a complaint regarding the exercise of your rights under this Notice, we will respond to your complaint as soon as possible. Your file will be handled by our Privacy Officer, who will inform you of the procedures to follow. Each complaint will be investigated. If the complaint is justified, the specific situation will be corrected, and you will be informed. We will contact you let you know how long it will take to resolve the complaint.

If you believe that we have not adequately dealt with your complaint, you may complain to the competent authority, such as the Commission d’accès à l’information du Québec for the province of Quebec or the Privacy Commissioner of Canada.