Background checks are the first step in consumer data protection and involves vetting, verifying, and ensuring all new employees are of reputable standing before accessing consumer data. All offers of employment are contingent upon clear results of a thorough background check. Background checks will be conducted on all final candidates and on all employees who are promoted, as deemed necessary.


Applies to all staff.

General Policy

A small group of designated employees and contractors are given access to customer data on an as-needed basis. Employee roles are used to determine if the employee/contractor shall have access to customer data (e.g. technical support). Background checks are required for roles that may at any time access customer data and are completed at time of hire or during employee transfers to roles requiring access to customer data. Background checks shall be kept on file for all active employees/contractors and kept for a minimum of three (3) years after termination/departure.

Background checks include:

  • Social Security Verification (as applicable): validates the applicant's Social Security number, date of birth and former addresses.
  • Prior Employment Verification: confirms applicant's employment with the listed companies, including dates of employment, position held and additional information available pertaining to performance rating, reason for departure and eligibility for rehire. This verification will be run on the past two employers for the previous five years of employment.
  • Educational Verification: confirms the applicant's claimed educational institution, including the years attended and the degree/diploma received.
  • Valid Work Permits (if applicable) - for example, that the employee has a legal right to work in a specific jurisdiction
  • Criminal History: includes review of criminal convictions and probation for a minimum of the last seven (7) years. This criminal history check shall include, to the extent available and permitted by law, a check for outstanding warrants and a check for pending felony charges in all such locations. Statewide county searches shall be performed in all states where such search mechanism is available without requiring specialized data (such as fingerprints or DNA), and the National Criminal File database shall also be searched. The following factors will be considered for applicants with a criminal history:
    • The nature of the crime and its relationship to the position.
    • The time since the conviction.
    • The number (if more than one) of convictions.
    • Whether hiring, transferring or promoting the applicant would pose an unreasonable risk to the business, its employees or its customers and vendors.
    • National/State Sex Offender Registry Status
  • Country specific checks (for example, Cifas in the UK)

Drug Screening

Certain employees may be required to pass drug screen tests to fulfill contractual commitments to specific customers.


See Access Control Policy for details on Background Check Audits