Introduction
This privacy policy applies to www.INSTAHIRE CHECK.com (“Website”) and services owned and operated by INSTAHIRE CHECK , LLC and its subsidiaries (“INSTAHIRE CHECK”, “we”, “us” or “our”). INSTAHIRE CHECK is a background screening company that provides employment screening, background checks, occupational health screening and reports for its customers who have a legal purpose for conducting such screening (“Services”). INSTAHIRE CHECK’s principal location and headquarters is 2685 S Rainbow Blvd Ste 200, Las Vegas, NV 89146.
INSTAHIRE CHECK values the privacy of each individual and is dedicated to safeguarding the personal information and data of our customers, clients, website users, employees, prospective employees, and other stakeholders. References to “you” or “your” in this policy pertain to the individual reading this policy, your organization, or the data subject whose personal information/data is being collected and processed.
Our privacy policy outlines the ways in which INSTAHIRE CHECK manages information that is collected, processed, disclosed, transferred, used, and retained when you interact with us. This includes visiting our website, using our services, participating in the background screening process, or applying for a job at INSTAHIRE CHECK. It also details your options regarding the use, access, deletion, and updating of your personal information.
The procedures for handling your personal data vary depending on your relationship with us, whether as a customer using our services, an individual consenting to a background check by an INSTAHIRE CHECK customer, a potential employee, a current employee, or a casual browser of our website without falling into the aforementioned categories.
Agreeing to use INSTAHIRE CHECK’s website and services signifies your acceptance of this privacy policy. Please note that this policy may be updated periodically, and we advise checking it each time you access our website to ensure you have the latest information.
Contents
• What personal data and information do we collect?
• How do we collect and use your personal data and information?
• How do we share your personal information and data?
• How do we store your personal information and data?
• What are your data protection rights?
• Marketing
• Third Party Websites / Links
• Third Party Websites / Links
• Cookies
• What other important privacy information is applicable?
• How do we transfer personal data and information globally or across borders?
• Changes to our privacy policy
• How to contact us
• How to contact the appropriate authorities
What Personal data and information do we collect?
We gather personal data for various reasons, depending on your type of interaction or relationship with us. It’s possible for you to engage with INSTAHIRE CHECK in multiple capacities or fit into more than one of the categories below:
Website Users:
When visiting our Website, we initially collect general internet data such as your domain name, computer ID, IP address, location, the webpage through which you accessed our site, which pages you visited, the duration of each visit, and other activities on our site and third-party links. To gather this information, a “cookie” is set on your computer during your visit. Cookies, which are detailed further below, store data that enables our web servers to recognize you on subsequent visits.
Beyond general internet data, we may collect specific information that you provide directly to us. This includes your name, job title, organization, and contact details (name, phone number, email, and/or mailing address), as well as your preferences for subscribing to our website newsletters or notices.
Customer / Vendor:
Customers are individuals or organizations that contract with us to obtain background screening information and use our Services. They are also referred to as end-users of the background report.
Vendors, consultants, or other service providers are those that INSTAHIRE CHECK hires to deliver certain services, perform specific business-related functions, or provide data.
Type of Information Collected:
Contact details such as name, email address, phone number, and physical address necessary for delivering our Services.
Commercial business information including payment and billing details, contacts, banking or credit card information, account numbers, email addresses, and other financial data.
Organizational information such as the products you order, your company details, size, credit information, and other non-personal data.
Candidate or Data Subject of Our Customer
A candidate or data subject is an individual for whom one of INSTAHIRE CHECK’s customers has requested a background screening report.
In addition to the information collected as a Website user, INSTAHIRE CHECK may gather the following details about data subjects/candidates:
Contact information: name (including prior names and aliases), email, physical address, phone number, and location.
Identifying information: social security number or other government ID, driver’s license number, date of birth, mother’s maiden name, place of birth, and other data necessary for identity verification and background report preparation.
Address history.
Criminal records: police records, arrest records, convictions.
Driving history.
Credit information: credit and debit records, judgments, payment history, and other credit-related details.
Educational background.
Employment history.
Professional licenses.
Right to work status.
Health and drug test results.
References and opinions.
Directorships and corporate affiliations.
Media presence (social, print, or online).
Billing or financial information if utilizing INSTAHIRE CHECK’s volunteer services.
Other information as requested by the customer.
Prospective Employees
INSTAHIRE CHECK may collect the same types of information from prospective employees as from customer’s candidates or data subjects to assess employment eligibility or conduct a background check. Additionally, during interviews, you may provide other pertinent information you believe is necessary for INSTAHIRE CHECK to consider.
INSTAHIRE CHECK Employee
Beyond the data collected during the application process, INSTAHIRE CHECK also gathers:
• Personal interests and other information you choose to share with us.
• Professional background.
• Identity details such as date of birth, identity documents, nationality, citizenship, and immigration status to confirm work authorization.
• Diversity data (e.g., gender, ethnicity, disability status, veteran status, race) for statistical purposes, which is not linked to your identifiable information.
• Work history, job performance, productivity, and other employment-related information to manage your work responsibilities.
• Tax and payroll details, financial information, benefits, insurance, medical information for benefits provisioning, and other personal data.
How do we collect and use your personal data and information?
INSTAHIRE CHECK collects personal information in various ways, depending on your interaction with us and the purpose for which the information is being used. You may fall into more than one category, and the use of your personal information is confined to specific purposes such as: providing the services for which it was collected; responding to requests for information or facilitating transactions for customers with a legitimate and lawful basis for such use; fulfilling contractual obligations; based on your consent; complying with legal requirements; or serving our legitimate interests.
Website Users:
Personal information may be automatically collected through your interactions with our website. Like most websites, we collect data such as IP addresses, browser type, ISP details, referring/exit pages, operating system, date/time stamps, and clickstream data, and store it in log files. This automatically collected data is not linked to personal information. Cookies on our website gather, track, store, and analyze data about your visits. This information helps ensure our websites function correctly, enhances performance and security, and aids in marketing and improving the user experience.
Personal information may be automatically collected through your interactions with our website. Like most websites, we collect data such as IP addresses, browser type, ISP details, referring/exit pages, operating system, date/time stamps, and clickstream data, and store it in log files. This automatically collected data is not linked to personal information. Cookies on our website gather, track, store, and analyze data about your visits. This information helps ensure our websites function correctly, enhances performance and security, and aids in marketing and improving the user experience.
Data Subjects or Candidates:
If you are a data subject or candidate of a customer, a potential or current INSTAHIRE CHECK employee, we collect personal information for background screening purposes. Typically, you will be notified in advance and provide your authorization for us to collect and use your personal information. We gather this information from:
You directly
Our customers
Public records and publicly available media, including social media
Educational institutions, employers, credit reporting agencies, law enforcement, courts, or other governmental entities
References or third parties you have authorized us to contact
*Note: Outside of the US, INSTAHIRE CHECK does not rely on consent to use personal information for conducting background checks. Our customers must have a lawful basis for requesting these checks.
INSTAHIRE CHECK Employees:
For current employees, we collect personal information necessary for human resource functions and may obtain information from various sources, including insurance companies, benefits providers, supervisors, and coworkers.
Customers:
For INSTAHIRE CHECK customers, we collect personal information directly from you or through our website or service platform to process your orders, manage your account, and provide services, results, and reports.
Additionally, to enhance our services, INSTAHIRE CHECK may aggregate personal information for analyzing trends and user statistics. This aggregated data is anonymized and does not identify any specific individuals.
How do we share your personal information and data?
INSTAHIRE CHECK transfers personal information only to affiliates, partners, vendors, and customers as necessary to deliver our services. Any transfers to third parties are governed by the terms of this policy, particularly concerning notice and choice, as well as by service agreements with our clients. We will not disclose your personal information to third parties unless it is required for the processing of our services.
How do we store your personal information and data?
The duration for which we retain personal information varies based on its type and the purposes for which it was collected. We store personal information for as long as it is necessary to provide our services, fulfill our and our clients’ contractual, legal, and business obligations, or maintain it for any legitimate business or legal reasons. When personal information is no longer needed, we either delete it or anonymize it, ensuring you cannot be identified from the data that is left. Our paper policy is to be kept in a restricted area and is a shred-all policy after the information is no longer needed.
Use of Local Storage (HTML5)
Our partners, who assist in providing features on our website or in displaying targeted advertising based on your web browsing activities, utilize Local Storage (HTML5) to collect and store content information and preferences. You can manage Local Storage using browser tools specifically designed to handle HTML5.
What are your data protection rights?
You are entitled to various data protection rights under applicable privacy laws. These rights include:
The right to access copy(ies): You have the right to request copies of your personal data from INSTAHIRE CHECK. A small fee may be charged for this service.
The right to alteration: You have the right to request that INSTAHIRE CHECK correct any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete.
The right to deletion: You can request that INSTAHIRE CHECK erase your personal data, under certain conditions.
The right to restrict processing: You have the right to request that INSTAHIRE CHECK restrict the processing of your personal data, under specific conditions.
The right to object to processing: You have the right to object to INSTAHIRE CHECK’s processing of your personal data, under certain conditions.
The right to data portability: You have the right to request that INSTAHIRE CHECK transfer the data we have collected to another organization, or directly to you, under certain conditions.
Access to Data Controlled by our Clients
In certain instances, INSTAHIRE CHECK processes personal information as a service to our clients. If you wish to access, correct, or delete data that INSTAHIRE CHECK handles, please direct your inquiries to our client who acts as the data controller. If you are a data subject or candidate associated with one of our clients and you no longer wish to be contacted by them, or if you want to withdraw your consent for our services, please contact the client with whom you originally interacted directly.
Marketing
We may collaborate with an external party to manage and display advertisements on our website or to oversee our advertising on other platforms. This third-party partner may employ technologies like cookies to collect data about your activities on our website and elsewhere, aiming to tailor advertisements based on your browsing preferences and interests.
If you provide us with your postal address online, you might receive periodic postal communications from us containing information about new products, services, or upcoming events. If you prefer not to receive these mailings, you can opt out by contacting us via email, phone, or postal mail using the details provided below.
To receive our newsletters, we require your name and email address to send them to you. Should you decide to stop receiving our newsletters or marketing emails, you can do so by: (i) following the unsubscribe instructions included in these emails, (ii) updating the email preferences in your account settings, or (iii) reaching out to us at [email protected]. To cease receiving emails from us, simply inform us by email, phone, or postal mail using the contact details below.
We feature personal testimonials and endorsements from satisfied customers on our website. With your permission, we may post your testimonial along with your name. If you wish to update or delete your testimonial, please contact us using the provided contact information.
User Access and Choice
If you need to update or remove your personal information, or if you no longer wish to receive our newsletters or marketing materials, you can correct, update, or delete your information either through our member information page or by reaching out to us via email, telephone, or postal mail at the listed contact details. We will address your request within 30 days. INSTAHIRE CHECK will keep your information for as long as your account is active or as necessary to continue providing marketing services.
Social Media Widgets
Our website includes social media tools like the ‘Share this’ button and Facebook ‘Like’ button, along with interactive mini-programs. These features may collect your IP address and page visit details on our website, and they require a cookie to function effectively. These widgets may be hosted directly on our site or by a third party, and your interactions with these features are subject to the privacy policy of the providing company.
Blog with Comments
Our website features publicly accessible blogs. Please be aware that any information you disclose in these areas may be accessible to others. To request the removal of your personal information from our blog or community forum, please contact us using the details provided below. There may be instances where we cannot remove your information, in which case we will inform you of our inability to do so.
Third Party Websites / Links
Our website contains links to external websites, each with its own privacy practices that may differ from those of INSTAHIRE CHECK. When you provide personal information to these sites, it is managed according to their respective privacy policies. We recommend that you thoroughly review the privacy policy of any website you visit.
Cookies
What are Cookies regarding your computer and the internet?
Cookies are small text files stored on your computer designed to collect standard internet log information and visitor behavior data. When you visit our website, we automatically gather information via cookies or similar technologies to enhance and streamline your experience.
For additional details on cookies, you can visit allaboutcookies.org.
On your visit to our website, we collect general internet data including your domain name, the entry page to our site, the pages you visit, and the time spent on each page. This collection is facilitated by setting a “cookie” on your computer, which contains data enabling our web servers to recognize you on subsequent visits.
How do we use cookies?
At INSTAHIRE CHECK, cookies are utilized to:
Keep you logged in
Analyze your usage of our website
Implement tracking technologies like cookies, beacons, scripts, and tags to monitor trends, manage the website, track user movements, and collect demographic information about our entire user base
Store session details, passwords, and client profiles to enhance service on future visits
Evaluate website usage to improve and optimize your experience
What types of cookies do we use?
Session Cookies: These cookies remain active only while you are on the website.
Persistent Cookies: These remain in use for an extended period and store preferences like passwords for easier browsing.
Essential Cookies: Crucial for delivering our services, navigating our site, and using various functions. These cannot be disabled.
Analytical Cookies: These help us understand user interaction, providing usage statistics and identifying any technical issues.
Functional Cookies: Recognize you and remember your preferences for a more personalized experience, including your preferred language and location.
Advertising Cookies: Gather data about your visits, viewed content, and followed links, along with your browser and device information. We sometimes share this data with third parties for advertising purposes.
How to Manage Cookies
In certain regions, you will be greeted with a cookie consent banner upon visiting our website, allowing you to adjust your cookie preferences. Additionally, you can modify your settings by clicking the cookie icon on our site.
You can configure your browser to block cookies.
If you choose to reject cookies, you can still access our website, be advised that some functionalities, like placing orders or viewing results, may be impaired without cookies. We ensure that no personal information is stored in cookies and that such data is not shared with external parties unless necessary.
What other important privacy information is applicable?
Policy Regarding Children
Our website is not designed for children, and we do not intentionally gather personal information from children without parental consent, except as allowed by law. If we discover that we have collected personal information from a child without appropriate parental consent, we will take steps to remove this information. If you believe that a child has provided us with personal information without the required consent, please get in touch with us.
Accuracy
At INSTAHIRE CHECK, we recognize the significance of accurate data, especially given our legal obligations to ensure the accuracy of our screening results. Most personal information we collect will be provided directly by you, which we consider accurate. When collecting information from other sources, the responsibility for accuracy lies with those sources. If it is discovered that your personal information is incorrect, we will correct any inaccuracies. If you need to request a correction to your personal information, please contact us.
Disclosure of Your Information
INSTAHIRE CHECK may disclose personal information to third parties if required by legal processes such as a court order, warrant, subpoena, or other enforceable legal demands. We will comply with the law as necessary, but we will attempt to notify you and obtain your consent before disclosing personal information, if permitted by law. If the information was collected on behalf of a client, we will consult with the client where possible before disclosing it.
Security
We implement physical, electronic, and procedural safeguards to protect the personal information you provide. Transactions on our services are protected with SSL encryption, and we employ security protocols and measures to shield your data from unauthorized access or alteration. These measures include internal and external firewalls, physical and digital security measures, and encryption of sensitive information like login credentials. However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, absolute security cannot be guaranteed. If you have concerns about security on our website, please contact us.
Additional Information for Individuals in California
The California Consumer Privacy Act (CCPA) and the California Privacy Rights Act provide specific rights to California residents. These laws are collectively referred to as “CCPA” in this privacy policy. However, there is an exception under the CCPA for information that is collected and processed in accordance with the Fair Credit Reporting Act (FCRA). Most of the personal information we collect at INSTAHIRE CHECK is intended for background reporting purposes under the FCRA. In such cases, we will handle and store your information in line with our obligations under the FCRA or equivalent state law. The FCRA also allows you the opportunity to request disclosures and/or a reinvestigation when applicable.
While the CCPA exempts data processed under the FCRA, it still applies to California residents who are users of our website, employees of INSTAHIRE CHECK, or customers of INSTAHIRE CHECK. We do not sell your personal information, though we may share it as described in the sections of this policy detailing how we collect, use, share, and store your information.
Unless exempted under the FCRA or when acting as a service provider or processor, California residents have the following rights:
Right to Know: You can ask about the categories of personal data we have collected, disclosed, sold, or shared within the past 12 months.
Right to Access: You can access the personal data we hold about you.
Right to Deletion: You can request the deletion of your personal data, unless it is exempt or if INSTAHIRE CHECK is acting as a service provider or processor.
Right to Non-Discrimination: You are entitled to equal services and rights without discrimination.
Right to Opt-Out: You can request that we do not sell or share your personal information.
Changes to Our Privacy Policy
INSTAHIRE CHECK may periodically revise or update this privacy policy to reflect changes in our practices. If there are any significant changes, we will notify you through our website before these changes become effective. For the most current information, please refer back to this page regularly. The date at the start of this privacy policy will be updated whenever changes are made.
How to contact us
If you have any questions about INSTAHIRE CHECK’s privacy policy, the personal data we have stored, or you would like to implement one, or more, of your data protection rights, please contact us.
Email us at: [email protected]
Call us: 702-760-2110
Or write to us at: 2685 S Rainbow Blvd Ste 200, Las Vegas, NV 89146
If you have any questions about our privacy practices, please contact us. You also have the right to file a complaint with your data protection authority if you have a concern about the way we are processing your personal data.
How to contact the appropriate authorities?
Should you wish to report a complaint or if you feel that INSTAHIRE CHECK has not addressed your concern in a satisfactory manner, you may contact your relevant supervisory authority, local data protection authority, or the Federal Trade Commission.
HUMAN TRAFFICKING POLICY & PROCEDURES
I. Purpose
In accordance with applicable law, InstaHire Check, LLC (“InstaHire”) will assist victims of human trafficking to have adverse information blocked from consumer reports if the adverse information resulted from human trafficking. Please follow the instructions below to assist victims of trafficking who contact InstaHire. This document is designed to help guide staff on how to process information related to human trafficking in a way that satisfies applicable law.
II. General Instruction For Staff
Please follow the procedures outlined below. If you have any questions after reviewing such procedures, raise them immediately with ______________________. In addition, if you have a question in a particular situation, please confer with ______________________________.
III. Specific Procedures
Step 1: Communicate with Consumer
Some consumers may call, email, or otherwise inquire with InstaHire about how to submit information regarding human trafficking. If you receive such a request from a consumer, please inform the consumer that they may submit information regarding human trafficking to InstaHire in any of the following ways:
- Via mail at InstaHire, 2685 S. Rainbow Blvd #200, Las Vegas, NV 89146.
- Via mail at [NEW ADDRESS CREATED FOR THIS EXPRESS PURPOSE].
- Via InstaHire’s online portal: [INSERT HYPERLINK].
Please also instruct the consumer to provide the four items of information identified in Step 2 below.
After receiving the initial contact from the consumer, you should review the information and documentation provided by the consumer to ensure that the correct information has been provided. You must review the information received from the consumer within four (4) business days. Each item of information/documentation required is discussed below, along with instructions for your review. Please make a note if any information is missing. You may need to follow-up with the consumer to request this missing information in Step 4.
Required Item #1 – Appropriate Proof of Identity: A consumer must submit appropriate proof of their identity, which typically includes providing InstaHire with a copy of the consumer’s:
- Driver’s license;
- State identification card;
- Passport;
- Social Security Card;
- Utility or service bills; or
- Other government-issued identification card.
Please review the proof of identity submitted by the consumer to confirm that the proof of identity provides sufficient information to match the consumer to their file/information.
If a consumer who is a victim of trafficking does not have any of the above forms of identification, please instruct the consumer to call InstaHire at 702-760-2110, so that their identity can be confirmed by another method. To confirm a consumer’s identity over the phone, you should ask the consumer standard verifiable identification questions regarding their date of birth, social security number, and/or current full address.
Required Item #2 – Victim Determination Documentation: A consumer must submit at least one of the following:
- Option 1: Documentation that establishes that one of the following entities has formally determined that the consumer is a victim of trafficking:
- A Federal, State, or Tribal governmental entity.
- A non-governmental organization or member of a human trafficking task force, including victim service providers affiliated with these entities and authorized by a Federal, State, or Tribal government entity.
- Option 2: Documentation that the consumer is a victim of trafficking made by a court of competent jurisdiction or a determination consisting of documents filed in a court of competent jurisdiction where a central issue in the case is whether the consumer was a victim of trafficking and the court has, at a minimum, affirmed the consumer’s claim either by accepting certain pieces of evidence which are assumed to be true or finding that there is no genuine dispute as to any material fact supporting a judgment in favor of the consumer as a matter of law.
- Option 3: A signed self-attestation attesting that the consumer is a victim of trafficking, if the self-attestation or accompanying document is signed by:
- A Federal, State, or Tribal governmental entity;
- A non-governmental organization or member of a human trafficking task force; or
- A court of competent jurisdiction.
Please review the victim determination documentation to ensure that the consumer has provided documentation sufficient to satisfy at least one of the categories above.
Required Item #3 – Identified Adverse Items of Information: Consumers who are victims of trafficking are required to identify any item(s) of adverse information (e.g., arrest records, criminal convictions, civil judgments, etc.) that they believe should not be included in a consumer report about them because the item(s) resulted from a severe form of trafficking in persons or sex trafficking of which they are a victim. Please review the consumer’s submission to determine whether the consumer has identified the adverse item(s) of information that they believe should not be reported. Note that you should not assess whether the consumer has “proven” that the adverse information resulted from human trafficking. Applicable law prohibits such an assessment. As long as the consumer can identify specific adverse information, that is sufficient.
Required Item #4 – Preferred Contact Method: Consumers who are victims of trafficking must provide InstaHire with their preferred contact method (e.g., mail or email). Please ensure the consumer has identified their preferred contact method.
Step 3: Initial Block of Adverse Information Resulting from Trafficking Within Four (4) Business Days of Consumer’s Submission
InstaHire must initiate an initial block of adverse information identified by the consumer within four (4) business days of the consumer’s request, subject to the exception below. If the consumer’s submission is complete, please place a block on any adverse information that a consumer believes should not be reported because the information resulted from a severe form of trafficking. This includes, at a minimum, making an appropriate note in a consumer’s file and/or InstaHire’s internal systems that certain items of information should not be reported about the consumer.
If InstaHire has previously prepared a consumer report about the consumer that includes items of adverse information linked to trafficking and the consumer report is still accessible by the end-user, please place an initial block on the relevant section of the report or, if necessary, the entire report.
IMPORTANT NOTE: InstaHire may only decline to enter an initial block of adverse information if it cannot reasonably confirm the consumer’s proof of identity, the consumer cannot provide documentation consisting of a victim determination, or the consumer reporting agency cannot properly identify the adverse items of information that the consumer is linking to trafficking. If you are lacking critical information necessary to place the initial block, please proceed to Step 4 to request the necessary information from the consumer.
Step 4: Request Additional Information from the Consumer, If Needed, Within Five (5) Business Days of Consumer’s Submission
InstaHire must notify the consumer if his/her submission is deficient within five (5) business days of receiving the consumer’s submission. You may request additional information if the consumer failed to provide appropriate proof of identity, failed to provide victim determination documentation, or if InstaHire cannot properly identify the adverse items of information that the consumer believes should not be included in a report. If the items above were not submitted, please contact the consumer via his/her preferred contact method to request that the consumer provide the information within seven (7) days.
If the consumer provides additional information, please review the information in accordance with Step 2 to ensure all necessary information/documentation has been provided. If all necessary information/documentation under Step 2 has been provided, please proceed to Step 3, and place an initial block.
Step 5: Make Final Determination Regarding the Block And Notify Consumer of Same
InstaHire must make a final determination on the consumer’s submission no later than 25 business days after receiving the consumer’s initial submission. InstaHire must: (1) maintain the initial block that was put in place; (2) decline to block; or (3) rescind a block. Each possible final determination is addressed below.
- Maintain Initial Block: You should maintain the initial block that was put in place if the consumer’s submission is complete, all necessary documentation and information has been provided, and you are able to identify the adverse items of information that should be blocked.
- Decline to Block: You should decline to block the reporting of adverse information if you cannot reasonably confirm the consumer’s proof of identity, the consumer cannot provide documentation reflecting a victim determination, or the consumer reporting agency cannot property identify the adverse items of information. To decline a block, you must have requested the necessary information in Step 4.
- Rescind a Block: You should rescind a block on the reporting of adverse information if you cannot reasonably confirm the consumer’s proof of identity, the consumer cannot provide documentation consisting of a victim determination, or the consumer reporting agency cannot property identify the adverse items of information. To rescind a block, you must have requested the necessary information in Step 4.
Please notify the consumer of InstaHire’s final determination no later than five (5) business days after the final determination has been made (or if InstaHire is rescinding a previously applied block, notice must be given within five (5) business days after rescinding the block). You must send written notice to the consumer regarding InstaHire’s final determination. The notice should include the following information and be sent to the consumer via their preferred method of contact:
- A statement that the review of the submission is completed;
- A statement of the outcome of the submission, including the reason(s) if the consumer reporting agency declined to block the adverse information identified by the consumer, or rescinded such a block;
- A consumer report, provided at no cost to the consumer, that is based upon the consumer’s revised file (if applicable) as a result of the consumer’s submission;
- A description of the procedure used to determine the outcome;
- A method for contacting the consumer reporting agency to appeal the determination or revise the submission to cure any of the noted reasons for declining to block the adverse information identified by the consumer; and
- The web page consumers can use to submit complaints to the Consumer Financial Protection Bureau (https://www.consumerfinance.gov/complaint/).
If the consumer has an existing report in the system that has blocked items of adverse information, ask the consumer whether they would like to initiate a dispute and have InstaHire provide a copy of the adjusted report to the prior end-users of their choice. If they say yes, send a legally compliant dispute resolution letter to the consumer, confirm which end users the consumer would like the revised report sent to, and send out the revised report to the designated end user(s).
Step 6: Retain Records
InstaHire is required to retain records for seven (7) years relating to consumer’s submissions related to human trafficking and InstaHire’s compliance with the law. This includes retaining consumer’s submissions, communications between InstaHire and the consumer, actions taken by InstaHire, and the reasons why InstaHire declined to block or rescinded a block of items of adverse information identified by the consumer. You are required to save all documents and communications related to human trafficking within InstaHire’s internal systems.
