Last updated: October 15, 2020
Click here to go directly to California Investigative Consumer Reports Privacy Notice
Scope of this Policy
This policy will describe the following:
- What information we collect;
- How information is used;
- With whom it is shared;
- How information can be corrected;
- How it is secured; and,
- Who to contact with concerns or questions about our privacy practices.
Pinkerton’s Website and our services are not directed at children.
Changes to this Policy
This policy may be subject to updates. Any future material changes or additions to the processing of personal information as described in this policy will be communicated to you through an appropriate channel. For example, we may place a prominent notice on our Website or email you to let you know of an updated policy.
Information Collection on our Website
Pinkerton strives to limit its collection of personal information to that necessary for the offering and administration of our services. Our Site collects the following types of information when you visit:
- Personally identifying information; and,
- Non-personally identifiable information.
Personally Identifiable Information
Personally identifying information (PII or “personal data”) is any information that can identify you, such as your name, address, and IP address. It does not include anonymized, aggregate or statistical information. Based on your relationship with us, you may be asked to provide certain PII as described below. If certain information is requested but not mandatory, Pinkerton will identify which information is required.
- Online Questions or Requests (which may be collected through our Site or offline). When you are requesting materials or information from Pinkerton, we may collect your name, job title, address, email address, phone number, IP address, company name, country/state of residence, photocopy of your ID and other PII, as well as professional interests and the reasons why you are requesting the Pinkerton services or products.
- Job Applicants. When you apply for employment with Pinkerton we will collect your name, email address, country of residence, physical address, cell phone number and any information you include in your resume which you upload through the Site.
- Employment Screening Client Login When you use the client log-in portal for background checks, drug testing, or electronic I-9 completion, you will be sent to our vendors’ system and webpage where they will collect login information such as account, username and/or password in order to access your account and perform the requested services.
- Background Screening Services (which may be collected through our Site or offline). When your employer or landlord requests a background check, Pinkerton may collect your PII both online and offline to process the request.
- Blog, Insights, Newsletters, Case Studies, and White Papers. When you subscribe to our communications, we will collect your email address.
- Global Alliance Membership. When you sign up to become a Pinkerton contractor we will collect your email address and IP address. If you apply to become a Pinkerton contractor, we will also need to collect your name, company name, job title, address, email address, phone number, IP address, country/state of residence, and other PII.
- Billing Information (which may be collected through our Site or offline). If you purchase our services you may need to provide Pinkerton with payment and billing information, such as your credit card details and billing address.
Non-personally Identifiable Information
When you visit our Website, we may collect and store general Internet data, such as your domain name, browser type, device, date and time of access, which of our web pages you visited, the referring Uniform Resource Locator (URL) and how long you spend on each page. This information may be collected to assist us in making improvements to our Website and to administer our Website. We do not link this information to any PII. Pinkerton may employ third party companies and individuals to facilitate these services (e.g., maintenance, analysis, audit, development). These third parties have limited access to your information and only to perform these services or tasks on our behalf.
Personally identifying information collected through our Site may be used to:
- To respond to your inquiries, process requests or otherwise correspond with you regarding employment, supplier affiliations, programs or services;
- Enroll you if you signed up to receive Pinkerton updates, free subscriptions or blog postings;
- Conduct pre-employment background checks, commercial background checks and tenant screening services as requested by customers of background check reports such as employers, investors, and landlords;
- Provide you with marketing information about Pinkerton’s services and products;
- Process billing, invoice and payment functions when you request Pinkerton services; and,
- Analyze and improve Pinkerton’s services.
Most browsers are set to accept cookies but users can change the setting to block cookies or otherwise choose how cookies are handled. Although disabling cookies will not interfere with your ability to access the Site, users will need to accept cookies to use certain services on the Site.
You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features of our Site will not work as intended. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser.
Third-Party Links and Websites
This policy applies to Pinkerton’s Website. However, you are able to access third-party sites through our Site by, for example, clicking on hyperlinks to those third-party sites from within our Site. We are not responsible for the content or privacy practices of any third-party sites, and if you visit those websites, we encourage you to review their respective privacy policies. Third party links on our Site are provided for your convenience and to provide further information or serve as a resource. They do not signify that we endorse the website(s). Pinkerton exercises no control whatsoever over such other websites and web-based resources and is not responsible or liable for the availability thereof or the content, advertising, products or other materials thereon. Pinkerton shall not be responsible or liable, directly or indirectly, for any damage or loss incurred or suffered by any user in connection therewith. Your access and use of linked websites, including information, material, products and services therein, is solely at your own risk.
Choice, Opt-Out and How We Respond to Do Not Track Signals
As a user of our Website, you make the decision whether to proceed with activities that request PII, such as requesting follow-up contact regarding our services and products, applying for employment, receipt of email communications from us, or receipt of our newsletter(s), blog or other communications. Note, however, that if you do not provide the requested information, you may not be able to complete certain transactions or receive information from us. If, after subscribing to receive emails or other electronic communications from Pinkerton you no longer wish to continue receiving such from us, you will be provided with instructions in our communications on how to opt-out of such communications, including by unsubscribing. In addition, you can also contact us through the Point of Contact information provided in this policy.
Pinkerton does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. To learn more about the choices you have regarding online tracking, please visit these sites:
Information Sharing and Disclosure
Pinkerton may disclose information we collect through this Site:
- To Pinkerton’s parent, subsidiaries and affiliates;
- To complete a transaction that you request through our Site;
- To complete a transaction requested by a third party for background screening purposes;
- To government agencies or Pinkerton’s suppliers or vendors in order to conduct background investigations as requested by your employer or landlord;
- When required by law, subpoena or other legal process, when pertinent to judicial or governmental investigations or proceedings;
- When necessary to investigate, take action or prevent suspected or actual illegal activities, fraud, or potential threats to safety or personal physical safety; and,
Pinkerton retains personal information as needed to provide you services or product information, respond to inquiries, consider your employment application, partner with you, or as required by contractual, statutory or other legal obligations.
Security and Confidentiality
Pinkerton strives to protect personal information that we collect, maintain and disclose through the use of appropriate and reasonable administrative, physical and technical safeguards. For instance, our products and/or services online are transmitted through a secure sockets layer (SSL) transmission, which is a protocol for establishing a secure connection for transmission of your personal information. Further, we have security protocols and measures in place to ensure confidentiality of PII and to protect the PII we maintain about you from unauthorized access or alteration as well as unlawful disclosure. These measures include internal and external firewalls, physical security and technological security measures, as well as encryption of certain information and password protection for account information. Our security program is designed to: (1) ensure the security and confidentiality of personal information; (2) protect against any anticipated threats or hazards to the security or integrity of the information; and (3) protect against unauthorized access, use, alteration, or unlawful disclosure of the information that could result in substantial harm or inconvenience to any individual. In the course of business, Pinkerton may collect or ask that you disclose your Social Security Number. To the extent practicable, Pinkerton protects the confidentiality of all information we collect, including Social Security Numbers. Accordingly, we prohibit the unlawful disclosure of personal information, including Social Security Numbers, and limit access to same. We dispose of such information by taking reasonable measures to protect against unauthorized access to or use of the information.
Point of Contact
- General Counsel
- Pinkerton Consulting & Investigations, Inc.
- 101 N Main St. Suite 300 Ann Arbor MI 48324
By Email: European Union (“EU”) Data Subjects – to assert Your Rights (as described in the Your Rights section) under the General Data Protection Regulation (GDPR) contact:GDPRSubjectAccessRequest@pinkerton.com
Your EU Contact: Kyle Dukes, Global Director, Information Systems & Technology — by sending an email to: GDPR.EU@pinkerton.com.
U.S. Consumers – to assert your rights under the Fair Credit Reporting Act (15 U.S.C. § 1681 et seq.) (“FCRA”) and U.S.-based state consumer reporting laws contact: PES.firstname.lastname@example.org
PRIVACY NOTICE: CALIFORNIA INVESTIGATIVE CONSUMER REPORTS
This notice is provided for California residents.Under California law (Cal. Civ. Code § 1786 et seq.), an “investigative consumer report” is a consumer report containing information on a consumer’s character, general reputation, personal characteristics or mode of living. Under California law, Pinkerton compiles “investigative consumer reports” about individuals and provides them to businesses for background screening related to employment purposes, including whether to hire, promote or retain an individual.
Personal Information Disclosure: United States or Overseas
In connection with our preparation and processing of investigative consumer reports under California law, we are required to advise you that Pinkerton does transfer personal information about you to our authorized service providers and affiliates outside the United States and its territories.
Privacy Practices. Pinkerton’s policies and procedures for preparing and processing of investigative consumer reports are designed to comply with the requirements of the California Investigative Consumer Reporting Agencies Act (Cal. Civ. Code §1786 et seq.) and the Fair Credit Reporting Act (15 U.S.C. § 1681 et seq.). Pinkerton, for example, maintains policies and procedures designed to limit the purposes for, and circumstances under which, we furnish investigative consumer reports. Pinkerton maintains reasonable procedures to assure maximum possible accuracy of the information concerning the individual about whom the report relates. Pinkerton provides individuals with the ability to request, upon proper identification, access to information we hold about them in our investigative consumer reporting files. Pinkerton conducts reinvestigations of the accuracy and completeness of information at the individual’s request. Pinkerton also has implemented administrative, physical and technical safeguards designed to protect the information that we maintain in our investigative consumer reporting files.
To obtain additional information about Pinkerton’s privacy practices and policies in the event of a compromise of your information, please contact:
- General Counsel
- Pinkerton Consulting & Investigations, Inc.
- 101 N Main St. Suite 300 Ann Arbor MI 48324
This section includes details of the purposes for which we use personal data and also the different legal grounds upon which we process that personal data. We use personal data to provide and improve services and for other purposes that are in our legitimate interests, as well as for compliance purposes. Some laws require us to explain what may happen to your personal data when it is transferred outside your home country and to, for instance, the United States. These laws also may require that we describe our lawful basis for processing your personal data. This section describes both as other rights all individuals have.
Pinkerton is a global organization and your personal data may be stored and processed outside of your home country, including in countries that may not offer the same level of protection for your personal data as your home country. We have measures in place to ensure that when your personal data is transferred internationally, it is subject to appropriate safeguards in accordance with data protection laws. Often, these include contractual safeguards or participation in the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks.
Pinkerton has vendors, servers, systems, and support around the world. We collaborate with third parties like government agencies, education and employment verifiers, criminal record providers and other suppliers of background screening services located around the world to serve the needs of our business, workforce and customers. We take appropriate steps to ensure that personal data is processed, secured and transferred according to applicable law. In some cases, we may disclose or transfer your personal data within Pinkerton or to third parties in areas outside of your home country, including to countries that have not been declared adequate for the purposes of data protection by the European Commission. To learn more about Pinkerton’s certification and our Privacy Shield policy click here and here.
If you are outside the United States and using our Website, your personal data may be transferred outside of your home country to the United States to Pinkerton or a third party service provider and will be subject to use and disclosure under the laws of the United States. It may also be accessible to law enforcement and national security authorities in the United States. For instance, when you apply for employment on our Website or request that we contact you, you provide personal data to us. If you do not provide mandatory personal data, such as name and email you may not be able to complete certain online transactions, or apply for employment.
Personal Data Processing Purposes
We use personal data for a number of legitimate interests, including to provide and improve our services, administer our relationship with you and our business, for marketing and in order to exercise our rights and responsibilities. More detailed information about these legitimate interests is set out below.
- Providing Background Screening Services. Pinkerton acts as a processor when processing personal data on behalf of our controller customers who request background checks for employment screening or vetting purposes to determine eligibility for employment, or retention with, a particular company. As a general rule, due in part to legal obligations, Pinkerton requires individuals provide consent to such checks and in addition, our customers’ basis for the processing of personal data may be the legitimate interests of the company.
- Administering the Relationship with our Clients and Prospective Clients. Pinkerton processes personal data to administer our relationship with our customers and prospective customers and to provide employment screening services, security risk management services,investigations, protective security, response services and intelligence services. This routinely includes: contacting you to discuss matters for which you have engaged us or those for which you may engage us to handle on your behalf. This also includes due diligence, fraud prevention,processing payments, accounting, auditing, billing and collection, and support services. Depending upon the specific legal or other services we reengaged to provide, this processing is undertaken to carry out our contract with you or in anticipation of entering into such a contract.
- Administering the Relationship with our Professional Contacts and Business Partners. Pinkerton processes personal data to maintain professional relationships and to establish, administer and maintain relationships with our business partners. This includes communicating with you and administering our relationships and, in the case of our business partners, administering our business relationships including due diligence,fraud prevention, processing payments, accounting, auditing, billing and collection, and support services. Depending on the circumstances, this processing is done on the basis of our legitimate interests or, in the case of contractual business partners, this processing is undertaken to carry out our contract with you or in anticipation of entering into such a contract. Processing of personal data about our professional contacts is done pursuant to our legitimate business interest.
- Compliance with Legal Obligations. We also process your personal data in order to comply with our legal and regulatory obligations. We also process personal data to establish, exercise and defend our legal rights and any legal proceedings which may arise; and to prevent, detect and respond to actual or potential fraud or other illegal activities.
- Visits to our Website. If you visit our Site, we collect data about your visit as well as personal data that you choose to provide through our Website pursuant to our legitimate interests. We may use your personal data to provide you with marketing as permitted by law.
- Newsletters, Blogs, White Papers and Similar Communications.Pinkerton also may process personal data to send you information about new developments or Pinkerton activities in the form of newsletters, event invitations, alerts, blog postings, or other similar communications. Depending upon the nature of the communication, these messages may be sent to you with your consent or pursuant to our legitimate interests. If you do not wish to receive such communications, you can opt-out of receiving future messages by email by opting out using the link in the message or by contacting the Point of Contact provided in this policy.
Your Rights – EU and UK Data Subjects
You may have rights under European, United Kingdom and other laws to have access to your personal data and to ask us to rectify, erase and restrict use of, your personal information. You may also have rights to object to your personal data being used, to ask for the transfer of personal data you have made available to us and to withdraw consent to the use of your personal data. Further information on how to exercise your rights is explained below.
We will honor your rights under applicable data protection laws. You have the following rights under European and/or UK laws, and may have similar rights under the laws of other countries.
- Right to rectification: The right to have inaccurate information about you corrected or removed.
- Right to erasure (“right to be forgotten”): The right to have certain personal data about you erased.
- Right to restriction of processing: The right to request that your personal data is only used for restricted purposes.
- Right to opt out of marketing: You can manage your marketing preferences by unsubscribe links found in the communications you receive from us or by contacting us through the Point of Contact provided in this policy.
- Right to object: The right to object to processing of your personal data in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests.
- Right to data portability: The right to ask for the personal data you have made available to us to be transferred to you or a third party in machine-readable format.
- Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal data. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent.
These rights are not absolute and they do not always apply in all cases. Also understand that in some cases, particularly as it relates to background screening services, your withdrawal of consent to the processing of your personal data may impact your eligibility or retention of employment.
In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why.