1. Scope
This Privacy Policy explains how EPASS Inc., doing business as PROFID (“PROFID,” “we,” “us,” or “our”), collects, uses, discloses, retains, and protects personal information in connection with theprofid.com, our portals, and our U.S. employment background-screening services.
It applies to: (a) applicants, employees, contractors, and other individuals who are the subject of screening (“Consumers”); (b) employers and authorized business users (“Clients”); and (c) visitors to our public website (“Site Visitors”).
The services currently covered include identity onboarding and verification, Social Security number trace, criminal-record searches, sex-offender and watchlist searches, motor vehicle records where available, report delivery, consumer disputes, and Standard PROFID Analytics. Products not activated for a Client are not covered merely because they may appear in a demonstration or future product description.
2. Information We Collect
| Category | Examples |
|---|---|
| Identifiers and contact information | Name, aliases, date of birth, address history, email, telephone number, Social Security number or partial Social Security number, and account identifiers. |
| Government and driving information | Identity-document details, document images, driver-license information, motor vehicle record information, source forms, and permitted government identifiers. |
| Identity-verification information | Selfies or short videos, facial-comparison or liveness data, extracted document fields, verification results, device/session signals, and fraud-prevention indicators. |
| Screening information | Court and agency records, criminal and registry information, watchlist results, source status, matching information, and other categories specifically ordered and legally activated. |
| Employment workflow information | Requesting employer, position, work locations, purpose, notices, authorizations, electronic-signature evidence, delivery records, and review status. |
| Reports and analytics | Raw consumer reports, corrections, dispute status, and Standard PROFID Analytics such as display values, flags, factual summaries, explanations, and methodology or model version. |
| Technical and security information | IP address, browser and device information, authentication events, access logs, security events, cookie or similar technology data, and support communications. |
| Client and business information | Business identity, ownership, addresses, authorized users, permissible-purpose certifications, billing records, contracts, and support communications. |
3. Sources of Information
- You, including information entered in the consumer portal and documents or evidence you submit.
- The requesting employer or another credentialed Client with a lawful permissible purpose.
- Courts, government agencies, motor vehicle agencies, registries, and other lawful public-record sources.
- Authorized data providers, consumer reporting agencies, identity-verification providers, hosting, security, communications, and support providers.
- Automatically from the website, portal, device, and session used to access the services.
4. How We Use Information
- Authenticate identity, prevent impersonation and fraud, and connect the correct person to the correct screening request.
- Perform, verify, quality-control, and furnish authorized background-screening and motor vehicle record services.
- Generate Standard PROFID Analytics from an eligible completed report as a non-authoritative organizational and visual review aid.
- Provide reports, notices, file disclosures, consumer communications, disputes, reinvestigations, corrections, and delivery evidence.
- Credential Clients, confirm permissible purpose, administer accounts, bill for services, and enforce contracts and source requirements.
- Secure, monitor, debug, maintain, and improve the reliability of our website and services.
- Comply with law, legal process, recordkeeping, regulatory requests, audits, and legal claims.
PROFID does not use Consumer Report Information, identity-verification information, or biometric information for advertising. We do not use identifiable Consumer Report Information to train or fine-tune a generalized model without a separate lawful basis, required notice and consent, and any required written agreement.
5. How We Disclose Information
We disclose personal information only as reasonably necessary for the authorized service, a legal requirement, security, or another purpose described in this Policy. Recipients may include:
- The credentialed employer or Client that requested the screening.
- Courts, government agencies, registries, motor vehicle agencies, and data sources needed to perform or verify an authorized search.
- Identity, hosting, security, communications, support, and technology providers acting under contractual restrictions.
- The Consumer, including through file disclosure, report delivery, dispute, or correction procedures.
- Professional advisers, insurers, auditors, transaction counterparties, or governmental authorities when legally permitted or required.
PROFID does not sell personal information and does not share personal information for cross-context behavioral advertising. Public website cookie practices are described in Section 11.
PROFID stores and processes personal information in the United States. Personal information is not transferred to, accessed from, or processed outside the United States or its territories. Personnel and contractors located outside the United States are prohibited from accessing production systems or personal information. They may access only source code, technical documentation, and test environments that do not contain real personal information.
6. Consumer Reports, Identity Verification, and Analytics
PROFID is a consumer reporting agency when it prepares or furnishes a consumer report. The requesting employer determines whether to hire, retain, promote, reassign, or take another employment action. PROFID does not make or recommend the final employment decision.
Identity verification may use automated document authentication, facial comparison, liveness, and fraud-detection methods. A separate biometric notice and consent is presented before regulated biometric processing. A non-biometric or manual identity-verification path is available. Biometric information is not used as an employment-suitability factor or individual analytics input.
Standard PROFID Analytics may use automated, rules-based, statistical, machine-learning, or generative methods to organize verified report content. The raw report is the authoritative record and controls any conflict. A score, color, label, or summary is not a hiring recommendation, prediction of future conduct, or substitute for human review.
7. Retention and Deletion
| Record | Retention rule |
|---|---|
| Consumer documents and audit evidence | Generally at least five years after the order when hosted by PROFID, unless a shorter binding legal or source schedule applies. |
| California investigative consumer reports | At least two years after the report is provided. |
| Motor vehicle recipient-and-purpose records | At least five years. |
| Biometric source data | Generally destroyed within 30 days after verification is completed, canceled, or abandoned, subject to the Biometric Privacy Policy and documented limited exceptions. |
| Reports, analytics, disputes, security logs, and source data | Only for the period permitted by applicable law and source contracts. Source payload may be deleted earlier when a binding source schedule requires it. |
| Website, client, billing, and support records | For the relationship, operational need, applicable limitation period, tax or accounting requirement, security need, or legal hold, then securely deleted or de-identified. |
Deletion from backups may occur through ordinary secure backup rotation. A valid legal hold or non-waivable legal obligation may require limited retention beyond the ordinary period.
8. Security
PROFID maintains administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including access controls, authentication, encryption in transit and at rest where commercially reasonable, logging, vendor oversight, incident response, personnel confidentiality, and secure disposal. No system is completely secure, and we do not guarantee that unauthorized access can never occur.
9. Your Rights and Requests
Depending on the information and applicable law, you may request access to your PROFID file, a copy of a report, recipient information, correction, deletion, information about processing or recipients, or review of a denied privacy request. You may dispute inaccurate or incomplete consumer report information without charge. Some records cannot be deleted while retention is required by the FCRA, state consumer-reporting law, the DPPA, a source contract, security needs, or a legal hold.
To protect your information, we may require reasonable proof of identity and may verify an authorized agent. We will not retaliate against a Consumer for exercising a protected right.
10. New York Consumer Report Rights
For a New York employment screening, the requesting employer must provide the notices and obtain the authorization required by New York and federal law. When criminal conviction information is furnished, the employer must provide the applicable New York Correction Law Article 23-A material. PROFID provides the separate New York forms through the applicable workflow; those forms are not replaced by this Policy.
- File disclosure:after proper identification, a New York Consumer may request a clear and accurate disclosure of information in PROFID’s file, the sources of that information subject to the limited investigative-source exception, and the recipients of employment-purpose reports furnished during the preceding two years.
- Method: a Consumer may request disclosure through the portal, by email, phone, or mail. PROFID may provide a decoded written copy or explanation of codes used in the file.
- Disputes: a Consumer may dispute inaccurate or incomplete information without charge. PROFID will conduct the reinvestigation and correction procedures required by applicable law and will update or suppress information when required.
- Public records: PROFID uses reasonable procedures designed to report public-record information completely and up to date to the extent practicable and records the current status during a required reinvestigation.
- New York City: for positions located in New York City, performed there part time, or associated with a New York City office, PROFID currently furnishes the raw report without Standard PROFID Analytics unless a compliant automated-employment workflow is separately activated. The employer, not PROFID, is responsible for the conditional-offer and Fair Chance process, written assessment, disclosure of the criminal-history information relied upon, and a response period of at least five business days before a final adverse decision.
11. Cookies and Website Choices
The public website may use essential cookies and similar technologies needed for security, preferences, and basic operation, and may use analytics technologies to understand website performance. Any optional advertising or cross-context behavioral advertising technology must be disclosed and controlled through the website cookie banner before activation. Consumer Report Information, identity-verification information, and biometric information are not used for advertising cookies.
You may use available browser or cookie-banner controls. Blocking essential cookies may prevent parts of the website or portal from working.
Do Not Track, Global Privacy Control, and cross-site tracking. Some browsers transmit a Do Not Track signal, and some browsers or extensions transmit an opt-out preference signal such as Global Privacy Control. PROFID does not sell personal information or share personal information for cross-context behavioral advertising; accordingly, those opt-out signals do not change those practices. PROFID does not otherwise respond to browser Do Not Track signals. Third parties may collect information about a Site Visitor’s online activities over time and across different websites only through cookies or similar technologies described in this Section and any applicable cookie banner. PROFID does not authorize those technologies to use Consumer Report Information, identity-verification information, or biometric information for advertising or cross-context behavioral advertising.
12. Separate Notices
- California Privacy Notice: https://theprofid.com/california-privacy
- Biometric Privacy Policy: https://theprofid.com/biometric-policy
- Consumer dispute information: https://theprofid.com/dispute
13. Children
PROFID services are not directed to children under 13. We do not knowingly collect personal information from a child under 13 through the public website. Employment screening involving a minor may proceed only through a legally approved workflow with the required parent, guardian, employer, and source documentation.
14. Changes to this Policy
We may update this Policy to reflect changes in law, services, or data practices. We will post the updated Policy with a new effective date and provide additional notice when required by law.
15. Contact
Privacy, file disclosure, and dispute contact
EPASS Inc. d/b/a PROFID, Privacy and Consumer Relations
Email: support@theprofid.com