JobTrax, Inc. Privacy Statement

Last Updated: August 2021

This privacy statement describes how JobTrax Inc. ("JobTrax") collects, uses, and shares personal data about individuals in the United States. JobTrax prepares consumer reports for our clients as allowed by the Fair Credit Reporting Act(FCRA) and other applicable state and federal law. 

Employment Data

JobTrax collects employee personal data from certain employers with whom it has a contract to do so. Pursuant to those contracts, JobTrax verifies employment and uses employer-provided information to offer automated employment and income verification services to third parties such as lenders and banks. The collection, use, and sharing of personal data for these purposes is regulated by state and federal law, including FCRA. JobTrax restricts the use of personal data collected for employment verification to those purposes identified herein. 

California Residents

Please note this privacy statement also contains a section devoted to the rights of California residents under the California Consumer Privacy Act of 2018 ("CCPA") and subsequent amendments.

Personal Data Collected

JobTrax collects the following general categories of personal data:

Name and contact information. First, middle, and last name. If an address is provided, it will only be a work address. JobTrax does not collect personal mailing addresses.

Demographic information. Date of birth.

Professional or employment-related information. Information regarding employment status, history, and compensation. This information is provided by employers related to JobTrax's provision of employment and compensation verification services to employers.

Sources of Personal Data

We collect personal data from the following sources:

Employers. Companies provide JobTrax with employment and compensation information about their current and former employees, including some limited personal data. We receive this information as part of providing services to our customers. JobTrax only uses the data provided for the purpose of providing employment and compensation verification services. JobTrax does not sell personal data for marketing purposes.

 

How We Use Personal Data

Business Purposes

We may use or disclose the personal data we collect for one or more of the following Business Purposes:

• To fulfill or meet the reason for which the information is provided.
• To carry out JobTrax's obligations and enforce its rights arising from any contract entered into between an employer and JobTrax.
• For authentication purposes.

Sharing Personal Data

We sometimes share personal data with third parties, including service providers, to carry out the above Business Purposes. JobTrax may also share personal data with third parties to whom you consent to us disclosing your personal data. JobTrax contracts with third parties to restrict their use of personal data to only those purposes specified in those contracts and requires the third party to maintain securely and confidentially all personal data.

We also share personal data for the following reasons: 

Disclosure required by law or legal process.  JobTrax may release personal data to third parties if required to do so under applicable law or legal process.

Changes in our corporate structure. If all or part of our company is sold or merged, if we make a sale or transfer of assets, or in the unlikely event of a bankruptcy, subject to the other provisions of this Privacy Statement, we may transfer your information, including your personal data, to one or more third parties as part of that transaction.

Commercial Purposes

We do not sell personal data to third parties for commercial purposes.

Choices and Control Over Your Information

In general, choices concerning our collection, use and disclosure of information are limited to those provided by law. For details of choices under the Federal Fair Credit Reporting Act, please see the FCRA Summary of Rights.

 

Security

JobTrax is committed to protecting the security of your personal data and uses a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. However, no data transmission or storage can be guaranteed to be 100% secure.  As a result, while we strive to protect the personal data we maintain, we cannot ensure or warrant the security of any information that you transmit to us. JobTrax complies with applicable data protection laws, including security breach notification laws.

JobTrax maintains records of CCPA consumer requests for at least 24 months and generally maintains certain employment and payroll records for a period of 5 years.

California Residents

The below section supplements our privacy statement to provide California residents with the information needed to exercise their rights under the CCPA.

Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples
Contact information.	First, middle, and last name; work address; and email address.
Personal information.	Date of birth.
Employment information.	Employee ID number; work address; hire date and termination date, if applicable; job title; length of employment; type of employment (temporary, permanent, or seasonal); average hours worked; and compensation information (base pay, overtime, commission, and total compensation).

 

 Under the CCPA, personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:

• certain health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the FCRA, the GLBA or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of information listed above from the categories of sources listed in the Sources of Personal Data section above. 

Sharing Your Personal Information

In the preceding 12 months, we have disclosed the following categories of information for the business purposes described above: 

• Identifiers.
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
• Protected classification characteristics under California or federal law.
• Professional or employment-related data.
• Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) only the degree to which a student employment assignment qualifies and is protected under FERPA.

We disclose these categories of personal information for business purposes to the following categories of third parties:

• Our service providers and other third parties that cannot use personal information collected by or on behalf of us for their purposes, including business process outsourcing providers, data processors and storage providers and internet service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with the services we provide to you.

Selling Your Personal Information 

In the preceding 12 months, we have not sold any categories of information as we do not sell any categories of personal information.

Rights of California Residents 

Pursuant to the CCPA, California residents have the right to submit the following requests to JobTrax. To submit these requests, please email JobTrax at info@verifyjobhistory.com or call our customer service team at 440.247.2100 during regular business hours of 8:00 – 5:00 Eastern Time. JobTrax is prohibited from discriminating against in any way in response to your exercise of any of these rights. This means we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
• Offer a product enhancement or financial incentive that is contingent on you sharing personal information, unless that incentive is reasonably related to the value provided to us by that collection.

To ensure personal information security and prevent fraudulent requests, we may need to collect personal information and other information such as your name, email, or transaction history to verify your identity. Any authorized agents making requests on your behalf need to provide similar information for verification.

Access

You have a right to request JobTrax provide you with the following information, covering the 12 months preceding the date your request is submitted.

• The categories and specific pieces of personal information collected about you
• The categories of sources of the personal information collected about you
• The business or commercial purposes for collecting your personal information; we do not sell your personal information
• The categories of third parties to whom we disclosed your personal information for a business purpose

Deletion

You have the right to request that JobTrax delete the personal information collected about you, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Opt-Out

JobTrax does not sell your personal information and as such, there is no opt-out option.

  

Changes to this Privacy Statement 

JobTrax may change its online privacy statement in the future. If we make changes to this privacy statement we will post the revised privacy statement and its effective date on this website.

 

Contact Us

If you have questions or comments about this privacy statement, please visit our Contact Form at https://www.verifyjobhistory.com/Contact.asp or write to the Chief Executive Officer, JobTrax Inc., 10 Center Street, Chagrin Falls, OH 44022. Please reference "JobTrax Privacy Statement," when contacting us about this privacy statement.