Orange Tree Privacy Policy

Requests for background screening reports are initiated by Orange Tree Clients that have agreed to request background screening reports only in those cases where there is a permissible purpose to do so, where the Client has made disclosure to the subject that they intend to procure a background screening report, and where they have received the subject’s authorization to do so, as allowed by law, or where the subject of the background screening report being created is the Client. Subject information is collected from Orange Tree Clients, from subjects directly and from authorized vendors and sources. Background screening reports are prepared using information provided from many sources, including but not limited to Orange Tree Clients, subjects, court and law enforcement agencies, local, state and federal agencies and record repositories, schools and universities (public or private), employers, references, private databases, public record researchers, credit bureaus and other Consumer Reporting Agencies. The background screening reports that are created for Orange Tree Clients are shared only with the Client that requested the background screening reports and their authorized contact(s), an End User as defined under the FCRA, or with the subject about whom the report was prepared (upon the request of the subject).

If you are a U.S. resident and you do not wish to have your personal data made available to our Client (for example, you yourself, or your current or prospective employer), do not authorize our Client to procure a background screening report about you. By consenting to the procurement of a background screening reports and submitting information to us or to us on behalf of our Client, you are agreeing to allow Orange Tree to disclose information about you to our Client and to our sharing that information with authorized vendors, subcontractors or information sources, for the purpose of completing the requested background screening report.

If you are a European Union resident or reside in other countries where Orange Tree is doing business, you may choose not to submit personal information to Orange Tree through the site or through forms provided by our Client for that purpose. You have been provided a consent form either by us or our Client. By filling out and submitting the consent form you expressly agree to provide personally identifying information and you consent to our use of that information in accordance with this policy.

To withdraw your consent, or to restrict or object to processing contact Heidi Seaton, Vice President of Compliance at hseaton@otes.com or by phone toll free 800-886-4777, extension 7121.

In connection with preparing background screening reports for our Clients, we may in some instances employ other companies and individuals as our vendors or subcontractors to complete parts of the background screening process on our behalf. Subcontractors are contractually obligated to use and maintain the confidentiality of personal information in a manner consistent with this policy. These companies and individuals may not share any such information with any third party, other than their authorized subcontractors, Orange Tree's subcontractors or Orange Tree. Except as described in this policy or required by law, we will not use or otherwise disclose any of the Sensitive Consumer information that you provide or that we collect from third parties or other sources. Note however, that Orange Tree may be required to disclose information that we collect in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. We may use non-sensitive information (like your name and email address) to market services to you.

Sensitive subject information is protected by reasonable and appropriate administrative, physical and technical measure and is stored in a secure manner within a secure facility. Use of background screening reports is restricted to users approved by Orange Tree Clients and Orange Tree agents with a legitimate business need to conduct background checks requested by Orange Tree Clients. Authorized Client users to the ClientConnect site access subject background screening reports in a secure manner using strong encryption and strong password protection. Data is stored in a secure manner in accordance with security best practices and have been audited by third parties.

Orange Tree maintains written internal Information Security Policies to which all Orange Tree employees and agents must adhere. In addition, all Orange Tree agents who have access to Sensitive Consumer information have signed non-disclosure agreements. Our Information Security Policies conform to requirements related to industry standards for the protection of personal information including of residents of the Commonwealth of Massachusetts.

Sensitive subject information and background screening reports are retained for a minimum of six (6) years in accordance with FCRA limitation of liability time frames. Subject may opt out of Orange Tree receiving information about them by not consenting to the background screening report for our Client (for example, you yourself, or your current or prospective employer). In general, once a subject has consented to such a report, Orange Tree retains the information on file for the six (6) year period.

Information sources that may be used in producing Consumer Reports are not maintained by Orange Tree, therefore Orange Tree cannot guarantee that the information from such sources is current or accurate. A subject may exercise their right to access and correct information in their file or dispute information in their file, as allowed by state law, the federal FCRA law, the General Data Protection Regulation (GDPR) or other applicable law. The Consumer Financial Protection Bureau’s Summary of Rights document provides a list of US consumer rights, and the Fair and Accurate Credit Transaction Act (FACT Act) also includes additional rights. See the Consumer Financial Protection Bureau’s Summary of Rights document. To request to access or correct the information in your consumer file (as allowed by applicable law) or to make a request for a free annual file disclosure (as allowed by the FCRA) contact Orange Tree toll free at 877-458-7137. If you are a subject and you believe your personal information has been compromised, please contact Heidi Seaton, Vice President of Compliance at hseaton@otes.com or by phone toll free 800-886-4777, extension 7121 for assistance or information.

If you are an European Union Data subject, you have the right to have your personal information erased under some circumstances. Contact the employer (our Client) that requested we prepare a background screening reports about you to request erasure. If you need help contacting the employer (our Client), please contact Heidi Seaton, Vice President of Compliance at hseaton@otes.com or by phone toll free 800-886-4777, extension 7121 for assistance or information.

Orange Tree agents are stationed in the United States and abroad, however subject information is maintained in United States.

Orange Tree commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Orange Tree at:

By phone: 800-886-4777, ext. 7121

By email: hseaton@otes.com

By mail:

Orange Tree Employment Screening

Attn: Heidi Seaton

7275 Ohms Lane

Minneapolis, MN 55439

Orange Tree has further committed to refer unresolved privacy complaints through the Better Business Bureau, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.