Orange Tree Privacy Policy

Notice | Purpose

• Requests for Consumer Reports are initiated by Orange Tree Clients.

  • Clients have agreed to request Consumer Reports only in those cases where there is a permissible purpose to do so, where the Client has disclosed to the consumer that they intend to procure a Consumer Report, and where they have received the consumer’s authorization to do so, as allowed by law, or where the subject of the Consumer Report being created is the Client.

• Consumer information is collected from clients and consumers directly.

  Consumer Reports are prepared using information provided from many sources, including but not limited to:

  • Orange Tree Clients, consumers, 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.

• Sharing of consumer information.

  The Consumer Reports that are created for Orange Tree Clients are shared only with the Client that requested the Consumer Report and their agent(s), and End User as defined under the FCRA, or with the consumer about whom the report was prepared (upon the request of the consumer).

Choice | Right to Object

• U.S. Residents

  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 Consumer Report about you. By consenting to the procurement of a Consumer Report 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 Consumer Report.

• European Union Residents

  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. 

• Withdrawing Consent

  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.

• Accountability for Onward Transfer

  In connection with preparing Consumer 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.

• Security | Data Integrity | Access

  Sensitive Consumer 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 Consumer 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 Consumer 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 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 standards for the protection of personal information of residents of the Commonwealth of Massachusetts.

  Sensitive Consumer information and Consumer Reports are retained for a minimum of six (6) years in accordance with FCRA limitation of liability time frames. Consumers may opt out of Orange Tree receiving information about them by not consenting to the Consumer Report (background screening report) for our Client (for example, you yourself, or your current or prospective employer).  In general, once a Consumer 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 consumer may exercise their right to access and correct information in their file or dispute information in their file, as allowed by Privacy Shield principles, state law, the federal FCRA law, or the Global Data Protection Regulation (GDPR). The Consumer Financial Protection Bureau’s Summary of Rights document provides a list of 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 Privacy Shield principles, state law , the federal FCRA law, or the Global Data Protection Regulation (GDPR)) 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 consumer 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 Consumer Report 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.

• Personal Information Disclosure: United States or Overseas

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

• Independent Recourse Mechanism/Enforcement | Liability

  In compliance with the EU-US Privacy Shield Principles, 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 under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, 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.

  The Federal Trade Commission (FTC) has enforcement authority over Orange Tree’s compliance with the Privacy Shield.  Under certain circumstances, an individual may invoke “last resort” binding arbitration to determine whether a Privacy Shield organization has violated its obligations under the Privacy Shield Framework.  A Privacy Shield organization may remain liable for information it transfers to 3rd parties.