Last updated: December 22, 2018
- “Cookies” are small text files offered to a user’s computer by web servers in order to keep track of the user’s browser as a website is navigated.
- “Personal Information” means any information about an identifiable individual.
- “Principals” means individuals that own and/or are involved in the management of a business.
- “Us”, “we”, “our” and “Certn” means Certn Holdings, Inc.
- “Website” means the website operated by Certn and located at https://certn.co.
Certn is an information and data analytics company with the goal of offering the highest quality alternative to the current consumer background screening, credit-related products and services. Today, we serve the business community by providing consumer and business risk, fraud and identity management information, as well as analytics tools to help our clients make informed decisions.
An overview of our business
We facilitate the process of hiring for employment and renting to tenants by providing background screening, consumer credit, and social profiles, in order to help our clients make informed decisions about their Applicants and to allow Applicants to put their best foot forward. Our clients are located in both Canada and the USA and include employers, banks, property managers and other institutions (the “Clients”). By their nature, our services must include some personal information about our Clients’ potential or existing employees or tenants (the “Applicants”). Accordingly, we regularly collect, use and disclose personal information of consenting Applicants when they apply for an employment opportunity or a vacant unit to rent.
Our collection practices for potential or existing Applicants
We primarily collect Applicant Personal Information from the following sources:
- Reports about Applicants that are provided to us by credit reporting agencies, bureaus, grantors or other institutions
- Collection agencies;
- The internet, and public social media profiles that individual authors have made publicly available;
- Directly from Applicants in response to any dealings we have with the Applicant including the Certn questionnaire; and
- Public records, federal, state and/or provincial government offices, public registries, and other sources permitted by law.
If you call us, we may record and retain the recording to ensure the accuracy of our discussions and for quality control and record keeping purposes.
Information we collect
What is included in our reports
Certn’s reports may contain the following information:
- Identifying information: Applicant name, previous name(s), date of birth, Social Insurance Number (including temporary and/or previous Social Insurance Numbers), current and previous addresses and telephone numbers, and current and previous employers;
- Public records: Information that may affect creditworthiness, such as judgments, bankruptcies, consumer proposals and registered items, as well as, criminal court cases, fraud lists, sex offender registries, and terrorist watch lists;
- Criminal record check: A list of identified criminal records on file with police services;
- Address history: A list of past residential addresses;
- Employment history: A list of previous employers as well as the dates of employment and any references associated with the employment;
- Education history: A list of previously attended educational institutions, the dates attended, and any degrees/diplomas/certificates/other obtained;
- Driving history: A list of driving infractions on file with a department of motor vehicles;
- Credit history: Record of payment history on current and previous bills/debt obligations, including payments on loans, credit cards, lines of credit and mortgages owing to organizations such as retail stores, banks, finance companies and telecommunications companies;
- Inquiries: A list of credit grantors and other parties authorized by the consumer and/or by law that have received all or part of an Applicant’s credit information. Also lists organizations that have received a service from Certn where consumer credit information was used but not necessarily disclosed, such as authentication;
- Collections: Information about collection matters. This segment may include information about outstanding collections on business accounts if you are personally liable for the debt. It may also include information about outstanding family maintenance support obligations, if permitted by law;
- Banking: Information about bank accounts that were closed by an institution for reasons such as empty envelope deposit, NSF cheques or uncollected overdraft charges;
- Remarks: All remarks that have been added to your file, such as a fraud alert or a consumer statement;
- Social profiles: Results from a scan of the internet and public social media profiles for information containing content published by you, about you or on your behalf; and
- References: Responses to questions presented to an Applicant’s provided references
What is NOT included in our reports
Certn reports do not contain:
- Medical histories;
- Information about purchases paid in full with cash or cheques;
- Race, creed, colour, ancestry, religion, ethnicity, sexual preference, family status or political affiliations.
Accuracy of the Personal Information collected
The majority of personal information collected is provided directly from the applicant themselves. As a result, the applicant controls the accuracy for most of the information received. Certn uses automated transcribing practices to the greatest extent possible to ensure the accuracy of information continues within our system. Any information that is found to be inaccurate, whether it be through our internal control processes or brought to our attention by the applicant for correction, is updated as soon as possible.
Correcting Personal Information
At any time, an applicant may request to have any identified inaccuracies associated with their personal information corrected. An applicant may also ask us not to collect their personal information and to delete any information that was previously provided to us provided it is permitted by law.
You are entitled to receive your Personal Information from Certn at no charge upon written request. We also encourage all consumers to request and review their Equifax credit report on a regular basis. By doing this, you can ensure that your report contains information that accurately reflects your credit history. You have the right to dispute any discrepancies by immediately notifying us, or Equifax in writing and we will investigate to ensure the items reported are factual. Where a piece of information, outside of the Credit file (Equifax Report), cannot be verified by the reporting source, Certn will remove it from your Certn files.
Access to your Personal Information
You also have a right to access the other personal information belonging to you that is under our control subject to any legal restrictions or rights of refusal. Such a request for access must be made in writing stating the details of the personal information you are requesting to Certn’s Chief Privacy Officer at Chief Privacy Officer, Certn (Canada) Inc. 1017 Fort St., Victoria BC V8V 3K5. To ensure we disclosure information to you only, with your request please include photocopies (front and back) of two (2) pieces of government issued photo id so that we may verify your identity.
Decision making associated with Personal Information
Certn does not take part in the decision-making process. Our reports do not make a recommendation to our clients whether positive or negative about the applicant. How the information contained in our report is weighted for decision making is entirely at the discretion of our client and their discussions with the applicant. Compensation received by Certn from Clients is in no way impacted by the information provided on the Certn report. No incentive exists for Certn to provide an opinion or alter information contained on the report and Certn has no vested interest in the outcome between Clients and their Applicants.
Our use and disclosure of Personal Information
We limit our use of Personal Information to those purposes which have been disclosed to the Applicant by us or our Clients and for which appropriate consents have been obtained, or for purposes which are otherwise permitted by law. In connection with our services, we do not have direct relationships with the Applicants. Accordingly, Clients to inform their Applicants of the purposes for which they are providing Personal Information to Certn, or accessing Personal Information from Certn, and to obtain appropriate consent at the time the information is collected from the Applicant and/or prior to its use or disclosure by Certn. We also require our Clients to limit the use of Personal Information obtained from Certn to purposes that are permitted by law.
When Certn provides services to a Client, the information is shared through our secure web portal with that Client.
Certn uses and discloses Personal Information in the following circumstances:
- To provide our consumer credit reporting services, business credit reporting services, and other related services to our Clients;
- To provide authentication, ID verification and/or credit services to Clients purchasing your credit file;
- To police services to conduct police record searches;
- To court runners to conduct court record searches;
- To drug testing labs to conduct drug screening;
- To departments of motor vehicles to driving record searches;
- To education institutions and professional bodies to verify credentials;
- To previous employers to verify employment;
- To translation service providers to conduct translation services where information is returned to Certn in a language other than English;
- Other similar service providers in locations outside of where Certn operates to return information from the geographical regions that is consistent with information contained in our reports locally;
- To manage, administer, collect or otherwise enforce accounts;
- To assist in the investigation of a contravention of a law and/or fraudulent activities;
- To fulfill our obligations under consumer reporting and privacy legislation (such as, a request to initiate an investigation); and
- To act in respect of an emergency that threatens the life, health or security of an individual or for other purposes as permitted or required by law.
In addition, we may provide anonymous information (i.e., information that does not identify Applicants or, where applicable, its Principals) in the form of aggregate or demographic data to our Clients or service providers. We may also generate and use anonymous information to develop, enhance or validate our products, processes or services. Personal Information will necessarily be used to generate anonymous information and, when required, to research, validate and test the use of anonymous information in such processes, products, services and enhancements.
In exceptional circumstances Certn may be forced to communicate personal information with law enforcement agencies, national security agencies, courts, or other similar institutions as required by law. If in receipt of a production order, subpoena, warrant or other enforceable demand, Certn will comply by law as required. We will communicate the request of information with the applicant on a best efforts basis unless prohibited by law.
What we won’t do with the collected information
Certn will not disclose or sell your personal information to advertising agencies, marketing services, or government agencies unless required to do so by law.
We collect, use and disclose personal information when the Applicant is aware of the purposes for which the information will be used or disclosed, and has given his or her consent to such use or disclosure, except where collection, use or disclosure of personal information without consent is permitted or required by law.
In most cases, Applicants will not provide such consent directly to Certn, but to our Clients. We require our Clients to obtain consent prior to providing Certn with personal information, and prior to accessing the personal information contained in our credit files.
We have appointed a Privacy Officer to oversee our compliance with the privacy principles established by the federal Personal Information Protection and Electronic Documents Act, and with provincial privacy and credit reporting legislation. However, protecting Personal Information does not begin and end there: we are committed to fostering a sense of responsibility amongst our employees for protecting the privacy and accuracy of Personal Information while it is in our care.
Likewise, our Clients have obligations to Applicants when accessing Personal Information from us or providing Personal Information to us. We have processes in place to encourage our Clients to comply with applicable law and obtain the necessary consents. Such processes include entering into binding agreements with our Clients and conducting random audits of our Clients’ internal procedures; however, the responsibility for the Clients’ compliance ultimately rests with them.
Personal information between countries
Certn has Clients in both Canada and USA. Where possible, Certn ensures that personal information only exists in its country of origin. There are however circumstances where a Client screens an Applicant outside of its country of origin. In these cases, the Applicant’s personal information is transferred from its place of origin and returned to the country of the company requesting the screen.
Retention of your Personal Information
Certn retains your Personal Information in our information database for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws.
Please contact our Consumer Relations Centre using the contact information below. Our Consumer Relations Centre is staffed by trained personnel who can assist with your inquiries. You may also direct your inquiry or request directly to our Privacy Officer. We may require that you put any request for access or correction in writing.
Consumers can also contact us through our:
- Website: https://certn.co
- Email: [email protected]
- Telephone: +1 (844) 822-3786, Mon-Fri 8am-8pm (EST)
When a Client bases its decision to deny a benefit or to increase a charge to the Applicant, in part on information received from Certn, the Client has an obligation to inform the Applicant Customer that it obtained information from us and our Partners at Equifax. In this situation, Clients must provide individuals who are declined with Certn’s and Equifax’s contact information so that the individual can verify the content of their Certn Report and Credit File and, if necessary, request from Certn, the credit bureau or one of our Certified Data Providers that information be amended or deleted. Certn does not play a role in the decision to deny or advance an Application, the Applicant should deal directly with the Client for more information on the denial of their Application.
If Certn is satisfied on reasonable grounds that a request made should be implemented, Certn will (a)correct the personal information as soon as reasonably possible, and (b)send the corrected personal information to each organization to which the personal information was disclosed by Certn during the year before the date the correction was made.
If no correction is made, Certn will create a note in our database with the correction that was requested but not made.
Certn requires, that when a Client is notified of a correction of personal information, the Client must correct the personal information under its control.
Certn’s Website makes use of “per-session” Cookies. Unlike “persistent” Cookies, which are stored on a user’s hard drive and can last indefinitely, per-session Cookies are stored only in a browser’s temporary memory and are deleted when the browser is shut down.
When users visit our Website, our web server offers the user’s browser a per-session Cookie. As the Website is navigated, this Cookie is read back to our web server, allowing us to generate an anonymous “click trail” profile of the visit. From the aggregated information about visits, Certn learns how visitors interact with its Website, how the Website design and content can be improved, and how visitors’ experiences can be improved.
Certn does not link, share or associate the contents of the per-session Cookie with any other information in a way that would enable the identification of visitors to our Website. Nor do we track or link together multiple visits by any single user over time. Our per-session Cookies cannot be “read” by any other web servers, so users cannot be tracked or profiled using Certn’s Cookies if they visit multiple sites on the Internet. Some browsers can be set to reject all Cookies. If a user chooses to modify a browser in this manner, some pages of our Website may not function properly.
IP addresses and server logs
Unique Internet Protocol (IP) addresses are assigned to all internet users by their Internet Service Providers (ISPs). IP addresses do not directly identify internet users; however, through an ISP, an IP address may be linked to a particular user. During a visit to a website, certain information about a user’s traffic patterns, linked with the user’s IP address, is passively and automatically collected in the normal course of establishing and maintaining a website connection. This information is logged by the web server of the website that is visited.
The following information is logged by Certn’s web servers during visits to our Website: IP addresses, type of operating system, time and duration of visit, web pages visited and browser type. We do not link server log information to any other information in a way that would enable the identification of visitors to our Website. Server log information is analyzed by us in order to improve our Website and to customize the Website for users. In addition, from time to time, server logs may be reviewed for security purposes; for example, to detect unauthorized activity on our Website. In such cases, server log data, containing IP addresses, would be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
Links to third party sites