Who this notice is for
This notice concerns individuals undergoing background screening through ICC Group’s HireSmart services at the request of an employer, prospective employer or another commissioning organisation.
This notice applies to candidates, existing personnel and other individuals undergoing screening commissioned by an ICC client. It does not cover personal information submitted when applying to work directly for ICC.
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The commissioning organisation
The organisation requesting a check determines the purpose for which it seeks screening and how it intends to use the findings. Its own privacy information should explain those purposes and its responsibilities.
ICC’s responsibilities depend on the particular processing activity and engagement. When processing on a client’s instructions, ICC’s handling must remain within the authorised scope and applicable legal requirements.
Any separate purpose for which ICC determines processing requires its own appropriate explanation and legal basis.
Information relevant to a check
The information involved depends on the requested package, the role, relevant countries and what the law permits. Not every person undergoes every check.
Relevant information may include:
- Name, identifying details and contact information.
- Address details and history needed for the check.
- Identification documents needed to match records accurately.
- Education, qualifications and professional credentials.
- Employment history and professional references.
- Relevant criminal, court or regulatory records where legally accessible and permitted.
- Financial or credit information where the specific use is lawful.
- Relevant sanctions, watchlist and adverse-media information.
- Public online information within an authorised and legally permitted screening scope.
- Consent or authorisation records, correspondence and verification findings.
The scope should be communicated through the instructions and notices accompanying the screening. The availability of a record does not make its collection appropriate for every role.
Information sources
Information can come from you, the commissioning organisation, previous employers, educational institutions, professional bodies, referees, relevant authorities, lawfully accessible records and appropriate verification providers.
A source may require a particular authorisation, identity evidence or supporting document before releasing information.
ICC’s Consent Forms and Authorizations page provides examples. Source-specific requirements should be checked for the relevant verification; a sample form is not a universal legal authorisation.
Purposes of screening
Screening information is used to compare supplied details with relevant sources, identify discrepancies, complete the requested checks and provide findings to the commissioning organisation.
Related processing may be needed to clarify a result, review an accuracy concern, document the work, answer an appropriate request or meet legal requirements.
Checks should remain relevant to the instructed purpose. A general request for screening does not permit unrelated investigation of a person’s private life.
Authorisation and lawful processing
Authorisation can be necessary for obtaining records from a particular source. It must be distinguished from the legal basis for processing the information.
Where processing relies on consent, it must meet the applicable requirements for consent, including the right to withdraw it. Other activities may rely on a different valid basis.
Sensitive information and criminal-offence information can require additional legal conditions or authority. Neither a client’s commercial interest nor a signed general form automatically resolves those requirements.
If information is unavailable
An institution may have incomplete records, a source may not respond, or a document may not provide enough information to complete verification.
An incomplete or unverified result is not, by itself, proof that the information supplied is false. Findings should distinguish what has been confirmed from what remains unavailable or disputed.
If requested information cannot be provided, contact ICC or the commissioning organisation to discuss its relevance and any appropriate alternative evidence.
Reports and recipients
Screening findings are intended for the commissioning organisation and other recipients authorised and legally entitled to receive them.
Verification can also require disclosing limited information to a source so that it can identify the relevant record. Information should be confined to what is necessary for that purpose.
Applicable law may require or permit disclosure to authorities, advisers or other relevant parties. Confidential handling does not mean that information can never be disclosed.
Accuracy concerns and corrections
If you believe information associated with your check is inaccurate or incomplete, email gcc@iccverify.com with the subject “Screening accuracy enquiry”.
Identify the commissioning organisation, the relevant check or reference, and the particular information you dispute. Explain the correction requested and indicate whether supporting evidence is available.
A review may require checking the original source or obtaining further evidence. Do not send extensive sensitive records until an appropriate submission method has been arranged.
A screening disagreement and an employer’s hiring decision are separate matters. Contact the commissioning organisation for questions about how it uses a report or decides an application.
Technology and human assessment
ICC’s published service information describes the use of technology alongside investigative and analytical expertise.
Technology-assisted collection, matching or analysis is different from a decision made solely by automated means that significantly affects a person. If relevant automated decision-making or profiling forms part of a particular activity, additional information and safeguards may be required.
This notice does not claim that every client uses screening results in the same way.
Cross-border checks
Verifying overseas education, work history or other records may involve sources outside the country where you are applying or working.
International processing must take account of applicable disclosure and transfer restrictions. Further information about the arrangements relevant to your screening can be requested from ICC and the commissioning organisation.
Retention and protection
Retention should reflect the purpose of the record, legal requirements, the relevant client agreement and any justified need to resolve a dispute.
Supporting documents, completed reports and accuracy-review records may have different retention requirements. Where ICC acts on a client’s behalf, its handling must also follow the client’s lawful instructions.
Our Information Security Policy Statement describes the policy principles for protecting confidential records.
Requests and complaints
Depending on applicable law, you may have rights relating to access, correction, deletion, restriction, objection, portability and consent withdrawal.
Email gcc@iccverify.com to raise a request. ICC may need to verify identity and involve the commissioning organisation. Rights and responses may be subject to lawful restrictions, including protection of other individuals’ information.
Additional country-specific screening rights and notices may apply. This notice does not replace mandatory local disclosures or employment screening procedures.