Applicant Privacy Notice

Who This Notice Applies To

This Applicant Privacy Notice applies to individuals who apply for employment with VertiSource HR, LLC (“VertiSource HR,” “we,” “our”) by submitting a resume, application, or related materials to careers@vertisourcehr.com or through the job postings at vertisourcehr.com/careers.

If you are hired, the Employee Privacy Notice applies to you going forward. If you are a website visitor rather than an applicant, the Privacy Policy applies.

Information We Collect About Applicants

The specific information we collect depends on the role and what you voluntarily provide. Typical categories include:

• Identifiers: full name, email address, phone number, mailing address, LinkedIn profile URL.
• Employment history: prior employers, job titles, dates of employment, responsibilities, reasons for leaving.
• Education and credentials: schools attended, degrees, dates, professional certifications (SHRM-CP, PHR, CPP, CEBS, etc.).
• Resume and cover letter content: whatever you voluntarily include.
• References: contact information for professional references you provide.
• Interview records: notes from phone screens, panel interviews, and any skills assessments.
• Government ID for work-authorization verification: collected only after a conditional offer is extended, as part of I-9 Employment Eligibility Verification.
• Background check data (where legally permitted and applied for the role): criminal history within federal and state limits, employment verification, education verification, driving record for driving roles, drug screen results. Background checks are conducted by third-party Consumer Reporting Agencies (CRAs); see Section 4.
• Voluntary demographic information: if you choose to self-identify race, ethnicity, sex, veteran status, or disability status under federal EEO/VETS/OFCCP programs.
• Information from your public professional profiles: if you link us to them (for example, LinkedIn, GitHub, personal portfolio).

We do not request salary history in states where doing so is prohibited (including California, New York, Washington, Colorado, and others). We do not use polygraph examinations or similar lie-detector tests (this is prohibited for most private-sector positions under the Employee Polygraph Protection Act).

Voluntary EEO self-identification. Any race, ethnicity, sex, veteran-status, or disability information you choose to provide is entirely voluntary. It is kept separate from your application, is not shared with the recruiters, hiring managers, or interviewers who evaluate you, and is used only for aggregated EEO-1, VETS-4212, and OFCCP reporting. Declining to self-identify will not affect your application in any way.

How We Use Applicant Information

We use applicant information exclusively for:

• Evaluating your qualifications and fit for the role you applied for;
• Evaluating your qualifications for other open or future positions, if you consent to be considered for future roles;
• Scheduling and conducting interviews and skills assessments;
• Conducting reference checks and, where applicable, background checks after a conditional offer;
• Extending an offer of employment, including negotiating compensation and start date;
• Complying with federal and state employment law, including EEO-1, VETS-4212, OFCCP, and affirmative-action-program reporting;
• Investigating and defending claims of discrimination or other employment-related matters;
• Internal recordkeeping.

We do not sell applicant information. We do not share applicant information for cross-contextual behavioral advertising. We do not use applicant information to profile you for automated hiring decisions that produce legal effects without human involvement; see Section 6.

Background Checks & FCRA Disclosure

If your role requires a background check, we will obtain your separate written authorization before ordering one, in the form of a clear-and-conspicuous disclosure and written consent that complies with the Fair Credit Reporting Act (FCRA, 15 U.S.C. § 1681b). The disclosure you receive at that time will name the Consumer Reporting Agency (CRA) performing the check and describe the information that may be obtained.

If we intend to take adverse action based in whole or in part on the consumer report, you will receive:

1. A pre-adverse action notice including a copy of the consumer report and the FTC-mandated Summary of Your Rights Under the FCRA;
2. A reasonable period of time (typically at least five business days) to review and, if appropriate, dispute or correct the report with the CRA; and
3. A final adverse-action notice if the decision is confirmed.

For California applicants, we will additionally provide the notices required by the California Investigative Consumer Reporting Agencies Act (ICRAA, Cal. Civ. Code § 1786 et seq.) and the Consumer Credit Reporting Agencies Act (CCRAA, Cal. Civ. Code § 1785.1 et seq.) as applicable.

Ban-the-box and fair-chance laws in your jurisdiction may limit when and how we consider criminal-history information. We comply with those laws.

Recipients of Applicant Information

• VertiSource HR internal personnel involved in recruiting, hiring, and HR (on a need-to-know basis);
• Hiring managers and interview panelists for the specific role;
• Third-party CRAs performing background checks (Section 4);
• Drug-screening providers;
• Reference contacts you provide;
• Federal and state regulators (EEOC, DOL, state FEP agencies) if compelled by legal process or required reporting;
• Legal counsel under privilege in case of an actual or threatened claim.

Automated Decision-Making & Profiling

VertiSource HR does not use automated systems to make final hiring, promotion, or employment-eligibility decisions that produce legal or similarly significant effects on applicants without meaningful human involvement. Applicant-tracking tools may rank, filter, or tag applications based on keyword match to job-description criteria, but final decisions are made by human recruiters and hiring managers. New York City Local Law 144 (Automated Employment Decision Tools, codified at NYC Admin. Code §§ 20-870 et seq.), Illinois Artificial Intelligence Video Interview Act, and similar state laws impose specific notice and audit obligations on automated employment decision tools. VertiSource HR does not currently use any tool that, under those laws’ controlling definitions, performs “substantial assistance” to, or “substantial replacement” of, human decision-making in hiring, promotion, or employment-eligibility decisions. If we add an AEDT in the future, we will update this Notice and provide the required notices before use.

Retention

We retain applicant information for the period required to evaluate your application and to comply with applicable law, including:

• Applications and interview notes for non-hired applicants: at least two (2) years following the decision (EEOC recordkeeping requires minimum one year; longer for federal contractors under OFCCP; longer in states with longer discrimination-claim statutes of limitation);
• Background check consumer reports: the period required by FCRA and the underlying CRA’s retention policy;
• Information about hired applicants: rolled into the employment record and retained per the Employee Privacy Notice.

If you request that we remove you from consideration for future roles, we will retain only the minimum required to document your opt-out and to comply with legal obligations.

Your Rights

8.1 California Applicants (CCPA/CPRA)

California applicants have the same CCPA/CPRA rights as other California consumers: know, delete, correct, portability, opt-out of sale/share (we do not sell or share), limit use of SPI, non-discrimination, and appeal. See Section 9.2 of the Privacy Policy for the detailed rights list and four exercise methods.

8.2 Applicants in Other States

California is currently the only state whose comprehensive consumer-privacy law extends consumer-privacy rights to job applicants. The comprehensive privacy laws of Utah, Virginia, Colorado, Connecticut, Texas, and the other enacted states exempt personal data processed within an employment or applicant context, so those statutes generally do not give applicants separate consumer-privacy rights in their capacity as applicants. Regardless of state law, VertiSource HR will consider reasonable access and correction requests from any applicant; submit them as described in Section 8.3.

8.3 How to Exercise Rights

Email privacy@vertisourcehr.com with “Applicant Privacy Request” in the subject line. Include the role(s) you applied for and the approximate date of your application to help us locate your records. We will respond within forty-five (45) days, extendable by another forty-five (45) days for complex requests.

8.4 No Retaliation

VertiSource HR does not retaliate against an applicant for exercising a privacy right. Making a privacy request will not affect whether or how your application is evaluated.

Security

Applicant information is protected under the same administrative, technical, and physical safeguards that apply to other personal information we process. See Section 7 of the Privacy Policy.

Changes

We may update this Notice from time to time. The “Last Updated” date at the top reflects the most recent change. If the changes are material, we will post notice on the careers page.

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