The California Consumer Privacy Act (CCPA) becomes effective January 1, 2020. We are pleased to advise that the CCPA does NOT apply to Sterling’s background screening services and want to take this opportunity to remind you that Sterling has comprehensive global privacy, compliance, and information security programs to ensure we comply with our obligations under the laws that apply to us around the world. We are prepared to support your CCPA compliance if it does apply to your use of our non-background screening services.
What is the CCPA?
The CCPA creates several new rights for consumers, including the right to access, correct, and request deletion of their personal information. It also imposes requirements on businesses to be transparent about which data they collect, process, and sell, and gives consumers the right to request that their data not be sold.
Sterling’s background screening services are not subject to the CCPA, but are subject to the Fair Credit Reporting Act (FCRA) which provides a set of protections and rights for individuals who are the subject of consumer reports.
The following Sterling services may be subject to the CCPA or may benefit from other exemptions set out in the CCPA, depending on your organization’s use of the services:
- Non-employment due diligence through Sterling Diligence
- Fingerprinting and identity verification through Sterling Identity
- Forms I-9
- Onboarding forms
- Facilitation of data exchange with regulatory bodies outside the context of a consumer report
- Any other administrative services performed by Sterling for your organization that are not directly related to preparing, delivering, and consuming consumer reports
What you need to do to ensure compliance?
For FCRA-regulated background screening services, the CCPA does not apply and no compliance activities are required.
For non-FCRA services, Sterling is a ‘service provider’ as defined in the CCPA and will comply with our obligations under the law as a service provider. Our standard contractual terms may already meet the requirements of a service provider agreement under the CCPA, but if yours does not or you are unsure, we ask that you:
- Review the CCPA FAQ with your Compliance and/or Legal team.
- Sign the pre-signed contract addendum, if applicable.
- Forward the pre-signed contract addendum to your Sterling Client Success representative.
Additionally, Sterling is hosting a webinar on Thursday, January 30, 2020 at 2:00 p.m. ET to give you an overview of the new rights and obligations created by the CCPA, and insight into how it may apply to your organization.
Should you have any questions or concerns, please reach out to your Account Manager or TheAdvocates@SterlingVolunteers.com