Canadian Privacy Policy
Effective Date: 27 February 2025
Click on one of the links below to jump to the listed section:
Table of Contents
1. Coverage
2. Your Choices
3. Your Rights
4. Transfers Outside Canada
5. Who At Checkr May Access Your Personal Information
6. Canadian Credit Reports
7. Automated Decision Making
8. Questions and Complaints
- Coverage
1.1 What this Canadian Policy Covers
This Canadian Privacy Policy (the “Canadian Policy”) applies only to our collection, use, and disclosure of personal information covered by Canadian law. It applies to personal information regardless of whether it was collected online or offline.
If you are a Checkr Canada employee in Alberta, British Columbia, Quebec, or the Canadian territories, please see our Worker’s Policy here and the Checkr Handbook. There, you will find more detailed accounts of how we collect, use, and disclose your personal information related to your employment within the Checkr corporate family.
1.2 What this Canadian Policy Does Not Cover
This Canadian Policy does not apply to business contact information. The reason is that, unlike laws in California, the United Kingdom, or the European Union, Canadian privacy laws do not cover business contact information. Consequently, this Canadian Policy would not apply to information such as business contact details a Customer sends us through a Checkr webform for scheduling a demo.
1.3 What We Cover Elsewhere
In this Canadian Policy, we address only matters specific to Canadian Consumers and Visitors and that our Privacy Policy does not already describe. Please see our Privacy Policy to learn more about the following:
- What personal information we collect and why
- From what sources we collect personal information
- What personal information we use and why
- What personal information we disclose and why
- What policies we have on storing and disposing of personal information
- What measures we take to protect personal information
2. Your Choices
For certain parts of our Services, you can choose what personal information you provide to us. Examples include the following.
2.1 Optional Fields
When collecting personal information from you, we will tell you what personal information is only optional. Examples include the following:
- Including the statement “(optional)” near a field asking you to input personal information, such as your or a Consumer’s phone number;
- Including the statement “(optional)” near a checkbox asking whether you have certain personal information, such as a middle name; and
- Providing the option “Prefer not to say” in a dropdown menu asking you to select a particular response, such as your sex.
If you provide this optional personal information, our vendors might be able to use it to determine with greater specificity whether particular information returned in results belongs to you.
2.2 Biometric Information
If you live in Quebec and are a Candidate, a Customer might request that we perform a criminal background check on you. To do that, the Royal Canadian Mounted Police requires that we first verify your identity. For that, we use multiple possible vendors.
One of those vendors will collect biometric information from you, such as measurements of your facial geometry. To that end, the vendor asks you to upload a selfie and a picture of your governmental identification. Then, it will extract facial measurements from those uploaded photographs. From there, it will compare the facial measurements of your selfie with those of your photograph on your governmental identification. This will help it determine whether those measurements sufficiently match. To prevent fraud, the vendor will also process your photographs to detect whether the person pictured in the selfie is likely alive.
At all stages of this vendor’s process, Checkr does not receive any of your biometric information from this vendor. If you live in Quebec, are a Candidate, and have questions about this process, please contact us at privacyofficer@checkr.com about choices you may have about our vendor’s collection and use of your biometric information.
2.3 Interest-Based Advertising
On the Site, we let Site Visitors living in Canada choose whether to receive interest-based advertising from us. Interest-based advertising uses cookies and similar technologies placed on the Site to analyze your behavior on websites not affiliated with Checkr. With that information, Checkr and its marketing partners can show you Checkr advertisements while you are on websites not affiliated with Checkr. As a result, this advertising might involve a certain level of profiling, location, and identification of you, as those terms are described in Quebec law.
To receive interest-based advertising, you can provide your consent through the cookie banner we present to you when you first visit the Site. If you change your mind about whether to receive interest-based advertising, you can adjust your cookie preferences through your browser or the floating cookie icon on the bottom left-hand corner of the Site.
If you would like to learn more about our use of cookies and similar technologies, please read our Cookie Policy.
3. Your Rights
Under Canadian law, you may have the following rights concerning your personal information:
- The right to access your personal information;
- The right to correct your personal information;
- The right to withdraw your consent except where legal or contractual obligations limit that right; and
- The right to challenge our compliance with applicable Canadian privacy laws, including by complaining to the appropriate privacy commissioner.
We describe how you may exercise the first three rights here. You can learn more about how to exercise the fourth right in Section 8 of this Canadian Policy.
If you live in Quebec, you also have the following rights:
- The right to delete your personal information under certain circumstances; and
- The right to receive computerized personal information collected from you in a structured, commonly used format.
Please contact us at privacyofficer@checkr.com if you believe that you qualify to have your personal information deleted or provided to you in a portable format under Quebec law. Once we receive your request, we will review it and determine whether these rights apply to your personal information. To protect privacy and confirm your legal eligibility to exercise these rights, we might ask you to provide proof of your identity and Quebec residency.
4. Transfers Outside Canada
4.1 Where Checkr is Located
Checkr is located in the United States. Although Checkr will use its Canadian affiliate, Checkr Canada, to help it provide a Canadian background check, Checkr itself will be the one actually performing the background check and communicating with you during that process. So, for example, when you are entering your personal information into our candidate portal or contact us with questions about Checkr’s Canadian background checks, you are interacting with a U.S. entity, not a Canadian one.
4.2 Possibility of Transfers outside Canada
As a global company, Checkr performs services for Customers and Consumers all over the world. To make that possible, Checkr may transfer your personal information to countries outside Canada, including outside Quebec. This means that your personal information could be accessed if required by the law of those countries.
4.3 Transfers to Service Providers outside Canada
We might use service providers outside Canada, including in the United States, Romania, Ukraine, Chile, India, Pakistan, Columbia, and the Philippines. Those service providers will collect, use, and disclose your personal information only as necessary to fulfill legitimate business purposes on our behalf. Such purposes include the following:
- Quality assurance, such as ensuring that our Site and Services are working properly;
- Accounting and billing, such as processing payments, handling collections, and responding to Customer billing questions;
- Candidate support, such as answering customer questions in French and other applicable languages;
- Legal support, such as responding to your questions about our privacy practices and advising Checkr and its family of companies on legal matters;
- Processing disputes, such as helping you address possible inaccuracies in your report and, where necessary, directing you to the appropriate source of the information for resolution;
- Human resources, such as administering payroll, benefits, and accommodation requests for Canadian employees at Checkr;
- Sales support, such as contacting or responding to inquiries from prospective customers;
- Technical support, such as addressing issues you might have interacting with the Site or our products; and
- Processing transactions, such as providing Customers with background checks authorized by Candidates.
We establish a contract with each service provider outside Canada that collects, uses, stores, or discloses personal information for Checkr. These contracts typically require the service provider to collect, use, store, and disclose only in accordance with our written instructions and applicable laws.
If you have questions about our engagement of service providers outside Canada, please contact us at privacyofficer@checkr.com.
5. Who at Checkr May Access your Personal Information
Checkr employees will need to access your personal information as part of their job duties. Such duties might include fulfilling a transaction you authorized, performing quality assurance, and responding to any questions you have about our privacy practices. The Checkr employees needing such access include those in the following departments:
- Information Security
- Legal
- Accounting
- Candidate Support
- Engineering
- Disputes and Investigations
- Human Resources for personal information belonging to Checkr’s and its affiliates’ employees
Click here if you are a Worker and want to know more about how we collect, use, and disclose your personal information for human resources purposes.
6. Canadian Credit Reports
6.1 Your Canadian Credit Report
Checkr obtains Canadian credit reports on behalf of its Customers. These credit reports will contain personal information and could bear on someone’s character, reputation, or solvency, as those terms are described in Quebec law.
6.2 Who Creates Your Canadian Credit Report
We do not create your credit report ourselves. Instead, we obtain credit reports from our vendor and only on request from our Customers. Before requesting a Canadian credit report, a Customer must have an established contract with us and provide us with the Candidate’s personal information so that we can order the credit report from our vendor.
Because Checkr does not prepare these credit reports itself, Checkr relies on its Customers, Candidates, and vendors to make sure that credit reports are accurate and up to date.
6.3 You May Access and Correct Your Credit Report
Except where applicable law says otherwise, you may request access to your Canadian credit reports obtained by Checkr. If you want to correct information in your credit report, we will direct you to the vendor that gave us the report.
To protect your personal information, we will ask to verify certain information about you before giving you access or allowing you to correct information in your credit report.
7. Automated Decision Making
Certain aspects of our Services use certain “automated decision making.” By that, we mean decisions likely made exclusively using automated technology, as described in Quebec law. In most cases, such automated decision making is part of routine portions of our Site, such as chatbots to help Site Visitors with questions they might have. In other cases, automated decision making is an important component of our Services to Customers–for example, biometric-based identity verification for Canadian criminal background screenings.
Examples of the automated decision making we use includes the following:
- Biometric-Based Identity Verification. This form of identity verification uses automated processes to determine whether, for example, your selfie sufficiently matches the photograph on your governmental identification. It might also use automated decision making to detect whether the person pictured is likely alive. You can learn more about our processing of biometric information in Section 2.2 of this Canadian Policy.
- Interest-Based Advertising. Such advertising often uses automated processes to determine what advertising to display to you on unaffiliated websites. You can learn more about how interest-based advertising works in Section 2.3 of this Canadian Policy.
- Chatbots. Chatbots often use automated processes to decide how best to respond to your messages typed into the chatbot. You can learn more about which privacy policies apply when using chatbots in Section 1.3 of the Policy.
- Cookie Banners. Our cookie management platform (CMP) vendor might use automated decision making to decide which type of cookie banner to display based on a Site Visitor’s geographic location. To illustrate, a Site Visitor in Quebec would not see the same cookie banner as a Site Visitor in the United Kingdom, because our CMP vendor would detect that those Site Visitors are visiting the Site from different countries, each with different cookie-related compliance requirements.
- Security Features. Certain security measures, such as CAPTCHAs and web application firewalls, use automated decision making to prevent access to the Services if they determine that such activity could present a security or fraud risk to the Services.
If you live in Quebec, you might have certain rights regarding automated decision making. To exercise those rights, please contact us at privacyofficer@checkr.com. Because we use vendors for the above forms of automated decision making, we might have to refer you to those vendors for answers to your questions.
8. Questions and Complaints
If you have a question or complaint about Checkr’s privacy practices, you can contact our privacy officer at the following:
Checkr, Inc.
Attn: Privacy Officer
1 Montgomery St
San Francisco, CA 94104
privacyofficer@checkr.com
For a faster response, we recommend contacting us at the above email rather than through other methods.
If your interaction with our privacy officer does not resolve your question or complaint, you may contact the following governmental authorities:
- Office of the Privacy Commissioner
- Office of the Information and Privacy Commissioner of Alberta
- Office of the Information and Privacy Commissioner of British Columbia
- Quebec Commission on Access to Information