Data Retention

1. Introduction

This Data Retention Policy (“Policy”) outlines the retention, storage, and disposal of data collected and processed by Wirestork, Inc. (“Wirestork”). Wirestork provides background check services, and this Policy is designed to ensure compliance with applicable U.S. laws and regulations. By using Wirestork’s services, you agree to the terms of this Policy.

2. Purpose

The purpose of this Policy is to:

• Ensure compliance with federal, state, and local laws and regulations.
• Protect the privacy and confidentiality of personal data.
• Manage data efficiently and effectively.
• Provide guidelines for data retention, storage, and disposal.

3. Scope

This Policy applies to all data collected, processed, and stored by Wirestork, including but not limited to:

• Personal Identification Information (PII)
• Employment Information
• Educational Information
• Criminal Records
• Financial Information
• Background Check Reports

4. Data Collection and Processing

Wirestork collects and processes data in compliance with applicable laws, including the Fair Credit Reporting Act (FCRA), and other federal, state, and local regulations. The data collected is used solely for the purpose of providing background check services to our clients.

5. Data Retention Periods

5.1 General Retention Period

Wirestork retains data for a period of seven (7) years from the date of collection or the completion of the background check report, whichever is later. This retention period complies with federal and state laws, including the FCRA.

5.2 Specific Retention Periods

Certain types of data may be subject to different retention periods based on legal requirements or business needs:

• Consumer Reports: Retained for seven (7) years from the date of report completion.
• Investigative Consumer Reports: Retained for five (5) years from the date of report completion.
• Criminal Records: Retained for seven (7) years from the date of report completion.
• Financial Information: Retained for seven (7) years from the date of report completion.
• Employment Verification Records: Retained for seven (7) years from the date of report completion.
• Educational Verification Records: Retained for seven (7) years from the date of report completion.

6. Data Storage and Security

6.1 Data Storage

Wirestork implements industry-standard security measures to protect data from unauthorized access, use, or disclosure. Data is stored in secure databases and systems that comply with applicable security standards, including encryption, access controls, and regular security audits.

• Encryption: All personal data is encrypted both in transit and at rest using strong encryption protocols.
• Access Controls: Access to data is restricted to authorized personnel only, based on the principle of least privilege. Role-based access controls are implemented to ensure that individuals have access only to the data necessary for their job functions.
• Regular Security Audits: Wirestork conducts regular security audits and assessments to identify and address potential vulnerabilities in our data storage systems.
• Data Backup: Regular backups of data are performed to ensure data integrity and availability. Backups are stored securely and are also subject to the same security measures as primary data.

7. Data Deletion

7.1 Data Deletion Procedures

At the end of the retention period, Wirestork will securely dispose of data in compliance with applicable laws and regulations. The methods of disposal include:

• Electronic Data: Secure deletion or destruction of electronic files using industry-standard data wiping methods to ensure data cannot be recovered. This includes overwriting data with random patterns, degaussing, and cryptographic erasure.
• Physical Data: Shredding, pulping, or incinerating physical documents containing personal data to ensure complete destruction. Physical destruction is conducted by a certified document destruction service to ensure compliance with applicable standards.

7.2 Data Deletion Requests

Consumers have the right to request the deletion of their personal data under certain circumstances. Wirestork will comply with all valid requests from consumers to exercise these rights in accordance with applicable laws and regulations, including the California Consumer Privacy Act (CCPA) and the General Data Protection Regulation (GDPR), as applicable.

• Request Verification: Before processing a data deletion request, Wirestork will verify the identity of the requester to ensure that the request is legitimate.
• Deletion Timeline: Wirestork will respond to data deletion requests within the timeframe required by applicable law, typically within 45 days. If an extension is necessary, Wirestork will inform the requester of the reason for the delay and the expected timeframe for completion.

8. Consumer Rights

8.1 Right to Access

Consumers have the right to access their personal data held by Wirestork. Upon request, Wirestork will provide a copy of the data in a structured, commonly used, and machine-readable format.

8.2 Right to Correct

Consumers have the right to request corrections to any inaccuracies in their personal data. Wirestork will promptly update any incorrect information upon receiving a valid request.

8.3 Right to Delete

Consumers have the right to request the deletion of their personal data under certain circumstances. Wirestork will comply with all valid requests for data deletion, subject to applicable legal exceptions.

9. Compliance and Training

Wirestork employees are trained on this Data Retention Policy and the importance of data protection and compliance with applicable laws. Regular audits and reviews are conducted to ensure adherence to this Policy.

• Employee Training: All employees receive training on data protection principles, security practices, and compliance requirements. Training is conducted annually and whenever there are significant changes to applicable laws or internal policies.
• Audit and Review: Wirestork conducts regular audits and reviews of its data retention and security practices to ensure compliance with this Policy and applicable laws. Any identified deficiencies are promptly addressed and remediated.

10. Policy Updates

Wirestork reserves the right to update this Data Retention Policy as necessary to comply with legal requirements or to reflect changes in our business practices. Any updates to this Policy will be posted on our website and communicated to our clients as appropriate.

• Notification of Changes: Significant changes to this Policy will be communicated to clients and consumers via email or other appropriate channels. The updated Policy will also be available on the Wirestork website.
• Effective Date: The effective date of any updates will be clearly indicated at the beginning of the Policy document.

11. Contact Information

If you have any questions or concerns regarding this Policy, please contact us at:

Wirestork.com
Conzurge Inc.
2035 Sunset Lake Road
City of Newark, Delaware 19702