Social61 Consumer Information and Privacy Policy Regarding Non-Public Personal Information for Social Media Background Checks and Other Matters.

Introduction
SSR Programming LLC dba Social61 (“Social61” herein) offers this privacy policy to describe how we secure and maintain the privacy of Non-Public Personal Information (NPPI) data that we acquire related to the services that we provide, including employment background and credential verification services obtained from online and other sources. The scope of this privacy policy is all information that comes under our control associated with the subjects of our Social Media Background Checks (“SMBC Subjects”).  All data is at all times collected, compiled, reviewed, stored and used in compliance with applicable federal, state and local law, including the Fair Credit Reporting Act (FCRA), law administered and enforced by the Equal Employment Opportunity Commission (EEOC), the Federal Trade Commission (FTC), and others. This policy explains why and how we gather and process NPPI and how this affects your privacy.

Our Intended Use of Information
Social61 obtains some NPPI on the persons we investigate from Clients and from other sources, so that we can provide them with Social Media Background Checks as requested. This often includes employment history, educational background and related credentials associated with the lawful purposes of our clients in ordering these reports.  Social61 will use such information only for these lawful purposes (for example, pre-employment credential and background verification and reference checks).  We may also obtain NPPI or other data from third parties and from public records, including current and previous contact information, biographical and other lawfully obtained information.  In some cases we may need your advance permission to source this information and we will therefore request this.  We may also capture and submit to clients various comments from social media sources. Social61 will redact (“edit-out”) irrelevant and superfluous information, summarize information which may lawfully be disclosed in this context, and provide a report or reports to our clients.

Collection of Information
Social61 may gather NPPI on our SMBC Subjects. We do this so that we can more accurately conduct Social Media Background Checks for our clients, who are most often companies and institutions who engage us to collect social media information on persons (such as current or prospective employees) who have given their permission to conduct this research. We may, for example, collect NPPI regarding SMBC Subject name(s), addresses, telephone numbers, occupations, employment data, financial information, email addresses and relevant online postings. This information may be sourced from your employment application(s), online profiles and postings, information service providers, and background reports provided by other businesses.

Does Social61 Share Information?
Social61 does not share NPPI except when properly ordered to do so by governmental authorities and/or the legal system. Under no circumstances would we sell NPPI, or use it to market products or services.

Protecting Information
Social61 takes comprehensive measures to secure NPPI, directly and through partners. Data is stored in a highly secure nondisclosed location with extensive controls to safeguard hardware, software and communications. NPPI is accessible only to Social61 personnel working directly on specific projects, and all personnel are educated on preventing unauthorized access, misuse, and data breaches. Entry to the location is controlled by a world-class security system, mostly by network engineers and technicians. Disposal and erasure of NPPI is conducted by Social61 management in accordance with legal requirements.

NPPI Transmission and Storage Outside of the U.S.
Social61 conducts all of its work in the U.S. and it is our policy to not send NPPI outside of the U.S. Further, we do not conduct Social Media Background Checks on SMBC Subjects residing outside of the U.S.

Accessing Your Information
Social61 complies with regulations requiring that SMBC Subjects have a right to their report(s) that we provided to our clients. This may be requested in writing to: Social61, 2337 Roscomare Road, Box #2-201, Los Angeles CA 90077-1833, or by email to asap@social61.com. We encourage SMBC Subjects to notify us of any errors, as discussed in the following paragraph. We will promptly act to correct and/or note your response to any disputed report content. In any correspondence to Social61, please include your full name(s), address, email address and telephone number. We may charge a fee of $15 to cover our costs, and will notify you after receipt of your request if this is required.

If You Disagree with Social61 Report Information
Please contact us if you believe that we store or have distributed what you believe is incorrect NPPI. You should also contact us if you have questions or concerns about our work or privacy policies. You may contact us at: Social61, 2337 Roscomare Road, Box #2-201, Los Angeles CA 90077-1833, or by email to asap@social61.com. In your communication be sure to include your full name(s), address, email address, telephone number, and a detailed description of the error(s). We will promptly investigate the matter, and if we make changes to our reports or stored information we will notify you and any clients who have received this information within the past 24 months, if you request this.

We will also inform you if we decline to make any changes, including our reasons for refusal.  In this case we will inform you that you may then provide us with a statement that we will include with your report.  The statement must be associated only with the areas you dispute, including an explanation of your disagreement (“your side of the story”.)  We reserve the right to not include content irrelevant to the dispute. We will store your statement and provide it to anyone who receives a copy of the disputed NPPI from Social61 in the future and to any Social61 client you designate who may have received the disputed NPPI within the past 24 months.

Last Updated: 2015-07-10.