TruCheck™ Privacy Policy

1. Scope of This Policy

This Privacy Policy applies to all data processed through the TruCheck™ application workflow, including interactive photo/video capture portals, document extraction modules, automated cross-matching engines, data verification dashboards, and portable digital verification cards.

VerifiedID LLC operates as a Consumer Reporting Agency (CRA) governed by the Fair Credit Reporting Act (FCRA, 15 U.S.C. § 1681 et seq.) when compiling and issuing TruCheck™ Consumer Reports for employment evaluation purposes. In addition, VerifiedID LLC acts as a Data Processor / Service Provider handling data under instructions from our Enterprise Clients, who act as the Data Controllers.

2. Information We Collect and Extract

To cross-authenticate your identity and assess frontend employment eligibility metrics, TruCheck™ collects and processes the following data assets directly from your verification sessions, as well as from information supplied by the authorizing Enterprise Client:

• Biometric Data & Video Streams: Facial geometry templates and computational maps derived from your live photo capture and your seamlessly generated session verification video. This active session explicitly includes the capturing of a background video as part of your live video interaction.
• Stored Photographic Images: The live verification photo and live selfie capture of your face taken during the session, used for automated facial matching, administrative identity confirmation, and display on your verification profile.
• Government-Issued Identification Documents: Digital image captures (Front and Back) of Driver’s Licenses, State IDs, Tribal IDs, and U.S. or Foreign Passports captured during your live interaction. Note: Uploaded document images are processed strictly within our secure engine and are NOT shared with or made visible to Enterprise Clients.
• Employment Eligibility Documentation: Image copies of acceptable employment authorization documents (such as U.S. Passports, Permanent Resident Cards, Employment Authorization Documents, or state-issued identity documents) captured during your live interaction solely for backend verification.
• Optional State-Issued ID Documents: Providing a State-issued Driver’s License or ID Card is completely optional. If provided, it helps verify state-level jurisdiction details (DL/Real ID - Issuing Jurisdiction). This document is not required to complete your verification.
• Client-Provided Historical Documentation: Copies of your identification, credentials, or work authorization documents previously provided by you to our Enterprise Clients during current or prior application/engagement cycles and uploaded to our system by the Enterprise Client.
• Extracted Textual Metadata: Full Legal Name, Date of Birth (DOB), Document ID Numbers, Issue Dates, and Expiration Dates parsed directly from uploaded credentials. Note: Date of Birth data is displayed on Candidate and CRA reports for identity verification under FCRA § 609, but is redacted (----) from Client-facing cards and consumer reports to comply with the Age Discrimination in Employment Act (ADEA).
• Identity Infrastructure Assets: Social Security Number (SSN). Note: The last four digits of your SSN are visible on Candidate and CRA reports to confirm file matching, but are redacted (----) from Client-facing consumer reports and verification cards.
• Technical Telemetry: IP address, detected connection type (including VPN or proxy indicators), network geolocation, physical location coordinates, device type, operating system version, browser type, camera hardware attributes, and session diagnostic logs.

3. How We Use and Cross-Match Your Data

VerifiedID processes your personal data via TruCheck™ exclusively for the following lawful business purposes:

• Identity Verification & Facial Matching: Evaluating your live photo, live selfie capture, verification video, and background video streams against the image on your submitted government-issued identification to prevent identity theft and substitution fraud.ification to prevent identity theft and substitution fraud.
• Multi-Source Data Cross-Matching & Extraction Validation: Extracting and cross-reconciling text strings, data fields, and alphanumeric identifiers across (a) your live Identity Documents, (b) your live Employability Documents, and (c) any historical verification files uploaded by the Enterprise Client. This reconciliation is performed using parsing technology and human-in-the-loop validation explicitly to identify data discrepancies, fraud vectors, age/identity manipulation, or conflicting record submissions.
• Verification Status Determination: Processing metrics to determine if an applicant achieves an evaluation status of "Clear", "Review Required", or a system "Alert" (such as network or geographic indicators) for identity and employability checks. All processing is conducted in strict compliance with federal anti-discrimination laws, including the Age Discrimination in Employment Act (ADEA), Title VII of the Civil Rights Act, and the Immigration and Nationality Act (INA § 274B). Sensitive parameters such as age, specific citizenship category, or document type are redacted on Client-facing cards to ensure unbiased evaluation by Enterprise Clients.
• Portable Identity & Employability Card Generation: Generating a secured, digital verification card containing your profile photo and authentication tokens, eligible for client sharing when evaluations return a "Clear" status.
• Security & Social Security Auditing: Validating the existence and approximate issuance date of your provided SSN against commercial databases and the Social Security Administration's Death Master File (DMF). An inability to match an SSN in commercial databases generates an informational alert and does not automatically confirm non-existence. Analyzing network attributes to generate security status indicators (such as VPN usage or checks initiated outside the United States). System logs and submitted assets are continuously analyzed for indicators of organized criminal activity, stolen identities, stolen SSNs, synthetic credentials, and forged or altered identification/employability documents (including counterfeit Driver’s Licenses, Passports, and Permanent Resident Cards).

4. Biometric Information Privacy Notice & Consent (BIPA & State Compliance)

PLEASE READ CAREFULLY: TruCheck™ processes biometric identifiers. By clicking "I Agree and Consent," you grant your explicit, standalone written consent to the following processing behaviors:

• Biometric Data Collected: Facial geometry signatures and mathematical facial maps extracted during your live selfie photo and generated video session (including accompanying video backgrounds).
• Specific Purpose: Verifying match consistency against your provided credentials to prevent credential and identity fraud.
• Downstream Sub-Processors: Data may be streamed to highly secure, bank-grade infrastructure partners solely to execute active face-to-photo validation.
• Strict Biometric Destruction Timeline: While flat reference images of your face may be stored for visual dashboard confirmation, all raw mathematical biometric identifiers, structural face maps, and calculations are permanently destroyed and erased from our active processing memory within twenty-four (24) hours of collection. or when the primary purpose is fulfilled,whichever is shorter (aligning strictly with Illinois BIPA 740 ILCS 14/15(a)).

5. Data Retention and Tiered Purge Policy

We adhere to a strict data minimization and fraud-prevention lifecycle governed entirely by the status outcome of your verification assessment:

• "Clear" Status Records: If both your Identity and Employability checks return a status of "Clear," your complete profile records, data metrics, and document media will be securely retained in our live system for a period of three (3) months from the date the TruCheck information was submitted by the Candidate, OR until the active TruCheck Expiry date (as explicitly printed on your TruCheck Clear Card), whichever occurs later. Following the conclusion of this designated retention threshold, the rest of your sensitive personal data and uploaded document images are permanently scrubbed and purged from our databases. We will continue to hold exclusively minimal archival parameters consisting strictly of your system RefNumber, your Candidate Name, and your final status assessment (Clear).
• "Review Required" Status Records: If your Identity, Employability, SSN check, or Geolocation evaluation results in a status of "Review Required," associated data assets and session files are retained in secure storage to prevent identity theft and synthetic credential fraud. These records are retained in compliance with statutory audit limits and remain subject to consumer dispute, correction, and statutory deletion rights as provided by applicable state and federal laws.

6. How We Disclose Your Information

We do not sell, rent, lease, or monetize your personal information or biometric data to third parties. Your data is disclosed strictly to facilitate the verification loop:

• The Requesting Enterprise Client: The potential employer or talent platform that invited you to complete TruCheck™ receives access to your document status evaluations(Clear, Review Required, or Alert), compliance tracking metrics, geolocation indicators, and your live candidate selfie image. Enterprise Clients do not receive access to raw images of your uploaded identity documents or employment documentation. Specific identifiers (such as Year of Birth and SSN) are redacted (----) on Client-facing views, and specific document types are displayed using generic labels (e.g., Candidate provided Document #1) to comply with INA § 274B anti-discrimination requirements.
• User-Initiated Sharing: Authorized third parties receive access to your portable verification card only when explicitly shared by you or the primary Enterprise Client, provided the card holds an active "Clear" status.
• Verified Infrastructure Partners: Restricted alphanumeric data or document streams are transmitted to certified database administrators and secure cloud storage vaults to perform identity matching, SSN lookups, and DMF safety checks.
• Fraud Prevention, Organized Crime & Law Enforcement Disclosures: VerifiedID LLC actively screens verification traffic to detect organized crime, identity theft rings, stolen Social Security Numbers, impersonation fraud, synthetic identities, and forged or counterfeit government documents (including fake Driver’s Licenses, Passports, and Permanent Resident Cards / Green Cards). We reserve the explicit right to disclose personal information, biometric indicators, document media, session diagnostic logs, and technical telemetry to federal, state, or local law enforcement agencies and regulatory authorities—including the Federal Bureau of Investigation (FBI / IC3), U.S. Homeland Security Investigations (HSI), the U.S. Secret Service, the Social Security Administration Office of the Inspector General (SSA-OIG), the Federal Trade Commission (FTC), and the U.S. Department of Justice (DOJ)—without prior notice to you, to assist in criminal investigations involving identity fraud (18 U.S.C. § 1028), Aggravated Identity Theft (18 U.S.C. § 1028A), document/visa fraud (18 U.S.C. § 1546), or pursuant to government agency disclosure authorities under FCRA § 608 (15 U.S.C. § 1681f) and state privacy exemptions.

7. Data Security Architecture

We implement rigorous administrative, technical, and physical security measures. All data streams in transit are encrypted via Transport Layer Security (TLS), and all data repositories at rest are isolated within corporate cloud environments protected by Advanced Encryption Standard (AES) 256-bit cryptography.

8. Data Subject Rights & FCRA Consumer Rights

Depending on your state or jurisdiction of residence, as well as under the Fair Credit Reporting Act (FCRA), you possess specific rights regarding your personal data, including:

• Right to Access & Disclosure (FCRA § 609): Request a copy of the personal information and consumer verification reports held about you.
• Right to Dispute & Correct (FCRA § 611): Request a free reinvestigation or correction of inaccurate, incomplete, or disputed information in your verification file.
• Right to Deletion: (FCRA § 612): Request deletion of your personal information (subject to legal retention exemptions for anti-fraud, security, or legal compliance).
• Summary of FCRA Rights: You retain all rights outlined in the official CFPB Summary of Your Rights Under the Fair Credit Reporting Act.

To file a dispute or exercise your privacy rights, you may submit a request to your prospective employer or contact our compliance team directly at:

• Dispute Processing (FCRA): disputes.trucheck@verifiedid.co
• Privacy & Data Rights: privacy.trucheck@verifiedid.co

9. Contact Us

If you have any questions regarding this Privacy Policy or TruCheck’s processing behaviors, please contact:

VerifiedID LLC

Attn: TruCheck Privacy and Compliance Office

11180 State Bridge Road, Suite 303, Alpharetta, GA 30022, USA

Toll-Free Phone: (888) 718-2597

Email: privacy.trucheck@verifiedid.co

Disputes: disputes.trucheck@verifiedid.co