Policy Classification: Public
Document Type: Background Screening Quality and Accuracy Policy
Applicability: Clients, Candidates, Data Subjects, Employees, Researchers, Verifiers, Analysts, Contractors, Verification Partners, and Authorized Service Providers
Policy Owner: Risk and Compliance / Operations Management
Approving Authority: Circa Logica Group Management
Version: 2.2
Effective Date: 1 July 2022
Last Review Date: 6 January 2026

PART I

GENERAL POLICY FRAMEWORK

1. POLICY STATEMENT

Talentprobe Due Diligence (“Talentprobe”), operated by Circa Logica Group (“CLG”), recognizes that the value of a background screening report depends upon the quality, accuracy, relevance, consistency, and appropriate interpretation of the information contained in it.

Background screening can involve information concerning an individual’s identity, education, employment, professional qualifications, references, court or public records, regulatory information, credentials, and other aspects of a person’s professional or personal history. Incorrect, incomplete, outdated, misattributed, or improperly characterized information may adversely affect both the individual being screened and the organization relying upon the report.

Talentprobe therefore maintains a quality assurance framework designed to promote reasonable accuracy and reliability throughout the screening lifecycle.

Talentprobe shall seek to ensure that information included in screening reports is obtained from appropriate sources, reasonably verified according to the nature of the check, attributed to the correct individual, presented with appropriate context, and subjected to applicable quality controls before being released.

Talentprobe shall further maintain mechanisms for identifying, investigating, correcting, and preventing material errors.

Quality and accuracy are continuing responsibilities. They apply from the moment a screening request is received through research, verification, analysis, reporting, delivery, correction, dispute resolution, and applicable post-report quality review.

2. PURPOSE

This Policy establishes Talentprobe’s principles and standards concerning:

a. background screening quality;

b. accuracy and reliability of reported information;

c. verification standards;

d. source selection and source reliability;

e. identity matching;

f. evidence and documentation;

g. handling of discrepancies;

h. treatment of incomplete or unverifiable information;

i. quality control and report review;

j. correction of errors;

k. amendment of reports;

l. candidate disputes affecting report accuracy;

m. risk classification and presentation of findings;

n. quality monitoring;

o. corrective and preventive action;

p. independence and neutrality;

q. accountability; and

r. continuous improvement.

This Policy is intended to provide clients, candidates, auditors, procurement teams, compliance functions, and other stakeholders with a clear understanding of Talentprobe’s commitment to responsible and accurate background screening.

3. SCOPE

This Policy applies to background screening, verification, and due diligence services performed by or on behalf of Talentprobe.

Depending upon the service requested, this may include:

a. identity verification;

b. address verification;

c. employment verification;

d. education verification;

e. professional qualification and license verification;

f. reference checking;

g. character reference verification;

h. court and public record searches;

i. criminal record-related searches where legally permissible;

j. sanctions and watchlist screening;

k. regulatory and compliance checks;

l. professional membership verification;

m. credential verification;

n. driving record verification where applicable;

o. financial or credit-related checks where legally permissible and appropriate;

p. social media or publicly available information reviews where authorized;

q. government record verification;

r. due diligence investigations; and

s. other verification services lawfully offered by Talentprobe.

The specific verification method and evidentiary requirements may differ according to the nature of the check, availability of sources, applicable law, jurisdiction, client instruction, and other legitimate circumstances.

4. OBJECTIVES

Talentprobe’s quality framework is intended to:

a. minimize material reporting errors;

b. promote consistent verification standards;

c. reduce the risk of mistaken identity;

d. distinguish verified facts from allegations, discrepancies, opinions, or unresolved information;

e. ensure that findings are supported by appropriate evidence;

f. prevent unsupported conclusions;

g. identify limitations in available information;

h. provide appropriate context to clients;

i. provide mechanisms for candidates to challenge potentially inaccurate findings;

j. correct substantiated errors promptly;

k. identify recurring quality issues;

l. improve verification processes continuously; and

m. maintain confidence in Talentprobe’s screening services.

PART II

CORE QUALITY PRINCIPLES

5. ACCURACY

Talentprobe shall take reasonable measures appropriate to the nature of the check to ensure that information included in a screening report accurately reflects the information verified or obtained from the relevant source.

Accuracy includes more than transcription.

Talentprobe shall seek to ensure that:

a. information relates to the correct individual;

b. information is represented consistently with the underlying source;

c. material information is not knowingly omitted in a manner that would make the finding misleading;

d. dates, names, institutions, employers, positions, qualifications, and other relevant details are recorded accurately;

e. limitations affecting the reliability of a finding are appropriately communicated; and

f. opinions or assumptions are not presented as verified facts.

6. RELEVANCE

Information included in a report should be relevant to the authorized screening service.

The existence of information does not automatically justify its inclusion.

Talentprobe shall seek to avoid including information that is clearly unrelated to the authorized check, unnecessarily intrusive, prohibited by applicable law, or incapable of serving a legitimate screening purpose.

7. PROPORTIONALITY

The level of verification performed should be proportionate to the nature of the check, the authorized scope, the potential consequences of the information, and the availability of reliable sources.

More consequential findings may warrant additional review or verification where reasonably practicable.

8. OBJECTIVITY

Talentprobe shall seek to report information objectively.

Reports should distinguish between:

a. verified information;

b. information supplied by the candidate;

c. information supplied by a third party;

d. discrepancies;

e. allegations;

f. pending matters;

g. unresolved information;

h. information that could not be independently verified;

i. opinions provided by references; and

j. conclusions supported by documented verification.

Talentprobe personnel shall not knowingly alter the characterization of a finding to produce a desired employment outcome.

9. NEUTRALITY

Talentprobe is an information verification and due diligence provider.

Talentprobe does not ordinarily determine whether a candidate should be hired, rejected, promoted, retained, transferred, or terminated.

Talentprobe may identify verified findings, discrepancies, risk indicators, or classifications according to established criteria, but the client remains responsible for the final employment or business decision.

10. CONSISTENCY

Similar information should, to the extent reasonably practicable, be treated according to consistent standards.

Talentprobe shall maintain internal procedures, definitions, classifications, guidance, and quality controls intended to reduce arbitrary differences in the treatment of substantially similar findings.

Consistency does not require identical treatment where relevant circumstances differ.

11. TRACEABILITY

Material findings should be reasonably traceable to the source, verification activity, evidence, or documentation supporting the finding.

Talentprobe shall maintain appropriate records sufficient to establish how a material finding was reached, subject to applicable privacy, security, contractual, and retention requirements.

PART III

VERIFICATION STANDARDS

12. VERIFICATION PRINCIPLE

Talentprobe shall seek to verify information through sources reasonably appropriate to the nature of the information being checked.

Verification methodology may differ according to:

a. type of check;

b. jurisdiction;

c. source availability;

d. institutional practices;

e. applicable law;

f. age of the information;

g. responsiveness of the source;

h. quality of available records; and

i. other legitimate operational circumstances.

The inability to use one verification method does not necessarily mean that information cannot be verified through another appropriate method.

13. PRIMARY SOURCES

Where reasonably practicable and appropriate, Talentprobe may seek information from primary or authoritative sources.

Examples may include:

a. the employer being verified;

b. the educational institution that issued the credential;

c. the professional organization or licensing authority responsible for the credential;

d. the relevant court or government agency;

e. an official registry;

f. an authorized institutional representative;

g. the issuing organization; or

h. another authoritative custodian of the relevant record.

Primary-source verification is preferred where it is reasonably available and appropriate to the nature of the check.

14. SECONDARY SOURCES

Secondary sources may be used where:

a. primary-source information is unavailable;

b. the primary source does not respond;

c. records are archived or inaccessible;

d. another recognized source maintains reliable information;

e. the nature of the check reasonably permits secondary verification; or

f. circumstances otherwise justify use of the source.

Where reliance on a secondary source materially affects the certainty of a finding, Talentprobe may appropriately qualify the result.

15. CANDIDATE-PROVIDED DOCUMENTS

Documents supplied by a candidate may assist the verification process but shall not necessarily constitute independent verification.

Where appropriate, Talentprobe may attempt to authenticate or corroborate candidate-provided documents through an issuing institution, official source, independent record, or other reasonable method.

A document shall not automatically be treated as fraudulent solely because independent verification is unavailable.

Likewise, possession of a document shall not automatically establish its authenticity where circumstances reasonably require additional verification.

16. PUBLICLY AVAILABLE SOURCES

Where public information forms part of an authorized screening service, Talentprobe shall seek to consider:

a. reliability of the source;

b. identity of the person to whom the information relates;

c. relevance to the authorized purpose;

d. date and currency of the information;

e. context in which the information appears;

f. applicable legal restrictions; and

g. risk of misinterpretation.

Public availability alone does not establish accuracy.

17. SOURCE RELIABILITY

Talentprobe shall consider the reliability and appropriateness of sources used for verification.

Factors may include:

a. whether the source is official or authoritative;

b. whether the source is responsible for maintaining the relevant record;

c. whether the information can reasonably be authenticated;

d. whether the source is current;

e. whether the source has a known relationship to the subject;

f. whether independent corroboration is available;

g. whether material inconsistencies exist; and

h. whether reliance on the source is appropriate under the circumstances.

PART IV

IDENTITY MATCHING

18. CORRECT SUBJECT IDENTIFICATION

Talentprobe recognizes that mistaken identity is a significant risk in background screening.

A record should not be attributed to a candidate merely because the candidate shares the same or a similar name with the person identified in the record.

Where reasonably necessary and available, Talentprobe may use additional identifiers such as:

a. middle name;

b. date of birth;

c. address;

d. photograph;

e. employment information;

f. educational information;

g. government-issued identifiers;

h. location;

i. other biographical information; or

j. other distinguishing information.

19. COMMON NAMES AND POSSIBLE MATCHES

Where available information is insufficient to establish reasonable confidence that a record relates to the candidate, Talentprobe should avoid representing the record as a confirmed match.

The result may instead be reported, where appropriate, as:

a. possible match;

b. unable to conclusively match;

c. further information required;

d. verification pending;

e. inconclusive; or

f. another appropriately qualified status.

The terminology used may vary depending upon the check and applicable reporting standards.

20. FALSE POSITIVE PREVENTION

Talentprobe shall maintain reasonable procedures intended to reduce false positive matches.

Where a potentially adverse record is identified, additional identity verification may be undertaken where reasonably practicable before the information is reported as relating to the candidate.

PART V

EMPLOYMENT AND EDUCATION VERIFICATION

21. EMPLOYMENT VERIFICATION

Employment verification should seek to establish information relevant to the authorized scope, which may include:

a. employer identity;

b. employment dates;

c. position or job title;

d. employment status;

e. department;

f. responsibilities where requested and available;

g. reason for separation where legally permissible and appropriately provided;

h. eligibility for rehire where relevant and lawfully available; and

i. other authorized employment information.

Talentprobe shall report material discrepancies between candidate-provided information and independently verified information where relevant to the requested service.

22. EMPLOYMENT RECORDS THAT CANNOT BE VERIFIED

An inability to verify employment does not automatically mean that the candidate supplied false information.

Verification may be unsuccessful because:

a. an employer has ceased operations;

b. records are no longer available;

c. the employer has changed ownership;

d. the employer does not respond;

e. the employer refuses to disclose information;

f. records have been archived;

g. contact information cannot be independently validated;

h. the employer maintains limited historical records; or

i. another legitimate limitation exists.

Such cases should be reported according to the available evidence and appropriate status rather than automatically characterized as dishonesty.

23. EDUCATION VERIFICATION

Education verification should seek to establish information relevant to the authorized scope, which may include:

a. institution;

b. qualification;

c. degree or diploma;

d. field of study;

e. attendance dates;

f. graduation or completion;

g. honors or distinctions where requested and available; and

h. other authorized educational information.

24. EDUCATIONAL DISCREPANCIES

Differences in terminology, dates, institution names, campus names, degree descriptions, or historical records should be assessed in context before being classified as material discrepancies.

Talentprobe shall seek to distinguish substantive discrepancies from administrative, formatting, translation, or terminology differences.

PART VI

COURT, CRIMINAL, REGULATORY, AND PUBLIC RECORD INFORMATION

25. CARE IN REPORTING ADVERSE INFORMATION

Potentially adverse information requires particular care because of its potential impact upon individuals.

Talentprobe shall seek to ensure that adverse information is:

a. associated with the correct individual;

b. derived from an appropriate source;

c. reported according to its actual status;

d. not materially overstated;

e. appropriately contextualized where necessary; and

f. reported in accordance with applicable law.

26. ALLEGATIONS, CHARGES, PENDING CASES, AND CONVICTIONS

Talentprobe shall seek to distinguish among legally or factually different types of information.

An allegation is not equivalent to a conviction.

A complaint is not necessarily equivalent to a finding of liability.

A pending case is not necessarily equivalent to a final judgment.

An arrest, charge, filing, proceeding, or similar record shall not knowingly be described as a conviction unless the underlying record supports that characterization.

Where the status of a matter is material to the report, Talentprobe shall seek to report the status supported by the available source.

27. NO RECORD OR CLEAR RESULT

A “clear,” “no record,” or equivalent result means that the relevant search did not identify a reportable record within the scope, sources, identifiers, jurisdiction, and time of the check performed.

It should not be interpreted as an absolute representation that no record exists anywhere.

This distinction is particularly important where databases, courts, agencies, or other sources have different coverage, availability, indexing, or reporting practices.

28. LIMITATIONS OF DATABASES

Talentprobe recognizes that databases may contain:

a. incomplete records;

b. delayed updates;

c. historical information;

d. name variations;

e. data entry errors;

f. limited jurisdictional coverage; or

g. other limitations.

Database information may therefore require additional verification or qualification depending upon the nature of the check and the significance of the information.

PART VII

REFERENCES AND SUBJECTIVE INFORMATION

29. REFERENCE CHECKS

Reference checks may contain opinions, observations, recollections, or assessments provided by third parties.

Talentprobe shall distinguish such information from independently verified objective facts where appropriate.

Talentprobe does not warrant that a reference’s personal opinion is objectively correct.

Talentprobe’s responsibility is to reasonably and accurately document the information provided within the authorized scope of the reference check.

30. ATTRIBUTION

Where appropriate, subjective statements should be attributed to the relevant source or characterized as reference feedback rather than presented as an independently established fact.

PART VIII

DISCREPANCIES AND FINDINGS

31. DEFINITION OF DISCREPANCY

A discrepancy may exist where information supplied by a candidate materially differs from information obtained through an appropriate verification source.

Not every difference constitutes a material discrepancy.

Talentprobe shall consider the nature, significance, context, and available evidence before classifying a difference.

32. MATERIALITY

Materiality may depend upon factors including:

a. significance of the information;

b. magnitude of the difference;

c. relevance to the verification;

d. whether the discrepancy can reasonably be explained;

e. reliability of the underlying source;

f. potential administrative or clerical causes; and

g. other relevant circumstances.

33. CANDIDATE EXPLANATIONS

Where appropriate, a candidate may be given an opportunity to provide additional information, clarification, or documentation concerning a discrepancy.

Candidate explanations shall be considered according to the available evidence and applicable verification procedures.

An explanation shall not automatically override independently verified information, but it may provide material context or enable further verification.

34. UNVERIFIABLE INFORMATION

Where Talentprobe cannot obtain sufficient evidence to verify or disprove information, the report should appropriately reflect the limitation.

Talentprobe shall avoid automatically converting “unable to verify” into an adverse factual finding.

PART IX

REPORTING STANDARDS

35. REPORT INTEGRITY

Talentprobe reports shall seek to present findings clearly, accurately, consistently, and in a manner appropriate to the service performed.

Reports should allow an authorized reader to reasonably distinguish among:

a. information provided by the candidate;

b. information independently verified;

c. discrepancies;

d. information that could not be verified;

e. pending verification;

f. adverse records;

g. limitations; and

h. other relevant findings.

36. FACTUAL REPORTING

Reports should focus on factual findings supported by available evidence.

Talentprobe personnel shall not knowingly:

a. fabricate information;

b. materially alter source information;

c. omit material context in a misleading manner;

d. characterize an unresolved allegation as a proven fact;

e. attribute a record to a person without a reasonable basis;

f. modify findings to satisfy a preferred client outcome; or

g. intentionally misstate the result of a verification.

37. REPORT LIMITATIONS

Where a material limitation affects the completeness or certainty of a check, the limitation should be appropriately communicated.

Examples may include:

a. unavailable records;

b. non-responsive institutions;

c. inaccessible archives;

d. incomplete identifiers;

e. jurisdictional limitations;

f. source restrictions;

g. inability to independently authenticate information; or

h. other circumstances affecting verification.

38. TIMELINESS AND CURRENCY

Talentprobe shall seek to use information reasonably current for the relevant check.

Where historical information is relevant, the report should not imply that historical information necessarily reflects current circumstances.

Screening reports represent findings based on information available at the time the relevant checks were performed.

PART X

RISK CLASSIFICATION

39. PURPOSE OF RISK CLASSIFICATION

Talentprobe may use risk classifications, indicators, flags, or similar tools to assist clients in understanding the nature or significance of reported findings.

Such classifications are intended to summarize screening findings according to established criteria.

40. NO AUTOMATIC EMPLOYMENT RECOMMENDATION

A Talentprobe risk classification is not a hiring recommendation.

A Low, Moderate, High, or other risk classification, where used, describes the screening findings according to Talentprobe’s applicable classification framework.

It does not independently determine whether the candidate is suitable or unsuitable for employment.

The client remains responsible for evaluating:

a. relevance of the finding to the position;

b. applicable employment law;

c. company policy;

d. individual circumstances;

e. proportionality;

f. candidate explanation;

g. business requirements; and

h. the final employment decision.

41. CLASSIFICATION CONSISTENCY

Risk classifications shall be applied according to established criteria intended to promote consistency.

Talentprobe may periodically review and update classification standards to reflect legal requirements, operational experience, quality findings, and changes in screening practices.

42. HUMAN REVIEW

Where a material finding requires interpretation or classification, Talentprobe may apply appropriate human review according to the nature of the check and applicable procedures.

Technology may assist screening operations but does not eliminate Talentprobe’s responsibility for reasonable quality control.

PART XI

QUALITY CONTROL

43. QUALITY ASSURANCE FRAMEWORK

Talentprobe shall maintain a quality assurance framework appropriate to the nature, scale, and risk of its screening operations.

The framework may include:

a. verification standards;

b. analyst guidance;

c. supervisory review;

d. quality checks;

e. report review;

f. exception management;

g. audit sampling;

h. error monitoring;

i. dispute analysis;

j. training;

k. corrective action; and

l. process improvement.

44. PRE-RELEASE QUALITY REVIEW

Reports or findings may be subject to applicable review before release.

The level of review may vary according to:

a. type of check;

b. complexity;

c. materiality;

d. risk;

e. presence of adverse information;

f. discrepancy;

g. source limitations; and

h. other relevant circumstances.

Talentprobe may apply enhanced review to findings that present a higher risk of material impact or error.

45. QUALITY REVIEW CRITERIA

Quality review may consider:

a. candidate identity;

b. completeness of required checks;

c. source documentation;

d. consistency between evidence and finding;

e. accuracy of data entry;

f. correct classification;

g. appropriate terminology;

h. material discrepancies;

i. unresolved issues;

j. report formatting;

k. applicable limitations; and

l. other relevant quality requirements.

46. SEGREGATION OF RESPONSIBILITIES

Where appropriate to the nature and risk of the work, Talentprobe may separate research, verification, review, or approval responsibilities to strengthen quality control.

Not every routine verification requires multiple independent personnel. Review requirements shall be proportionate to the nature and risk of the check.

47. QUALITY SAMPLING

Talentprobe may conduct periodic or risk-based sampling of completed cases to evaluate compliance with applicable verification and reporting standards.

Sampling may consider:

a. accuracy;

b. completeness;

c. documentation;

d. classification;

e. timeliness;

f. procedural compliance;

g. recurring errors; and

h. opportunities for improvement.

PART XII

ERROR MANAGEMENT AND CORRECTION

48. DEFINITION OF ERROR

For purposes of this Policy, an error may include a material inaccuracy caused by:

a. incorrect data entry;

b. transcription;

c. mistaken identity;

d. incorrect source interpretation;

e. inappropriate classification;

f. incomplete reporting;

g. technical processing;

h. failure to incorporate material verified information;

i. incorrect status;

j. unauthorized alteration; or

k. another failure affecting the accuracy of a report.

49. ERROR REPORTING

Potential errors may be identified through:

a. internal quality review;

b. candidate dispute;

c. client notification;

d. source correction;

e. audit;

f. system monitoring;

g. personnel escalation; or

h. other means.

Talentprobe personnel are expected to escalate suspected material errors through established channels.

50. INVESTIGATION OF POTENTIAL ERRORS

Talentprobe shall reasonably investigate credible allegations of material error.

Investigation may include:

a. review of source evidence;

b. review of verification records;

c. recontacting the source;

d. checking candidate identifiers;

e. reviewing communications;

f. obtaining additional documentation;

g. reviewing analyst actions;

h. conducting independent re-verification; or

i. other appropriate measures.

51. CORRECTION

Where Talentprobe establishes that a material error occurred, it shall take appropriate corrective action.

This may include:

a. correcting the underlying record;

b. amending the report;

c. changing a classification;

d. adding necessary context;

e. withdrawing an incorrect finding;

f. notifying the relevant client;

g. notifying the candidate where appropriate;

h. documenting the correction; and

i. taking preventive action where necessary.

52. REPORT AMENDMENT

An amended report should clearly supersede or supplement the affected prior report where appropriate.

Talentprobe shall maintain reasonable version control so that corrected information can be distinguished from prior information.

Where a material correction affects a report previously delivered to a client, Talentprobe shall take reasonable measures to provide the corrected information to the relevant authorized recipient.

53. CORRECTION DOES NOT IMPLY ORIGINAL NEGLIGENCE

The correction of information does not, by itself, establish that Talentprobe acted negligently or failed to follow appropriate procedures.

Information may change after verification, sources may subsequently amend records, new evidence may become available, or previously unavailable information may later become accessible.

Talentprobe shall evaluate each correction according to its circumstances.

PART XIII

CANDIDATE DISPUTES

54. RIGHT TO RAISE A DISPUTE

Candidates may raise a good-faith dispute concerning information in a Talentprobe report that they reasonably believe is inaccurate, incomplete, outdated, or attributed to the wrong individual.

Talentprobe shall provide an appropriate channel for such disputes.

55. DISPUTE INFORMATION

Talentprobe may request sufficient information to identify and investigate the disputed finding, including:

a. candidate identity;

b. affected report or case;

c. disputed information;

d. explanation of the alleged error;

e. supporting documentation; and

f. other information reasonably necessary to investigate.

56. REINVESTIGATION

A dispute may result in re-verification or reinvestigation where appropriate.

Talentprobe shall evaluate the original source, candidate-provided evidence, available records, and other relevant information.

57. GOOD-FAITH DISPUTES

Talentprobe shall not knowingly penalize a candidate merely for raising a legitimate dispute.

The existence of a dispute does not automatically mean that the original finding was incorrect.

Likewise, the original finding shall not automatically be treated as correct merely because it was previously reported.

The matter shall be assessed according to the available evidence.

58. CLIENT COMMUNICATION DURING DISPUTES

Where a material finding already provided to a client is subject to a credible dispute, Talentprobe may inform the client that the relevant information is under review where appropriate.

Following resolution, Talentprobe may provide an amended, confirmed, or otherwise updated result.

Detailed dispute procedures are governed by the Candidate Rights, Dispute and Resolution Policy.

PART XIV

QUALITY INCIDENTS AND ROOT CAUSE MANAGEMENT

59. QUALITY INCIDENTS

A significant quality incident may include:

a. material false positive;

b. material false negative attributable to process failure;

c. mistaken identity;

d. unsupported adverse finding;

e. incorrect classification with material impact;

f. systemic reporting defect;

g. unauthorized report alteration;

h. repeated verification failure;

i. significant source reliability issue; or

j. another event materially affecting report integrity.

60. ROOT CAUSE ANALYSIS

Significant or recurring quality incidents may be subject to root cause analysis.

Root causes may include:

a. personnel error;

b. unclear procedures;

c. inadequate training;

d. source limitations;

e. system defects;

f. workflow deficiencies;

g. insufficient quality controls;

h. vendor performance;

i. data quality problems; or

j. other contributing factors.

61. CORRECTIVE AND PREVENTIVE ACTION

Where appropriate, Talentprobe may implement corrective and preventive measures including:

a. procedure changes;

b. additional training;

c. enhanced review;

d. system changes;

e. source replacement;

f. vendor corrective action;

g. classification changes;

h. updated guidance;

i. additional monitoring; or

j. disciplinary action where misconduct is involved.

PART XV

PERSONNEL COMPETENCE AND ACCOUNTABILITY

62. TRAINING

Personnel involved in screening should receive training or guidance appropriate to their responsibilities.

Training may include:

a. verification procedures;

b. privacy;

c. confidentiality;

d. source evaluation;

e. identity matching;

f. report preparation;

g. risk classification;

h. quality standards;

i. dispute handling;

j. information security; and

k. applicable legal or regulatory requirements.

63. COMPETENCE

Talentprobe shall seek to assign screening activities to personnel with appropriate training, experience, supervision, or guidance for the work performed.

More complex or consequential matters may be escalated to more experienced personnel where appropriate.

64. PERSONNEL ACCOUNTABILITY

Personnel are responsible for following applicable verification and quality requirements.

Intentional falsification, fabrication, unauthorized modification, concealment of material errors, or deliberate misrepresentation of screening findings is prohibited and may result in disciplinary or contractual action.

65. CONFLICTS OF INTEREST

Personnel should disclose circumstances that could reasonably compromise their impartiality in performing a screening activity.

Talentprobe may reassign a case or implement another appropriate control where a material conflict exists.

PART XVI

THIRD-PARTY AND VERIFICATION PARTNER QUALITY

66. THIRD-PARTY VERIFICATION SERVICES

Talentprobe may use authorized third parties to assist with certain screening activities.

Use of a third party does not eliminate Talentprobe’s responsibility to maintain reasonable standards concerning information incorporated into Talentprobe reports.

67. THIRD-PARTY QUALITY EXPECTATIONS

Where appropriate, third-party verification providers may be expected to maintain standards concerning:

a. lawful information gathering;

b. confidentiality;

c. accuracy;

d. source documentation;

e. timely reporting;

f. correction of errors;

g. information security; and

h. escalation of material issues.

68. THIRD-PARTY PERFORMANCE

Talentprobe may review third-party performance based on factors including:

a. accuracy;

b. responsiveness;

c. turnaround time;

d. documentation quality;

e. dispute rates;

f. error rates;

g. compliance; and

h. other relevant performance indicators.

Material or recurring quality concerns may result in corrective action, enhanced monitoring, suspension, or discontinuation of the relationship.

PART XVII

TECHNOLOGY AND AUTOMATION

69. TECHNOLOGY-ASSISTED SCREENING

Talentprobe may use technology, automation, data matching, artificial intelligence-assisted tools, or other systems to support screening operations.

Technology may assist with:

a. workflow management;

b. document processing;

c. information organization;

d. identity matching;

e. data extraction;

f. research;

g. quality checks;

h. anomaly identification; and

i. other operational activities.

70. TECHNOLOGY DOES NOT REPLACE ACCOUNTABILITY

The use of technology does not remove Talentprobe’s responsibility to maintain appropriate quality controls.

Automated outputs should not be treated as inherently accurate solely because they were generated by a technological system.

Where appropriate, material findings may be subjected to human verification or review.

71. SYSTEM QUALITY

Talentprobe shall seek to identify and address system issues that could materially affect report accuracy.

Where a system defect is identified as potentially affecting multiple reports, Talentprobe may conduct an appropriate impact assessment and corrective review.

PART XVIII

QUALITY MEASUREMENT

72. QUALITY MONITORING

Talentprobe may maintain quality indicators to evaluate the effectiveness of screening operations.

Indicators may include:

a. identified error rates;

b. correction rates;

c. dispute volumes;

d. substantiated dispute rates;

e. quality audit results;

f. rework;

g. source-related issues;

h. turnaround performance;

i. recurring error categories; and

j. other appropriate measures.

73. ERROR RATE

Talentprobe may establish internal quality targets concerning reporting errors.

Any externally communicated error rate or quality metric should be based on a defined measurement methodology and applicable reporting period.

Talentprobe shall avoid representing a quality metric as an absolute guarantee that no error can occur.

74. TREND ANALYSIS

Quality information may be periodically reviewed to identify:

a. recurring errors;

b. problematic sources;

c. training needs;

d. system issues;

e. process bottlenecks;

f. dispute patterns;

g. vendor performance issues; and

h. opportunities for improvement.

75. MANAGEMENT REVIEW

Relevant quality information may be reported to appropriate management personnel for review, oversight, corrective action, resource allocation, and continuous improvement.

PART XIX

LIMITATIONS AND CLIENT RESPONSIBILITY

76. NATURE OF BACKGROUND SCREENING

Background screening is dependent upon information available from candidates, institutions, employers, courts, government agencies, databases, references, and other sources.

Talentprobe cannot guarantee that every source:

a. maintains complete information;

b. maintains error-free information;

c. responds to verification requests;

d. retains historical records indefinitely;

e. provides information within a particular period;

f. makes information publicly or legally available; or

g. updates records immediately.

77. NO ABSOLUTE GUARANTEE

Talentprobe shall exercise reasonable care and maintain appropriate quality controls, but no background screening provider can reasonably guarantee that every source record is complete, current, or free from error.

A screening report represents the results of the checks performed using information reasonably available within the authorized scope and relevant period.

78. SCOPE LIMITATIONS

A report does not establish facts beyond the scope of the checks actually performed.

For example, a court records search does not constitute an NBI clearance unless NBI verification was specifically included in the authorized service.

Similarly, a clear result from one source does not constitute a representation concerning records maintained exclusively by another source that was outside the authorized scope.

79. CLIENT USE OF REPORTS

Clients are responsible for reviewing Talentprobe reports appropriately and considering any stated limitations.

Clients should not:

a. interpret an incomplete check as a completed verification;

b. treat an unable-to-verify result automatically as misconduct;

c. treat an allegation as a conviction;

d. disregard material report limitations;

e. use screening information for unlawful discriminatory purposes; or

f. represent Talentprobe’s risk classification as an automatic hiring decision.

80. CLIENT DECISION-MAKING

The final decision regarding employment, engagement, promotion, retention, or other action remains with the client.

Talentprobe does not warrant that a particular candidate is suitable or unsuitable for a particular position solely because of a screening result.

PART XX

RECORDKEEPING AND AUDITABILITY

81. QUALITY RECORDS

Talentprobe shall maintain records appropriate to support quality assurance and report traceability.

Such records may include:

a. verification evidence;

b. source records;

c. correspondence;

d. analyst notes;

e. review records;

f. report versions;

g. corrections;

h. disputes;

i. quality audit records; and

j. corrective action records.

Retention shall be governed by applicable privacy, contractual, legal, and retention requirements.

82. AUDIT TRAIL

Where appropriate, Talentprobe systems or processes may maintain an audit trail concerning material case activities.

Audit information may support:

a. quality review;

b. security;

c. dispute investigation;

d. regulatory compliance;

e. accountability; and

f. process improvement.

83. CONFIDENTIALITY OF QUALITY RECORDS

Quality records may contain personal data, confidential business information, internal methodologies, source information, security information, or privileged material.

Accordingly, not all quality records are available for public or client inspection.

Talentprobe may provide appropriate evidence or summaries of quality controls without disclosing information that would compromise privacy, confidentiality, security, legal privilege, or verification integrity.

PART XXI

RELATIONSHIP WITH OTHER POLICIES

84. DATA PRIVACY

Personal data processed for quality assurance purposes shall remain subject to Talentprobe’s Data Privacy and Protection Policy.

Quality assurance does not authorize unrestricted collection, use, or retention of personal data.

85. INFORMATION SECURITY

Verification records, reports, evidence, and quality documentation shall be protected according to Talentprobe’s Information Security and Data Breach Management Policy and applicable internal security requirements.

86. RETENTION

Quality records and screening evidence shall be retained and disposed of according to Talentprobe’s Data Retention and Secure Disposal Policy.

87. CANDIDATE RIGHTS AND DISPUTES

Detailed procedures governing candidate access, disputes, appeals, corrections, and related rights are addressed in Talentprobe’s Candidate Rights, Dispute and Resolution Policy.

88. DATA PROCESSING AGREEMENTS

Where Talentprobe performs screening as a processor on behalf of a client, applicable quality activities shall also be performed consistently with the relevant Data Processing Agreement and lawful client instructions.

PART XXII

GOVERNANCE AND CONTINUOUS IMPROVEMENT

89. MANAGEMENT RESPONSIBILITY

Talentprobe management shall promote a culture in which report accuracy, responsible verification, and appropriate escalation are treated as operational priorities.

Commercial pressure, client expectations, turnaround requirements, or case volume shall not justify intentional compromise of report integrity.

90. QUALITY OVERSIGHT

Appropriate operational, risk, compliance, or management functions shall oversee the implementation of this Policy.

Responsibilities may include:

a. defining quality standards;

b. reviewing quality performance;

c. investigating significant incidents;

d. approving corrective actions;

e. monitoring recurring issues;

f. reviewing training requirements;

g. assessing verification partners;

h. updating procedures; and

i. reporting material quality concerns to management.

91. CONTINUOUS IMPROVEMENT

Talentprobe shall periodically evaluate its screening processes and quality controls.

Improvements may be driven by:

a. quality reviews;

b. disputes;

c. candidate feedback;

d. client feedback;

e. audit findings;

f. regulatory developments;

g. technology changes;

h. source availability;

i. operational experience;

j. quality metrics; and

k. recognized industry practices.

92. POLICY REVIEW

This Policy shall be reviewed periodically and may be revised in response to:

a. changes in law or regulation;

b. changes in Talentprobe services;

c. material changes in verification methods;

d. new technologies;

e. quality incidents;

f. audit findings;

g. changes in risk;

h. client requirements;

i. operational developments; or

j. changes in Circa Logica Group governance requirements.

93. POLICY AVAILABILITY

This Policy is classified as a public policy and may be:

a. published on Talentprobe’s official website;

b. provided to clients;

c. provided during vendor accreditation;

d. submitted in response to procurement or due diligence requests;

e. shared with candidates;

f. provided to auditors or compliance reviewers; and

g. otherwise made available to legitimate stakeholders.

Internal procedures, proprietary methodologies, verification techniques, security controls, source arrangements, fraud detection methods, and detailed quality thresholds may remain confidential.

PART XXIII

QUALITY AND ACCURACY COMMITMENT

94. TALENTPROBE COMMITMENT

Talentprobe recognizes that background screening is not simply the collection of information.

It is the responsible verification, interpretation, documentation, and communication of information that may influence important decisions.

Talentprobe therefore commits to maintaining reasonable and appropriate standards designed to ensure that:

the right information is associated with the right person;

information is obtained from appropriate sources;

verified facts are distinguished from allegations, opinions, and unresolved information;

material discrepancies are appropriately investigated and reported;

limitations are disclosed rather than concealed;

potentially adverse findings receive appropriate care;

substantiated errors are corrected;

candidates have an appropriate mechanism to challenge potentially inaccurate information;

quality issues are analyzed and used to improve processes; and

screening findings remain informational and do not replace the client’s responsibility for the final employment decision.

Talentprobe shall continuously seek to improve the accuracy, consistency, reliability, and integrity of its background screening services.

Accuracy is not treated solely as an operational metric. It is a fundamental responsibility to the candidates whose information we process and to the organizations that rely upon our work.