Policy Classification: Public
Document Type: Candidate Rights, Dispute and Resolution Policy
Applicability: Candidates, Data Subjects, Clients, Employees, Researchers, Verifiers, Analysts, Contractors, Verification Partners, and Authorized Service Providers
Policy Owner: Data Privacy, Protection, and Security Office / Risk and Compliance
Approving Authority: Circa Logica Group Management
Version: 4.3
Effective Date: 1 December 2023
Last Review Date: 6 January 2026

PART I

GENERAL POLICY FRAMEWORK

1. POLICY STATEMENT

Talentprobe Due Diligence (“Talentprobe”), operated by Circa Logica Group (“CLG” or the “Group”), recognizes that individuals whose information is processed in connection with background screening and due diligence have legitimate rights and interests concerning the accuracy, fairness, security, transparency, and lawful processing of their personal data.

Background screening may involve information that can materially affect employment, engagement, credentialing, contracting, access, risk management, or other decisions made by Talentprobe clients. Talentprobe therefore maintains mechanisms through which candidates and other data subjects may exercise applicable privacy rights, request access to information, question or dispute screening findings, submit clarifications or supporting evidence, request correction of inaccurate information, and raise concerns regarding the processing of their personal data.

Talentprobe shall handle candidate requests and disputes objectively, respectfully, consistently, securely, and without unnecessary procedural barriers.

A candidate shall not be treated as having admitted the accuracy of a finding merely because the candidate does not immediately dispute it. Likewise, the submission of a dispute does not automatically establish that the original finding was incorrect.

Talentprobe shall evaluate disputed information according to available evidence, appropriate verification standards, applicable law, the reliability of relevant sources, and the circumstances of the case.

Talentprobe shall distinguish between:

a. a request to exercise a data subject right;

b. a dispute concerning the factual accuracy of screening information;

c. a request for clarification;

d. a request for correction or rectification;

e. an appeal or request for reconsideration;

f. a privacy complaint;

g. a security concern; and

h. a disagreement with an employment decision made by a client.

Talentprobe shall address matters within its authority while recognizing that final employment or engagement decisions ordinarily remain the responsibility of the client.

2. PURPOSE

This Policy establishes Talentprobe’s framework for:

a. protecting candidate and data subject rights;

b. providing reasonable transparency concerning personal data processing;

c. receiving and evaluating requests for access;

d. receiving and evaluating requests for rectification;

e. receiving requests for erasure or blocking;

f. receiving objections to processing;

g. addressing applicable data portability requests;

h. receiving screening-result disputes;

i. receiving supporting evidence and candidate explanations;

j. conducting reinvestigation or re-verification where appropriate;

k. correcting inaccurate screening information;

l. issuing amended reports;

m. notifying relevant recipients of material corrections where appropriate;

n. reviewing disputed risk classifications;

o. providing an escalation or appeal mechanism;

p. receiving privacy complaints;

q. protecting candidates from improper treatment for exercising legitimate rights;

r. documenting disputes and resolutions;

s. identifying recurring causes of disputes or errors; and

t. supporting continuous improvement of Talentprobe’s screening services.

3. SCOPE

This Policy applies to individuals whose personal information is processed by Talentprobe in connection with:

a. pre-employment screening;

b. employment-related screening;

c. background verification;

d. identity verification;

e. employment verification;

f. education verification;

g. reference checking;

h. professional credential verification;

i. court and public record searches;

j. criminal record-related searches where lawfully performed;

k. sanctions and watchlist screening;

l. regulatory or compliance screening;

m. professional membership verification;

n. due diligence;

o. periodic or continuing screening where authorized;

p. post-employment or engagement screening where lawful and authorized; and

q. other verification or due diligence services offered by Talentprobe.

4. RELATIONSHIP WITH DATA PRIVACY RIGHTS

This Policy supplements the rights and procedures described in Talentprobe’s Data Privacy and Protection Policy.

Nothing in this Policy is intended to reduce or waive any right available to a data subject under applicable law.

Where a request concerns a statutory data privacy right, Talentprobe shall evaluate the request in accordance with applicable privacy law.

Where a request concerns the accuracy or interpretation of a screening result, Talentprobe shall also apply its Background Screening Quality and Accuracy Policy and relevant verification standards.

5. PRINCIPLES

Talentprobe shall administer candidate rights and disputes according to the following principles:

a. accessibility;

b. fairness;

c. objectivity;

d. confidentiality;

e. proportionality;

f. reasonable timeliness;

g. accuracy;

h. accountability;

i. evidence-based review;

j. non-retaliation for good-faith requests; and

k. appropriate transparency.

PART II

CANDIDATE AND DATA SUBJECT RIGHTS

6. RIGHT TO BE INFORMED

Candidates and data subjects have the right to receive appropriate information concerning the processing of their personal data as required by applicable law.

Relevant information may include:

a. categories of personal data processed;

b. purposes of processing;

c. lawful basis for processing where applicable;

d. scope and method of processing;

e. recipients or categories of recipients;

f. applicable retention information;

g. identity and contact information of the relevant Personal Information Controller or representative;

h. existence of applicable data subject rights; and

i. other information required by applicable law.

7. RIGHT TO ACCESS

Subject to applicable law and legitimate limitations, a data subject may request reasonable access to personal data concerning the data subject that is processed by Talentprobe.

A valid access request may include information concerning:

a. personal data processed;

b. categories of personal data;

c. sources from which information was obtained, where applicable;

d. purposes of processing;

e. manner of processing;

f. recipients or categories of recipients;

g. reasons for disclosure where applicable;

h. relevant retention information;

i. applicable information concerning automated processing; and

j. other information to which the data subject is lawfully entitled.

8. LIMITATIONS ON ACCESS

The right of access does not necessarily require Talentprobe to disclose information concerning another individual, confidential third-party information, legally privileged material, proprietary methodologies, confidential security information, or information otherwise restricted by applicable law.

Where only part of a record is restricted, Talentprobe may consider whether appropriate access can be provided through redaction, extraction, summary, or another lawful means.

9. RIGHT TO RECTIFICATION

A candidate or data subject may dispute inaccurate or erroneous personal data and request appropriate correction.

Where Talentprobe determines that personal information is materially inaccurate, incomplete, outdated, misattributed, or otherwise requires correction, Talentprobe shall take reasonable measures to correct the information in accordance with applicable law and this Policy.

10. RIGHT TO OBJECT

Where applicable under law, a data subject may object to processing of personal data.

Talentprobe shall evaluate an objection according to:

a. the applicable lawful basis;

b. purpose of processing;

c. contractual requirements;

d. legal obligations;

e. rights and interests of the data subject;

f. rights and interests of other persons; and

g. other applicable legal considerations.

An objection does not automatically require Talentprobe to cease processing where another lawful basis authorizes or requires continued processing.

11. RIGHT TO ERASURE OR BLOCKING

A data subject may request the suspension, blocking, removal, deletion, destruction, or other appropriate restriction of personal data where provided by applicable law.

Talentprobe shall evaluate such requests according to the circumstances and applicable legal requirements. A request may be granted wholly or partially where appropriate.

12. LIMITATIONS ON ERASURE

Talentprobe may retain information where continued processing or preservation remains lawfully necessary, including for:

a. fulfillment of an authorized purpose;

b. compliance with a legal obligation;

c. establishment, exercise, or defense of legal claims;

d. legitimate business purposes consistent with applicable law;

e. security;

f. fraud prevention;

g. active disputes;

h. regulatory requirements;

i. legal holds; or

j. another lawful basis.

13. RIGHT TO DATA PORTABILITY

Where applicable, a data subject may request personal data in an electronic or structured format that permits further use or transfer, subject to the requirements and limitations of applicable law.

14. RIGHT TO FILE A COMPLAINT

A candidate or data subject who believes that personal data has been processed improperly or that applicable data privacy rights have been violated may raise the matter directly with Talentprobe.

Nothing in this Policy prevents a data subject from exercising the right to lodge a complaint with the National Privacy Commission or another competent authority where legally available.

15. RIGHT TO DAMAGES

Nothing in this Policy limits any right to seek damages or other relief provided by applicable law.

16. AUTHORIZED REPRESENTATIVES

A data subject may authorize another person to exercise applicable rights on the data subject’s behalf, subject to appropriate verification of identity and authority.

Talentprobe may request documentation reasonably necessary to establish:

a. identity of the data subject;

b. identity of the representative; and

c. authority of the representative.

17. LAWFUL HEIRS AND ASSIGNS

Rights that are transmissible under applicable law may be exercised by lawful heirs or assigns where the required legal conditions are satisfied.

PART III

SCREENING RESULT DISPUTES

18. RIGHT TO DISPUTE A SCREENING FINDING

A candidate may raise a good-faith dispute concerning a Talentprobe screening finding that the candidate reasonably believes is:

a. inaccurate;

b. incomplete;

c. outdated;

d. misattributed;

e. based on mistaken identity;

f. incorrectly classified;

g. unsupported by the identified source;

h. materially misleading because relevant context is missing; or

i. otherwise inconsistent with the information that should reasonably have been reported.

19. DISPUTE VERSUS DISAGREEMENT

A screening dispute concerns the accuracy, completeness, attribution, verification, classification, or presentation of information contained in a Talentprobe report.

A disagreement with a client’s employment decision is not necessarily a dispute with Talentprobe.

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

Where the candidate disagrees solely with the client’s decision and does not identify a potential problem with Talentprobe’s information or processing, the matter may need to be addressed directly with the client.

20. EXAMPLES OF DISPUTABLE MATTERS

A candidate may dispute matters including:

a. incorrect employment dates;

b. incorrect position or job title;

c. incorrect educational information;

d. incorrect credential status;

e. incorrect identity match;

f. court information attributed to the wrong individual;

g. inaccurate status of a legal proceeding;

h. inaccurate reference information;

i. information belonging to another person with a similar name;

j. incorrect risk classification;

k. failure to reflect a material correction received from a source;

l. inaccurate transcription;

m. information reported outside the authorized screening scope; or

n. another material factual concern.

21. MATTERS THAT MAY REQUIRE CLARIFICATION RATHER THAN CORRECTION

Some concerns may involve a difference in interpretation rather than an objective error.

Examples may include:

a. differing job title terminology;

b. employer-specific position descriptions;

c. differences in academic terminology;

d. reference opinions;

e. differences between candidate recollection and official records;

f. information whose status changed after the screening date; or

g. information accurately reported from an authoritative source but disputed by the candidate at source level.

Talentprobe shall determine whether the appropriate response is correction, clarification, qualification, re-verification, or confirmation of the original finding.

PART IV

SUBMITTING A REQUEST OR DISPUTE

22. ACCESSIBLE REQUEST PROCESS

Talentprobe shall seek to make the submission of candidate requests and disputes reasonably clear, simple, straightforward, and convenient.

Use of a prescribed form may assist processing but shall not automatically be required where a request otherwise contains sufficient information for Talentprobe to identify and evaluate the matter.

23. CHANNELS

Candidate rights requests, disputes, privacy concerns, and related matters may be submitted through designated Talentprobe channels, which may include:

a. candidate support channels;

b. authorized online forms;

c. account support channels;

d. Data Privacy, Protection, and Security Office; or

e. other channels communicated by Talentprobe.

24. INFORMATION TO BE PROVIDED

Talentprobe may request information reasonably necessary to evaluate a request or dispute, including:

a. candidate’s full name;

b. relevant case or report reference;

c. contact information;

d. nature of the request;

e. specific information disputed;

f. explanation of the alleged error;

g. requested correction or resolution;

h. supporting documents;

i. information necessary to distinguish the candidate from another individual; and

j. other information reasonably necessary for investigation.

25. NO UNNECESSARY FORMALITY

Talentprobe shall not reject an otherwise understandable request solely because the candidate did not use a particular legal term, policy title, or prescribed wording.

The substance of the request shall determine how it is handled.

26. IDENTITY VERIFICATION

Before disclosing, correcting, deleting, blocking, or otherwise acting upon personal information, Talentprobe may take reasonable measures to verify the identity of the requesting individual.

Verification shall be proportionate to the sensitivity of the information and risk associated with the request.

27. ADDITIONAL INFORMATION

Where a request is materially incomplete, Talentprobe may request additional information reasonably necessary to proceed.

The candidate shall not be required to provide information unrelated to the request merely as a condition of exercising a legitimate right.

28. SUPPORTING DOCUMENTS

A candidate may provide documents or other evidence supporting a dispute.

Such documents may include:

a. certificates of employment;

b. payslips;

c. employment contracts;

d. diplomas;

e. transcripts;

f. professional licenses;

g. government-issued records;

h. court documents;

i. clearance documents;

j. identification documents;

k. official correspondence;

l. affidavits where appropriate; or

m. other relevant evidence.

Candidate-provided evidence shall be evaluated according to its relevance, reliability, authenticity, and relationship to the disputed finding.

PART V

INITIAL REVIEW AND ACKNOWLEDGMENT

29. INITIAL ASSESSMENT

Upon receipt, Talentprobe shall determine the nature of the matter and route it appropriately.

A request may be categorized as:

a. access request;

b. correction request;

c. erasure or blocking request;

d. objection;

e. portability request;

f. screening dispute;

g. classification dispute;

h. privacy complaint;

i. security concern;

j. client employment decision concern; or

k. another request.

30. ACKNOWLEDGMENT

Talentprobe shall seek to acknowledge requests within a reasonable period.

Acknowledgment may include:

a. confirmation of receipt;

b. request reference number;

c. additional information required;

d. expected next steps;

e. appropriate contact channel; and

f. other information reasonably useful to the requester.

31. PRIORITY

Requests may be prioritized based on factors including:

a. potential harm to the candidate;

b. pending employment decision;

c. severity of the alleged error;

d. mistaken identity;

e. potentially adverse information;

f. security concerns;

g. regulatory requirements;

h. client urgency; and

i. complexity.

Priority treatment does not guarantee a particular outcome.

PART VI

REINVESTIGATION AND RE-VERIFICATION

32. REINVESTIGATION

Where a credible dispute concerns a material screening finding, Talentprobe shall conduct an appropriate review or reinvestigation.

33. SCOPE OF REINVESTIGATION

Reinvestigation may include:

a. review of original source information;

b. review of verification evidence;

c. review of candidate identifiers;

d. recontacting an employer;

e. recontacting an educational institution;

f. reviewing official records;

g. checking court or public records;

h. contacting a credentialing authority;

i. reviewing correspondence;

j. reviewing system logs;

k. obtaining additional information from the candidate;

l. obtaining additional information from the client where appropriate;

m. independent re-verification; or

n. another reasonable investigative measure.

34. INDEPENDENT REVIEW

Where appropriate, a disputed material finding may be reviewed by personnel other than the individual who performed the original verification.

This may be particularly appropriate where the dispute concerns:

a. mistaken identity;

b. potentially adverse court information;

c. material discrepancy;

d. significant classification;

e. alleged analyst error; or

f. another matter where independent review would strengthen objectivity.

35. SOURCE RECONTACT

Where the dispute concerns information obtained from a third-party source, Talentprobe may recontact the source to confirm, clarify, or correct the information.

36. AUTHORITATIVE RECORDS

Where an authoritative source confirms information that differs from candidate-provided information, Talentprobe shall consider the reliability and status of the authoritative record.

A candidate’s disagreement with an official record does not automatically authorize Talentprobe to alter the official record.

Where correction must first be made by the issuing institution, court, government agency, employer, or other record custodian, Talentprobe may advise the candidate accordingly.

37. CHANGED INFORMATION

Information that became inaccurate only because circumstances changed after the original screening shall not necessarily constitute an error in the original report.

Where appropriate, Talentprobe may update the report to reflect subsequent information while preserving the historical accuracy of the original screening date.

38. UNAVAILABLE SOURCES

Where a source is no longer available or cannot reasonably be contacted, Talentprobe shall evaluate the dispute using other available evidence.

The inability to reconfirm information shall not automatically result in either confirmation or removal of the disputed finding.

PART VII

TREATMENT OF DISPUTED FINDINGS

39. DISPUTE STATUS

Where appropriate, Talentprobe may identify a material finding as disputed or under review while reinvestigation is pending.

40. CLIENT NOTIFICATION DURING REVIEW

Where a credible dispute concerns a material finding already delivered to a client and continued reliance on the finding could materially affect the candidate, Talentprobe may notify the relevant authorized client that the finding is under review.

Such notification does not imply that the finding has been determined to be incorrect.

41. NO PRESUMPTION AGAINST CANDIDATE

A candidate shall not be presumed dishonest merely because information supplied by the candidate differs from information obtained from another source.

Differences shall be evaluated according to context and available evidence.

42. NO PRESUMPTION AGAINST ORIGINAL FINDING

A finding shall not automatically be removed solely because a candidate disputes it.

Talentprobe shall evaluate the matter objectively.

43. PENDING MATTERS

Where information concerns a pending legal, regulatory, administrative, disciplinary, or similar matter, Talentprobe shall seek to report the actual status supported by available evidence.

A pending matter shall not knowingly be represented as a final determination where no final determination exists.

44. ALLEGATIONS AND CONVICTIONS

Talentprobe shall distinguish allegations, complaints, charges, pending cases, findings, judgments, and convictions according to the information available from appropriate sources.

An allegation or pending case shall not knowingly be characterized as a conviction unless supported by the relevant record.

45. INCONCLUSIVE DISPUTES

Where available evidence does not permit Talentprobe to conclusively resolve a dispute, the report may be appropriately qualified.

Possible outcomes may include:

a. unable to verify;

b. inconclusive;

c. disputed by candidate;

d. source unavailable;

e. further verification required; or

f. another status accurately reflecting the evidence.

PART VIII

RESOLUTION OF DISPUTES

46. POSSIBLE OUTCOMES

Following review, Talentprobe may determine that:

a. the original finding is accurate;

b. the original finding is materially inaccurate;

c. the finding is partially accurate but requires clarification;

d. the finding is outdated;

e. the finding relates to another person;

f. the finding requires reclassification;

g. the available evidence is inconclusive;

h. the underlying source has corrected its information;

i. the report requires additional context; or

j. another appropriate resolution applies.

47. SUBSTANTIATED ERROR

Where Talentprobe determines that it made a material error, appropriate corrective action shall be taken.

Corrective action may include:

a. correcting the personal information;

b. correcting the finding;

c. changing the classification;

d. removing an incorrectly attributed record;

e. adding necessary context;

f. issuing an amended report;

g. notifying the relevant client;

h. updating applicable internal records; and

i. reviewing the cause of the error.

48. PARTIALLY SUBSTANTIATED DISPUTE

Where part of a candidate’s dispute is substantiated, Talentprobe shall correct or clarify the affected portion without necessarily altering information that remains supported by reliable evidence.

49. UNSUBSTANTIATED DISPUTE

Where reinvestigation reasonably confirms the original finding, Talentprobe may retain the finding.

Where appropriate, Talentprobe shall communicate that the disputed information was reviewed and confirmed based on the available evidence.

50. CANDIDATE EXPLANATION

Where a factual finding remains accurate but the candidate provides material context, Talentprobe may, where appropriate and relevant to the screening service, include or otherwise communicate the candidate’s explanation.

Candidate explanations shall be identified as such and shall not automatically replace independently verified information.

PART IX

REPORT CORRECTION AND AMENDMENT

51. CORRECTED REPORT

Where a material correction affects a screening report, Talentprobe shall issue an amended or corrected report where appropriate.

52. VERSION CONTROL

Corrected reports should be identifiable as the current version.

Talentprobe shall maintain reasonable controls intended to reduce the risk that a superseded report is inadvertently treated as the current report.

53. MATERIAL CORRECTIONS

Where a correction materially affects information previously delivered to an authorized client, Talentprobe shall take reasonable measures to communicate the correction to the relevant recipient.

54. PREVIOUS RECIPIENTS

Where required by applicable law or appropriate under the circumstances, Talentprobe may inform recipients that previously received inaccurate personal information of the correction or rectification.

55. RETRACTED INFORMATION

Where applicable, Talentprobe shall maintain appropriate records of corrected and retracted information to support auditability, dispute management, and compliance.

Retention of a superseded record does not authorize continued reliance on information known to have been corrected.

56. CORRECTION AT SOURCE

Where the disputed information originates from an official or authoritative third-party record and Talentprobe cannot lawfully alter that source, Talentprobe may require or encourage the candidate to seek correction directly from the relevant source.

Once appropriate evidence of source correction is available, Talentprobe may update the screening result accordingly.

PART X

RISK CLASSIFICATION DISPUTES

57. CLASSIFICATION REVIEW

A candidate may raise a concern regarding a Talentprobe risk classification where the candidate believes the classification is based upon:

a. inaccurate information;

b. mistaken identity;

c. incorrect application of classification criteria;

d. outdated information;

e. a subsequently corrected source record; or

f. another material error.

58. CLASSIFICATION IS NOT A HIRING DECISION

Talentprobe risk classifications summarize screening findings according to applicable criteria.

They do not constitute an automatic hiring, rejection, retention, promotion, termination, or engagement recommendation.

The client remains responsible for its employment or business decision.

59. CLASSIFICATION CORRECTION

Where the underlying information or application of classification criteria is determined to be materially incorrect, Talentprobe shall correct the classification where appropriate.

60. DISAGREEMENT WITH CLIENT STANDARD

Where a candidate’s concern relates solely to the client’s own employment standard, eligibility requirement, risk appetite, or decision-making criteria, Talentprobe may refer the candidate to the client.

Talentprobe shall not alter an accurate screening finding solely because the client applies a standard with which the candidate disagrees.

PART XI

APPEAL AND ESCALATION

61. REQUEST FOR RECONSIDERATION

Where a candidate reasonably believes that a dispute was not adequately resolved, the candidate may request reconsideration or escalation.

62. GROUNDS FOR ESCALATION

Appropriate grounds may include:

a. new material evidence;

b. evidence that relevant information was overlooked;

c. procedural irregularity;

d. potential conflict of interest;

e. incorrect application of verification standards;

f. unresolved mistaken identity concern;

g. incorrect classification; or

h. another material basis for reconsideration.

63. ESCALATED REVIEW

An escalated matter may be reviewed by an appropriate senior, compliance, quality, privacy, risk, or management representative who was not primarily responsible for the original determination, where reasonably practicable.

64. DUPLICATIVE REQUESTS

Talentprobe may decline to repeatedly reinvestigate substantially identical matters where:

a. the issue has already been reasonably investigated;

b. no new material information has been provided;

c. the request is manifestly unfounded, vexatious, or otherwise unreasonable; and

d. further review is not required by applicable law.

Such decisions shall not be used to prevent legitimate requests supported by new evidence.

65. FINAL INTERNAL DETERMINATION

Following appropriate review or escalation, Talentprobe may communicate its final internal determination concerning the disputed screening information.

A final internal determination does not restrict any right the candidate may have to pursue remedies before a competent authority.

PART XII

PRIVACY COMPLAINTS

66. PRIVACY CONCERNS

Candidates may raise concerns regarding matters including:

a. unauthorized collection;

b. unauthorized use;

c. unauthorized disclosure;

d. excessive collection;

e. inaccurate personal data;

f. unauthorized retention;

g. failure to appropriately secure information;

h. improper disposal;

i. failure to address a data subject request;

j. processing outside the authorized purpose; or

k. another alleged violation of applicable privacy requirements.

67. INTERNAL COMPLAINT HANDLING

Talentprobe shall provide a mechanism for privacy concerns to be received, documented, reviewed, and appropriately addressed.

Privacy complaints may be referred to the Data Privacy, Protection, and Security Office or Data Protection Officer.

68. INVESTIGATION

A privacy complaint may require review of:

a. processing records;

b. system activity;

c. communications;

d. consent or authorization records;

e. client instructions;

f. disclosure records;

g. access logs;

h. retention records;

i. relevant policies; and

j. other information necessary to evaluate the complaint.

69. NATIONAL PRIVACY COMMISSION

Nothing in Talentprobe’s internal dispute process is intended to prevent a data subject from exercising the right to file a complaint with the National Privacy Commission in accordance with applicable law and the Commission’s rules.

70. COOPERATION WITH AUTHORITIES

Talentprobe and Circa Logica Group shall cooperate appropriately with lawful inquiries, investigations, orders, or proceedings of competent regulatory authorities.

PART XIII

PROCESSING TIMES AND COMMUNICATION

71. REASONABLE TIMELINESS

Talentprobe shall seek to address candidate requests and disputes within a reasonable period appropriate to the nature and complexity of the matter.

72. FACTORS AFFECTING COMPLETION

Resolution time may depend upon:

a. complexity of the dispute;

b. responsiveness of third-party sources;

c. availability of historical records;

d. government or court processing;

e. need for additional candidate information;

f. foreign jurisdiction involvement;

g. volume of information;

h. identity verification requirements;

i. legal requirements; and

j. other circumstances beyond Talentprobe’s reasonable control.

73. DELAYS

Where a material delay occurs, Talentprobe may provide an appropriate status update and request additional time where reasonably necessary.

74. NO ARTIFICIAL DEADLINE FOR SOURCE RESPONSES

Talentprobe shall not knowingly sacrifice verification accuracy merely to meet an internal resolution target where additional time is reasonably required to obtain reliable information.

75. LEGAL DEADLINES

Where applicable law imposes a specific mandatory period for responding to a particular request, the applicable legal requirement shall prevail over ordinary internal service targets.

PART XIV

CLIENT RESPONSIBILITIES DURING DISPUTES

76. CLIENT COOPERATION

Clients may be requested to cooperate with Talentprobe where their information, instructions, records, or decisions are relevant to resolving a candidate request or dispute.

77. EMPLOYMENT DECISIONS

Talentprobe does not control whether a client pauses, continues, reverses, or completes an employment decision while a dispute is pending, except where a contractual arrangement provides otherwise.

Clients remain responsible for complying with applicable employment, privacy, anti-discrimination, due process, and other legal requirements relevant to their decisions.

78. RELIANCE ON DISPUTED INFORMATION

Where Talentprobe informs a client that a material finding is under active review, the client should take that status into account when determining whether and how to rely upon the disputed information.

79. CLIENT-SUPPLIED INFORMATION

Where disputed information was supplied by the client rather than independently generated by Talentprobe, Talentprobe may coordinate with the client to determine the appropriate response.

80. CLIENT RECORDS

Talentprobe cannot directly correct information independently controlled by a client unless Talentprobe is authorized and technically able to do so.

Where Talentprobe corrects information within its own systems, the client remains responsible for correcting copies or records independently maintained by the client where applicable.

PART XV

SPECIAL CATEGORIES OF DISPUTES

81. MISTAKEN IDENTITY

Potential mistaken identity shall be treated as a significant quality concern.

Talentprobe may review additional identifiers to determine whether a record belongs to the candidate.

A name match alone shall not automatically be treated as sufficient evidence that an adverse record belongs to the candidate.

82. COURT AND CRIMINAL RECORDS

Where a candidate disputes court or criminal record-related information, Talentprobe shall review the available record and relevant identifiers.

Talentprobe shall seek to distinguish appropriately among:

a. complaint;

b. allegation;

c. filing;

d. charge;

e. pending proceeding;

f. dismissed matter;

g. acquittal;

h. judgment;

i. conviction; and

j. other legally distinct statuses.

83. NBI AND OTHER CLEARANCES

Different screening sources may have different coverage, methodologies, identifiers, databases, and legal functions.

A result obtained through court record searches does not constitute an NBI clearance unless NBI verification was specifically included in the authorized screening scope.

Similarly, an NBI result does not necessarily replace another screening source where a different verification was requested.

84. EMPLOYMENT RECORDS

Where employment information is disputed, Talentprobe may consider records from:

a. employer human resources;

b. authorized employer representatives;

c. payroll or employment records where lawfully available;

d. certificates of employment;

e. candidate-provided documentation; and

f. other reliable evidence.

85. EDUCATION RECORDS

Where education information is disputed, Talentprobe may seek confirmation from the issuing institution or another authorized record custodian.

Differences in naming conventions, historical institution names, degree terminology, dates, or campus descriptions shall be evaluated before being treated as material discrepancies.

86. REFERENCE INFORMATION

References may contain opinions, observations, recollections, or subjective assessments.

A candidate’s disagreement with a reference’s opinion does not necessarily establish factual inaccuracy by Talentprobe.

Talentprobe shall, however, investigate allegations that reference information was fabricated, misattributed, materially mistranscribed, or obtained from an unauthorized person.

87. PUBLICLY AVAILABLE INFORMATION

Where a dispute concerns publicly available information, Talentprobe shall consider:

a. reliability of the source;

b. identity match;

c. currency;

d. relevance;

e. context;

f. subsequent correction or deletion at source; and

g. applicable legal requirements.

PART XVI

AUTOMATION, AI, AND TECHNOLOGY-ASSISTED PROCESSING

88. TECHNOLOGY-ASSISTED PROCESSING

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

89. RIGHT TO QUESTION MATERIAL OUTPUTS

A candidate may raise a concern where the candidate reasonably believes a technology-assisted process contributed to:

a. mistaken identity;

b. inaccurate data extraction;

c. incorrect classification;

d. duplicate information;

e. inappropriate matching; or

f. another material error.

90. HUMAN REVIEW

Where appropriate, a material disputed finding generated or materially assisted by technology may be subjected to human review.

Technology-assisted output shall not be considered inherently correct solely because it was generated automatically.

91. AUTOMATED DECISION-MAKING

Talentprobe does not ordinarily make the client’s final employment decision.

Where automated processing is used in a manner subject to specific transparency or data subject rights requirements, Talentprobe shall address applicable obligations according to its role in the processing activity.

PART XVII

FAIRNESS AND NON-RETALIATION

92. GOOD-FAITH EXERCISE OF RIGHTS

Talentprobe shall not knowingly disadvantage a candidate merely because the candidate:

a. requests access;

b. requests correction;

c. raises a dispute;

d. objects to processing where legally permitted;

e. requests erasure or blocking;

f. raises a privacy concern;

g. requests reconsideration; or

h. files a legitimate complaint.

93. ABUSIVE OR FRAUDULENT REQUESTS

This protection does not require Talentprobe to facilitate fraud, impersonation, harassment, unauthorized access, deliberate obstruction, or misuse of the dispute process.

Talentprobe may take appropriate measures where a request is fraudulent, manifestly unfounded, vexatious, repetitive without new basis, or otherwise abusive, subject to applicable law.

94. NO CHARGE FOR ORDINARY GOOD-FAITH DISPUTES

Talentprobe shall not ordinarily charge a candidate merely for submitting a legitimate dispute concerning the accuracy of a Talentprobe screening report.

This does not prevent lawful charges where expressly permitted by applicable law for a separate service or extraordinary request.

PART XVIII

CONFIDENTIALITY AND SECURITY

95. CONFIDENTIALITY

Candidate requests, disputes, supporting documents, investigations, and resolutions shall be treated as confidential information.

96. ACCESS RESTRICTION

Access to dispute information shall be limited to persons reasonably requiring access for:

a. investigation;

b. verification;

c. quality review;

d. privacy compliance;

e. legal review;

f. client coordination;

g. management oversight; or

h. another authorized purpose.

97. SECURE COMMUNICATION

Talentprobe shall use reasonable measures to protect sensitive information exchanged during a dispute or data subject request.

Candidates should avoid sending unnecessary sensitive personal information through unsecured channels.

98. SECURITY INCIDENTS

Where a dispute reveals a potential security incident or personal data breach, the matter shall be escalated under the Information Security and Data Breach Management Policy.

PART XIX

RECORDKEEPING

99. DISPUTE REGISTER

Talentprobe shall maintain appropriate records concerning material candidate disputes and their disposition.

100. REQUEST RECORDS

Records may include:

a. date received;

b. nature of request;

c. identity verification;

d. disputed information;

e. supporting evidence;

f. investigative actions;

g. sources consulted;

h. findings;

i. resolution;

j. corrections;

k. notifications;

l. escalation; and

m. closure.

101. RETENTION

Candidate request and dispute records shall be retained according to the Data Retention and Secure Disposal Policy and applicable legal, contractual, evidentiary, and regulatory requirements.

102. AUDITABILITY

Talentprobe shall maintain sufficient documentation to reasonably demonstrate how material disputes were investigated and resolved.

PART XX

QUALITY IMPROVEMENT

103. DISPUTES AS QUALITY INFORMATION

Candidate disputes provide information that may assist Talentprobe in identifying:

a. recurring verification errors;

b. problematic sources;

c. identity-matching issues;

d. training needs;

e. system issues;

f. unclear reporting terminology;

g. classification inconsistencies;

h. vendor performance issues; and

i. opportunities for improvement.

104. ROOT CAUSE ANALYSIS

Material or recurring substantiated disputes may be subject to root cause analysis.

105. CORRECTIVE AND PREVENTIVE ACTION

Where appropriate, Talentprobe may implement:

a. procedure changes;

b. additional training;

c. source review;

d. enhanced quality controls;

e. system changes;

f. vendor corrective action;

g. classification changes;

h. updated guidance; or

i. other preventive measures.

106. QUALITY METRICS

Talentprobe may monitor indicators including:

a. dispute volumes;

b. dispute categories;

c. substantiated disputes;

d. corrections;

e. mistaken identity incidents;

f. source-related issues;

g. turnaround times;

h. repeat issues; and

i. other relevant quality measures.

PART XXI

RELATIONSHIP WITH OTHER POLICIES

107. DATA PRIVACY AND PROTECTION POLICY

Data subject rights and privacy complaints shall be administered consistently with Talentprobe’s Data Privacy and Protection Policy.

108. BACKGROUND SCREENING QUALITY AND ACCURACY POLICY

Screening-result disputes, re-verification, corrections, and quality reviews shall be administered consistently with the Background Screening Quality and Accuracy Policy.

109. INFORMATION SECURITY AND DATA BREACH MANAGEMENT POLICY

Security incidents identified through candidate requests or disputes shall be managed under the Information Security and Data Breach Management Policy.

110. DATA RETENTION AND SECURE DISPOSAL POLICY

Records created through candidate rights requests, disputes, corrections, and appeals shall be retained and disposed of in accordance with the Data Retention and Secure Disposal Policy.

111. DATA PROCESSING AGREEMENTS

Where Talentprobe acts as a Personal Information Processor on behalf of a client, certain data subject requests may require coordination with the relevant client acting as Personal Information Controller.

Talentprobe shall provide reasonable assistance according to applicable law and contractual obligations.

PART XXII

ROLE OF TALENTPROBE AND CLIENT

112. TALENTPROBE AS PERSONAL INFORMATION CONTROLLER

Where Talentprobe determines the purposes and means of particular personal data processing and acts as a Personal Information Controller, Talentprobe shall address applicable data subject rights within its responsibility.

113. TALENTPROBE AS PERSONAL INFORMATION PROCESSOR

Where Talentprobe processes personal information solely on behalf of a client acting as Personal Information Controller, Talentprobe may refer or coordinate applicable requests with the client and shall provide reasonable assistance consistent with the Data Processing Agreement and applicable law.

114. MIXED PROCESSING ROLES

Talentprobe may act as a Personal Information Processor for certain activities and as a Personal Information Controller for other activities.

The appropriate response to a request shall depend upon Talentprobe’s role concerning the specific processing activity involved.

115. CLIENT EMPLOYMENT DECISIONS

Talentprobe reports verified findings and applicable risk classifications but does not ordinarily make the final employment decision.

Clients remain responsible for determining how screening information is used in accordance with applicable employment law, company policy, anti-discrimination requirements, proportionality, and other legal obligations.

PART XXIII

EXTERNAL REMEDIES

116. RIGHT TO APPROACH REGULATORS

Nothing in this Policy removes or limits any right of a candidate or data subject to approach a competent regulatory, judicial, administrative, or other lawful authority.

117. NATIONAL PRIVACY COMMISSION

Data subjects who believe their rights under Philippine data privacy law have been violated may have the right to lodge a complaint with the National Privacy Commission in accordance with its applicable rules and procedures.

118. INTERNAL RESOLUTION

Talentprobe encourages candidates to bring concerns to Talentprobe so that the organization has an opportunity to investigate and address them promptly.

This provision does not waive or restrict any remedy available under applicable law.

PART XXIV

GOVERNANCE AND ACCOUNTABILITY

119. MANAGEMENT RESPONSIBILITY

Talentprobe management shall support appropriate processes and resources for the fair and timely handling of candidate rights and disputes.

120. DATA PRIVACY, PROTECTION, AND SECURITY OFFICE

The Data Privacy, Protection, and Security Office shall provide oversight concerning data subject rights and privacy complaints.

121. RISK, COMPLIANCE, AND QUALITY FUNCTIONS

Appropriate risk, compliance, operations, and quality personnel may support:

a. dispute review;

b. re-verification;

c. classification review;

d. quality analysis;

e. corrective action;

f. escalation; and

g. policy improvement.

122. INDEPENDENCE OF REVIEW

Personnel handling disputes shall seek to evaluate evidence objectively and shall not be instructed to preserve an original finding merely to avoid acknowledging an error.

Likewise, personnel shall not alter a supported finding merely to satisfy a candidate or client.

123. CONFLICTS OF INTEREST

A person with a material conflict of interest concerning a dispute should disclose the conflict and, where appropriate, the matter should be reassigned or subjected to additional review.

PART XXV

POLICY ADMINISTRATION

124. POLICY REVIEW

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

a. changes in applicable law;

b. National Privacy Commission requirements;

c. changes in Talentprobe services;

d. dispute trends;

e. quality findings;

f. technology changes;

g. audit findings;

h. client requirements;

i. regulatory developments; or

j. recognized background screening and privacy practices.

125. POLICY AVAILABILITY

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

a. published on Talentprobe’s official website;

b. provided to candidates;

c. provided to clients;

d. submitted during vendor accreditation;

e. provided during procurement or due diligence;

f. shared with auditors and compliance reviewers; and

g. otherwise provided to legitimate stakeholders.

Internal investigative methodologies, source arrangements, fraud controls, security information, proprietary classification criteria, and other confidential operational information may remain restricted.

126. INTERPRETATION

This Policy shall be interpreted consistently with applicable law and Talentprobe’s other governance policies.

Where applicable law provides a greater mandatory right or protection than this Policy, the applicable legal requirement shall prevail.

PART XXVI

CONTACT AND REQUEST CHANNELS

127. CANDIDATE RIGHTS AND PRIVACY CONTACT

Requests concerning privacy rights, personal data, or this Policy may be directed to:

Data Privacy, Protection, and Security Office
Talentprobe Due Diligence / Circa Logica Group

Email: privacy@circalogicagroup.com

Talentprobe may maintain separate candidate support or dispute channels for operational screening concerns.

128. INFORMATION TO INCLUDE

To facilitate appropriate handling, a requester should provide sufficient information to identify:

a. the individual concerned;

b. the relevant Talentprobe case or screening, where available;

c. the information or finding concerned;

d. the nature of the request or dispute;

e. the requested resolution; and

f. supporting information where relevant.

Talentprobe may request additional information reasonably necessary to verify identity or investigate the matter.

PART XXVII

TALENTPROBE CANDIDATE RIGHTS COMMITMENT

129. OUR COMMITMENT

Talentprobe recognizes that background screening involves real people, not merely records, databases, or case numbers.

A screening report may contribute to decisions that affect an individual’s employment and professional opportunities. That responsibility requires accuracy, fairness, transparency, and an effective means for individuals to raise legitimate concerns.

Talentprobe therefore commits to maintaining reasonable and appropriate mechanisms designed to:

inform candidates about the processing of their personal information;

respect applicable data subject rights;

provide reasonable access to personal data where required;

allow candidates to dispute inaccurate or misattributed information;

receive relevant supporting evidence and explanations;

investigate credible disputes objectively;

distinguish allegations, pending matters, and verified outcomes;

take particular care to prevent mistaken identity;

correct substantiated errors;

amend reports when material corrections are required;

communicate material corrections to appropriate recipients where required;

provide an appropriate escalation mechanism;

protect candidate information throughout the dispute process;

avoid retaliation for the good-faith exercise of legitimate rights;

learn from disputes and use them to strengthen screening quality; and

preserve the distinction between Talentprobe’s responsibility to report verified findings and the client’s responsibility to make the final employment decision.

A background screening process should not require a candidate to accept information that is demonstrably inaccurate simply because it has already been reported.

Equally, responsible dispute resolution requires that verified information should not be removed merely because it is unfavorable.

Talentprobe’s responsibility is to determine, as objectively and reasonably as possible, what the available evidence supports and to report that information accurately, fairly, and with appropriate context.