APPLICANT PRIVACY POLICY

INTRODUCTION

At SQUIRE Technologies, Inc. (“SQUIRE”), we are committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and protect the information you provide as part of our job application process.

APPLICABILITY

The Applicant Privacy Policy applies only to personal information that is provided by you or collected about you, either directly or by third parties, when you apply for a job with SQUIRE.  Use of personal information gathered during the course of use of SQUIRE’s products or services is governed by the SQUIRE Privacy Policy. 

POLICY

As part of our job application process, we collect only the information necessary to evaluate your qualifications and comply with legal and regulatory requirements. We are committed to handling your data with the utmost care, ensuring that your privacy is respected at every step. 

As an Affirmative Action Employer, SQUIRE maintains an Affirmative Action Plan to promote opportunities for underrepresented groups, including women, minorities, individuals with disabilities, and veterans.  Accordingly, during our job application process, applicants are provided the opportunity to disclose demographic data in support of our plan goals.  This information is not required, is completely voluntary and is not used as part of the evaluation process. 

Questions, concerns or requests for additional information about any of the information contained in this policy may be directed to [email protected].   

INFORMATION WE COLLECT

The information we collect will vary depending upon which step(s) of the recruitment process you participate in.  Information collected at each stage of the process is as follows:

1) Initial Application - during the initial application process, the following information is required in order for SQUIRE to consider your application and is provided by you:

• Contact information (full name, phone number, email address)
• Professional qualifications, relevant work experience, and educational history (e.g. resume, cover letter, CV, etc.) 

You may also provide the following voluntary information as part of your application:

• Preferred Pronouns
• Current location (i.e. City and/or State)
• Name of current employer
• Professional Website URL (i.e. LinkedIn, GitHub, etc.)
• Demographic Information:
• Race/Ethnicity
• Gender
• Veteran Status
• Disability Status

Occasionally, job-specific qualifying questions may be added to the application, or certain data fields will be required.  For example, if a job is required to be performed in a specific state, we may change the Current Location field to required.  We may also add questions to obtain additional information not included in our standard job application.  For example, if a job requires a specific professional license or certification, we will ask applicants to indicate whether they hold that license or certification.  In all cases, any additional information collected will be used solely to evaluate your qualifications and ensure compliance with legal requirements. 

2) Offer - once the decision has been made to extend an offer of employment, additional information is required and collected from you.  In order to prepare an offer of employment and proprietary information and inventions agreement (PIIA), the following information is required:

• Full legal name
• Full mailing address

3) Post-Offer  - upon acceptance of an offer of employment, SQUIRE will collect information required to conduct a background check and verify employment authorization as outlined in our Pre-Employment Screening Policy.  Required information collected is as follows:

• Previous Name(s) Used (if applicable)
• Social Security Number (SSN)
• Date of Birth (DOB)
• Previous employment history (last 7 years)
• Professional Reference contact information
• Other personal identifying information, such as a Passport Number or State Driver’s License Number or any other identifying information contained in documents that are used to verify your authorization to work in the United States.

HOW WE USE YOUR INFORMATION

The information we collect is used only as permitted by law and for the following purposes:

• To evaluate your qualifications for the job(s) to which you have applied
• If authorized by you, to contact you regarding other job opportunities you may be qualified for
• Contacting you regarding your job application and interview status
• Verifying the information provided, such as references or educational qualifications
• Complying with legal obligations, such as equal employment opportunity reporting
• Conducting a background check, where permitted by and in accordance with applicable law
• Complying with other legal obligations, including verifying that you are legally authorized to work in the United States
• Responding to a warrant, subpoena, or other valid legal process
• Resolving disputes and/or as a part of a legal defense, if necessary

DISCLOSURE OF YOUR INFORMATION

Your information will be stored securely and used only for purposes related to your application or as required by law.  Your data may be shared with third-party service providers who assist us with application processing and background checks. These providers are contractually obligated to keep your information confidential and use it solely for the purposes of our hiring process.  Disclosure of your information may occur as follows:

• Select Team Members: SQUIRE Employees who are directly involved in the recruitment process such as the Hiring Manager and members of the Interview committee will be given access only to the required components of the information provided in the Initial Application process.  For the avoidance of doubt, Demographic Information will never be shared with any employee outside of the People and/or Legal team members.  Within the People and/or Legal teams, Demographic information will be accessible only to those employees with a job-related need to access such information (i.e. EEO-1 reporting).
• Affiliates: Other entities within our corporate group, as necessary for global recruitment.
• Legal Authorities: Government bodies, regulators, or law enforcement if required by the law and to protect SQUIRE’s legal rights, enforce policies, or respond to claims.
• Approved Third Parties: As part of a business transaction, such as a merger or acquisition, or an approved service provider engaged by SQUIRE to perform services, such as background check vendors.

SQUIRE will never rent or sell your personal information to third parties.

DATA RETENTION

SQUIRE will retain your personal information for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws and regulations. Information may also be retained for future opportunities at SQUIRE unless requested to be removed.

YOUR RIGHTS

Depending on your location, you may have certain rights regarding your personal information, including the right to:

• Access your data
• Correct any inaccurate information
• Request the deletion of your data
• Object to or restrict certain types of data processing
• Data portability

SQUIRE may choose to retain some personal information to comply with legal and regulatory requirements and to resolve disputes, in which case, your personal information will not be used for any other purpose.  To exercise these rights or if you have questions regarding this Privacy Statement, please contact us at [email protected].

SECURITY OF YOUR INFORMATION

SQUIRE deploys the resources necessary to implement, operate, and sustain a robust

cyber security posture. Utilizing industry-proven technology and practices, SQUIRE

protects the confidentiality, integrity, and availability of corporate data and resources and maintains the necessary access controls to verify all third-party vendors have or meet SOC2 compliance.

CHANGES TO THIS PRIVACY POLICY

SQUIRE may update this Privacy Statement from time to time. Any changes will be posted on this page with the revised effective date. Applicants are encouraged to review the policy periodically.

APPENDIX

California

Residents of the State of California have rights under the California Consumer Privacy Act (“CCPA”).  You can learn more about the CCPA and your rights by clicking here to view the language in full. If you believe a business has violated the CCPA, you may file a complaint with the Office of the Attorney General.

Colorado

Residents of the State of Colorado have rights under the Colorado Privacy Act (“CPA”). You can learn more about the CPA and your rights by clicking here to view the language in full. If you believe a business has violated the CPS, you may file a complaint with the Office of the Attorney General.

Virginia

Residents of the State of Virginia have rights under the Virginia Consumer Data Privacy Act (“VCDPA”). You can learn more about the VCDPA and your rights by clicking here to view the language in full. If you believe a business has violated the VCDPA, you may file a complaint with the Office of the Attorney General.

Connecticut

Residents of the State of Connecticut have rights under the Connecticut Data Privacy Act (“CTDPA”). You can learn more about the CTDPA and your rights by clicking here to view the language in full. If you believe a business has violated the CTDPA, you may file a complaint with the Office of the Attorney General.

Utah

Residents of the State of Utah have rights under the Utah Consumer Privacy Act (“UCPA”). You can learn more about the UCPA and your rights by clicking here to view the language in full. If you believe a business has violated the UCPA, you may file a complaint with the Office of the Attorney General.

Nevada

Residents of the State of Nevada have rights under the Nevada Online Privacy Policy. You can learn more about the Nevada Online Privacy Policy and your rights by clicking here to view the language in full. If you believe a business has violated the Nevada Online Privacy Policy, you may file a complaint with the Office of the Attorney General.

**Last Updated: 1/16/25

Know Your rights

To view the most up to date poster, click here.

Pay Transparency Nondiscrimination

SQUIRE does not discriminate against employees or job applicants who inquire about, discuss, or disclose their compensation or that of others as outlined by the Pay Transparency Nondiscrimination Provision.

To view the most up to date poster, click here.

Pre employment Screening

INTRODUCTION

Making the right hiring decisions is key to keeping our workplace safe, productive, and welcoming for everyone. Our Pre-Employment Screening Policy helps us ensure we’re protecting our employees, customers, and the company as a whole—creating a strong foundation for trust and success.

ELIGIBILITY

This policy applies to all applicants of full-time and part-time employee positions, internships and contracts for contracted work, as well as all full-time and part-time employees, interns and contracted workers currently holding a position at SQUIRE, as applicable.  Temporary workers will be subject to their employer’s pre-employment screening processes which must meet the standards of this policy. 

POLICY

All offers of employment and contracted work with SQUIRE are contingent upon the individual's successful completion of a background check and the verification of the individual’s employment authorization.  The information obtained during the course of the pre-employment screening process will be used solely for the purpose of determining employment and/or work eligibility.  In the event an employee, intern or contractor starts prior to the Company completing its background check, the applicant’s continued employment, internship or contract continues to remain contingent upon successful completion and acceptance of the applicant’s results. SQUIRE will not discriminate against an applicant for employment as provided by applicable Federal or State laws. 

BACKGROUND CHECKS

Background checks are conducted for all individuals who are offered employment or contract work with SQUIRE.  The background check components will vary based on whether an individual is being offered employment or a contract role. 

Employment Background Checks

Background checks for employment purposes include:

• SSN Trace 
• Federal Criminal Search (Last 10 Years)
• National Criminal Search (Standard)
• State Criminal Search (Last 7 Years)
• County Criminal Search (Last 7 years)
• Sex Offender Search 
• Global Watchlist Search
• Employment Verification (Last 7 years of employment)

Contractor Background Checks

Background checks for contract work purposes will be conducted using the contractor’s name, dba name, legal name and address.  Searches conducted include:

• SSN Trace
• National Criminal Search (Standard)
• Sex Offender Search 
• Global Watchlist Search
• Specially Designated Nationals and Blocked Persons List 

All background checks may be conducted through a third party vendor.  Consent will be required prior to our vendor conducting the background check.  Refusal to authorize the background check may be the basis for denial of employment. In the event an applicant refuses to consent to a background check, or if the check is performed and results in finding(s) that may exclude an applicant from employment with SQUIRE, and the Company elects to take adverse employment action against them based in whole or in part on consumer report(s) consistent with applicable law, the Company will initiate the adverse action process.  This process allows applicants to receive a copy of the background report under the Fair Credit Consumer Reporting Act (FCRA) and dispute any information they believe inaccurate. 

EMPLOYMENT AUTHORIZATION

SQUIRE is a federal subcontractor and complies with the E-Verify Federal Acquisition Regulation (FAR) rule, which mandates the use of E-Verify for confirming the employment eligibility of all newly hired employees as well as existing employees assigned to federal contracts, in accordance with FAR requirements.  E-Verify is a web-based system operated by the U.S. Department of Homeland Security (DHS) in partnership with the Social Security Administration (SSA). It allows employers to verify the identity and employment eligibility of newly hired employees by electronically comparing information provided on the Form I-9 against federal databases. As a tool to ensure compliance with federal law, E-Verify helps prevent unauthorized employment in the United States.  All offers of hire and continued employment are conditioned on providing satisfactory evidence of identity and legal authority to work in the United States.

COMPLIANCE WITH REGULATIONS

SQUIRE complies with all E-Verify rules and regulations, including timely verification of employment eligibility and ensuring all employees are treated fairly during the E-Verify process, providing them the opportunity to contest tentative non-confirmations (TNCs) without fear of retaliation or discrimination.

Verification is initiated within three business days of an employee's start date for newly hired employees.  For existing employees working on federal contracts, verification is conducted as required upon their assignment to the contract.

VERIFICATION PROCESS

Applicants who have accepted an offer of employment must produce documentation that verifies their identity and legal authority to work. Each applicant must also attest to their legal authority to work and identity on an I-9 Form provided by the federal government. This verification form will be distributed by the Company and must be completed as soon as possible after an offer of employment is made.  The Company will initiate an E-Verify case for each new hire within the same timeframe. 

In no event can the form and proof of identity be completed and returned to the Company more than three (3) business days after an individual is hired.  In the event a fully completed I-9 form and supporting documentation is not received by the close of business on the third business day following the date of hire, the employee may be terminated. 

If an employee has provided right-to-work documentation that has an expiration date, updated documentation must be given to the Company before this expiration date.  Failure to do so may result in the employee being placed on an unpaid leave of absence pending updated documentation, or termination of employment if updated information is not received in a timely manner.

PROHIBITED PRACTICES

Pre-employment verification is strictly prohibited. E-Verify is used only after an offer of employment has been accepted.  Selective verification of certain individuals or groups is not permitted.

EMPLOYEE RIGHTS
Employees will be informed of their Right to Work during the verification process and provided with the opportunity to contest tentative non-confirmations (TNCs) if applicable.  Please refer to the Employee Rights and Responsibilities page of the US Government’s E-Verify site for full details on your rights and responsibilities, as well as instructions for reporting concerns or suspected violations. 

Please click here for the Right to Work notice in Spanish. 

RECORDKEEPING
The company maintains documentation of the E-Verify process in compliance with record retention guidelines.

NON-DISCRIMINATION

The company commits to upholding equal employment opportunity laws and does not use E-Verify to pre-screen applicants or discriminate based on race, national origin, or citizenship status.

Questions, Concerns, or Grievances

If you have any questions, concerns, or grievances related to this policy, please contact [email protected]. 

e-verify

To view the most up to date poster, click here.