Employment Screening Acceptable Use Policy

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Carousel does not decide who gets hired — you do. This Policy sets out how you may use Carousel's employment screening. It forms part of your agreement with us, together with our Terms & Conditions and Privacy Policy. Capitalised terms not defined here have the meaning given in the Terms. In this Policy, "you" means the employer account holder and anyone acting under that account; "Candidate" means a person you invite to complete a screening; and "Report" means the results of a screening and the documents behind them.

#1. Who this Policy applies to

• Your account and your people. It applies to you and to every teammate you invite, whatever their access level.
• Anyone acting for you. Recruiters, staffing agencies and other agents screening through your account are bound by it, and you remain responsible for them.
• Connected software. Any application you connect to your account and permit to read Reports is bound by it, and you remain responsible for what it does with Reports.
• Employment only. This Policy governs employment screening. Tenant screening is governed by the Tenant Screening Acceptable Use Policy.

#2. Permitted purpose

• A real role, a real candidate. You may screen only a person who is genuinely under consideration for a position with you or with a client for whom you are recruiting.
• One decision. You may use a Report only to assess that Candidate for that position. You may not reuse it for another position, another candidate, or any purpose other than hiring, without a fresh screening and fresh consent.
• Only what the role needs. You may select only the checks that are relevant to the position.
• No workarounds. You may not use Carousel to obtain information you could not lawfully obtain yourself.

#3. Candidate consent

• Consent comes first. No check runs until the Candidate consents in Carousel's own flow. You may not screen anyone who has not consented there.
• No pressure, no proxies. You may not complete the flow on a Candidate's behalf, ask them for their credentials, or treat a refusal to consent as a reason to penalise them beyond declining to proceed with the screening.
• Your own duties stand. The consent a Candidate gives Carousel does not replace any notice, consent or disclosure the law requires you to give them. You remain responsible for your own obligations as an employer.

#4. What you may not do

• Screen anyone who is not a Candidate for a real position with you.
• Screen a current employee under the employment product.
• Resell, publish or otherwise distribute Reports, or use them to build a database or product of your own.
• Use a Report, or any part of it, for credit, tenancy, insurance, marketing, or any purpose other than the hiring decision for which it was obtained.
• Attempt to re-identify, scrape, reverse engineer or interfere with the platform or its providers.
• Share your account access with anyone outside your organisation.

#5. Human rights and non-discrimination

5.1 General. You may not use a Report, in whole or in part, to make a hiring decision on a ground protected by applicable human rights legislation. Federal, provincial and territorial human rights statutes apply to you, not to Carousel, and it is your responsibility to know which apply to the position.

5.2 Criminal and penal records.

• Québec. You may not refuse to hire, or otherwise penalise, a Candidate for a penal or criminal conviction that has no connection with the employment, or for any conviction for which a pardon or record suspension has been granted. Where a conviction is disclosed, you must assess its actual connection to the duties of the position on the facts, rather than on assumption.
• Ontario. You may not make a decision affected by a Candidate's record of offences, as that term is defined in the Human Rights Code.
• British Columbia, Newfoundland and Labrador, Prince Edward Island, Yukon, Northwest Territories and Nunavut. Criminal conviction or record is a protected ground in employment in these jurisdictions, worded differently in each. You may not rely on a conviction unrelated to the employment.
• Everywhere. A record disclosed in a Report is not a decision. You must consider the nature and seriousness of the offence, how long ago it occurred, and its actual bearing on the duties of the position, and you must be able to explain that reasoning.

5.3 Credit information. You may select a credit check only for a position in which the Candidate would have financial responsibility or access to money or financial systems, and you may not treat credit information as a proxy for character or reliability.

5.4 Fair criteria. Apply the same criteria to every Candidate for the same position, decide on the basis of the position's actual requirements, and keep a record of the basis for your decision.

#6. Rules for particular checks

6.1 Identity verification. Identity verification is included in every screening. It confirms that the Candidate is who they say they are. It is not a character assessment and must not be used as one.

6.2 Credit checks. Credit checks are optional and are run with the Candidate's consent for an employment purpose, as a soft inquiry that does not affect the Candidate's credit score.

6.3 Police checks. Police checks are optional and are subject to section 5.2 and to any statutory process in the Candidate's province, including any right the Candidate has to review the result before it is released to you.

6.4 Québec penal searches and court files. Opening an underlying Québec court file is not available for employment Positions. The penal search itself remains subject to section 5.2.

#7. Decisions, accuracy and the Candidate's chance to respond

• The decision is yours. Carousel does not approve or reject Candidates, score them, or recommend outcomes. Nothing in a Report is a recommendation.
• Results can be wrong. Records can be mismatched, out of date or incomplete. You must not treat a Report as conclusive.
• Tell the Candidate before you decide against them. If something in a Report would count against a Candidate, you must tell them what it is and give them a fair opportunity to respond or correct it before you make your decision final.

#8. Handling and keeping Reports

• Need to know. Give access only to teammates involved in the hiring decision, and remove access when they no longer need it.
• No onward sharing. Do not send a Report outside your organisation except where the law requires it or the Candidate has separately agreed.
• Keeping and deleting. Keep Reports only as long as you need them for the hiring decision and any legal requirement that applies to you, and no longer.
• Connected software. If you connect software to your account, you are responsible for its security and for what it does with Reports.

#9. Candidates never pay

Employment screening on Carousel is paid for by the employer. You may not charge a Candidate, directly or indirectly, for a screening or any part of it, and you may not make payment a condition of being considered.

#10. Security of your account

• Keep your account details accurate, and keep your credentials confidential.
• Remove access promptly when a teammate leaves or changes role.
• Tell us without delay if you believe your account or any Report has been accessed without authorisation.

#11. Records, reviews and cooperation

We log screenings sent, Reports accessed, policy acceptances and connected-software access. We may review account activity to confirm compliance with this Policy, and may ask you for the position and the basis on which a screening was run.

#12. Enforcement

If you breach this Policy we may suspend screenings, cancel screenings in progress, restrict access to Reports, or terminate your account, in each case with notice where it is reasonable to give it. Serious or repeated breaches may be reported where the law requires.

#13. Changes to this Policy

We may update this Policy. The current version is posted at oncarousel.com/employment-acceptable-use-policy, and we will tell account holders of material changes. Each acceptance is recorded against the version then in force.

#14. Contact

on Carousel Inc., 5101 rue Buchan, Suite 210, Montréal, Québec H4P 1S4, Canada. Privacy Officer: Charles Papazian, privacy@oncarousel.com.