Background Screening and Eligibility Policy

1. Who Is Screened

• All Concierges must complete identity verification and background screening before claiming their first task
• Posters are not required to complete background screening
• Concierges performing senior care tasks are subject to enhanced screening

2. Scope of Screening

2.1 Standard Screening

• Identity verification (SSN trace and government ID)
• National criminal records search, including county, state, and federal
• National and state sex offender registry
• Terrorist watch list screening

2.2 Enhanced Screening (Senior Care)

• Enhanced criminal background check
• Abuse, neglect, and exploitation registry checks
• Deeper look-back period where permitted by law

2.3 Motor Vehicle Records (Driving Tasks)

• License status and validity
• Major moving violations and DUI/reckless driving

3. Disqualifying Offenses

3.1 Automatic Disqualification

• Registered sex offender status
• Violent felonies within the applicable look-back period
• Terrorism-related offenses
• Active warrants
• Fraud or identity theft convictions
• Elder abuse, neglect, or financial exploitation convictions

3.2 Case-by-Case Review

The following are evaluated individually, considering:

• Nature and severity of the offense
• Time elapsed since the offense
• Evidence of rehabilitation
• Relevance to senior concierge activities
• Number and pattern of offenses

Items considered on a case-by-case basis include minor misdemeanors older than seven years, traffic violations, and certain non-violent offenses.

4. Eligibility Decisions

• Clear: No disqualifying records found; eligible to serve
• Consider: Records require individualized review before a decision
• Not Eligible: Disqualifying offense or failure to complete screening

Eligibility is determined by Citovelo based on Checkr's report and the criteria above. Citovelo applies fair-chance principles and evaluates the totality of circumstances where permitted by law.

5. Ongoing Monitoring

• Annual re-screening is required for active Concierges
• Continuous monitoring of criminal databases (U.S.) where available
• Immediate notification of new disqualifying offenses
• Random spot checks for compliance
• You must promptly notify Citovelo of any arrest or conviction that occurs after your initial screening

6. Adverse Action and Your Rights

If screening results may lead to ineligibility, you will receive:

1. A pre-adverse action notice with a copy of the report and a summary of your FCRA rights
2. A reasonable period to dispute the accuracy of the report directly with Checkr
3. A final adverse action notice if ineligibility is confirmed

You may dispute inaccurate information with Checkr at support@checkr.com and may provide additional context or documentation for Citovelo's review.

7. Data Privacy and Retention

• Screening data is encrypted and stored securely per FCRA guidelines
• Access is limited to authorized personnel with a legitimate need
• Results are retained per legal requirements and Citovelo's retention schedule
• Background information is never shared with other users

8. Limitations

9. Updates to This Policy

We may update screening procedures to enhance safety. Material changes will be communicated via email or in-app notice. Continued use after changes constitutes acceptance.