Background Check and Screening Policy

1. Scope; Relationship to Privacy Notice and FCRA Disclosure

1.1 Scope.

This Policy applies to identity verification and background screening conducted in connection with the Platform, including screening of Providers and other Users where Village Haven determines screening is reasonably necessary for safety, compliance, or platform integrity.

1.2 Relationship to FCRA / ICRAA Disclosure.

Where screening involves a "consumer report" or "investigative consumer report," Village Haven provides a standalone FCRA / ICRAA Notice: Background Check Disclosure, available at: Background Check Disclosure (FCRA / ICRAA Notice) and obtains authorization where required by law. That Disclosure governs legally required consumer reporting notices, dispute rights, and adverse action procedures.

In the event of conflict, applicable federal or state consumer reporting law controls.

2. Platform Role; Independent Contractor Structure

Village Haven operates solely as a technology marketplace platform.

Village Haven:

• A. Does not employ Providers;
• B. Does not supervise or control services performed by Providers;
• C. Does not guarantee conduct, safety, or service outcomes;
• D. Is not a staffing agency or placement firm.

Background screening is conducted solely for platform eligibility and safety purposes and not for employment purposes.

Service relationships are formed directly between Users.

3. Legal Framework

Background screening may involve "consumer reports" and/or "investigative consumer reports" as defined under:

• A. The federal Fair Credit Reporting Act (FCRA);
• B. The California Investigative Consumer Reporting Agencies Act (ICRAA);
• C. The California Consumer Credit Reporting Agencies Act (CCRAA);
• D. Other applicable state consumer reporting laws.

Where required by law, Village Haven will:

• A. Provide a clear and standalone disclosure;
• B. Obtain written authorization prior to procuring a consumer report;
• C. Provide pre-adverse and adverse action notices if applicable;
• D. Afford reasonable opportunity to dispute inaccuracies.

Village Haven does not prepare consumer reports and does not determine report accuracy.

4. Who May Be Subject to Screening

Screening may apply to:

4.1 Providers.

Individuals offering services on the Platform, particularly where services involve:

• A. In-home access;
• B. Caregiving for minors, elderly individuals, or persons with disabilities;
• C. Transportation services;
• D. Access to vulnerable populations.

4.2 Users Seeking Certain Features.

Users requesting access to enhanced trust features, badges, or specific service categories.

4.3 Risk-Based or Re-Screening Situations.

Screening may occur:

• A. Before onboarding;
• B. Periodically during participation where permitted;
• C. Upon account reactivation;
• D. Following safety complaints;
• E. When risk signals or compliance needs reasonably require review.

Village Haven does not guarantee continuous monitoring or real-time updates.

5. Categories of Screening

Subject to legal limitations and user authorization, screening may include:

• A. Identity verification;
• B. Criminal history records where legally reportable;
• C. Sex offender registry searches;
• D. Address history and alias verification;
• E. Motor vehicle records where relevant;
• F. Professional license verification where applicable;
• G. Public sanctions or watchlist screening;
• H. Education or credential verification where relevant.

Village Haven does not request sealed, expunged, or legally restricted records where prohibited by law.

6. Screening Evaluation and Platform Eligibility Decisions

Screening results are evaluated using a structured and proportional assessment framework that may consider:

• A. Nature and severity of reported conduct;
• B. Recency;
• C. Relevance to the service category;
• D. Evidence of rehabilitation;
• E. Legal restrictions on use of certain records;
• F. Applicable “fair chance” laws;
• G. Platform-specific safety considerations.

Village Haven does not apply automatic permanent exclusions without individualized review where required by law.

Eligibility decisions relate solely to platform participation and do not constitute employment determinations.

7. Adverse Action Process

If Village Haven intends to take action affecting platform eligibility based in whole or in part on a consumer report:

1. A pre-adverse action notice will be provided;
2. A copy of the report will be provided;
3. A Summary of Rights under the FCRA will be included;
4. A reasonable opportunity to dispute inaccuracies will be afforded.

Final action will occur only after legally required procedures are completed.

Disputes regarding report accuracy must be directed to the consumer reporting agency.

8. Data Handling and Retention

Background screening information is treated as sensitive personal information under our Privacy Notice. Such information:

• A. Is access-restricted;
• B. Is used solely for lawful eligibility, compliance, and safety purposes;
• C. Is not sold;
• D. Is not shared for cross-context behavioral advertising.

Retention is limited to what is reasonably necessary for compliance, fraud prevention, dispute resolution, audit, and legal defense, consistent with applicable law.

9. Limitations of Background Screening

Users acknowledge that background screening:

• A. May contain inaccuracies or delays;
• B. May omit conduct not reflected in public records;
• C. Is dependent on third-party data sources;
• D. Does not guarantee safety or suitability.

Completion of screening does not constitute endorsement, certification, or a guarantee of conduct.

Users remain responsible for independent judgment and safety precautions.

10. Multi-State Operation; Non-Waivable Rights

Village Haven operates across multiple jurisdictions. Nothing in this Policy limits rights that cannot be waived under applicable federal, state, or local law.

Where state law provides additional protections, those protections control.

11. Changes to This Policy

Village Haven may update this Policy from time to time to reflect changes in law, enforcement guidance, operational risk, or screening practices.

Material changes will be posted on the Platform and, where required, additional authorization or disclosure will be obtained.