Background Check Policy



We are committed to recruiting candidates and promoting qualified employees while protecting our assets and the assets of our clients.

In order to fulfill this commitment, this Background Check Policy ("Policy") has been established to provide the parameters and guidelines to be applied by Incognia when conducting background check ("BCK") analysis of those applying for employment, promotion or transfer positions with Incognia (herein referred to as "Applicants"), and all practices and processes involving BCK shall be fully guided by the terms set forth herein.


The objectives of this Policy are:

  1. To implement parameters, limitations, assumptions and general guidelines for conducting BCK research within the scope of Incognia's business in order to comply with the provisions of applicable laws and regulations, both in Brazil and in the USA.

  2. Promote the use of best practices in conducting background checks and mitigate risks of abusive or discriminatory practices, reinforcing our commitment to ethics and respect in the recruitment and employee promotion processes.


This Policy applies to all Applicants subject to BCK and employees involved in the process of conducting and analyzing BCK.

Subcontractors or agents who participate in the recruitment process, as well as third parties, partners or contractors who refer their employees to perform work at Incognia or our clients, are also subject to the provisions contained in this Policy.


1. Who are the Applicants eligible to perform BCK?

  • Senior applicants: in general, seniors, specialists, supervisors, coordinators, managers, directors, vice-presidents, and c-levels;

  • Applicants from specific areas: applicants who, regardless of their position, work in areas that have access to confidential information, administrator access permissions to Incognia's systems, personal data stored in databases or strategic information about the company's technological and security structure, with the exception of interns, who are not submitted to the BCK process. The areas are described below:

    1. Product Engineering: Product management, Research, Data Analytics and Backend;

    2. Core Engineering: Security, SRE, Infra and Data Engineering;

    3. Support: Finance and People.

2. What information is included in the BCK?

In Brazil:

  1. Registration status (verification of CPF, identity, etc.),

  2. Professional reference;

  3. Educational history;

  4. Criminal history;

  5. Judicial lawsuits;

  6. Credit check, SPC and Serasa (for Finance only);

  7. Reputational media.

In the USA:

  1. Registration status (Government ID/SSN validation/Global ID check);

  2. Reference check;

  3. Confirmation of employment history;

  4. Education history;

  5. Criminal record and Sex Offender;

  6. Lawsuits (according to state laws);

  7. Watchlist check (BIS, OFAC e GSA);

  8. Credit and bankruptcy record (for Finance only);

  9. Reputational media.

The categories of information contained in BCK searches may vary, depending on legislation applicable to specific localities and cases. To obtain detailed information about the information contained in each BCK survey, Applicants can request access to the results by contacting People.

3. When is the BCK conducted?

For Applicants for job openings, the BCK will be conducted concurrently with the Cultural Fit phase (Brazil) or concurrently with the sending of the offer letter (USA), which will be conditioned to the result of the BCK. For Promotion or Area Transfer Applicants, BCK will be held prior to the final decision and announcement of the promotion/transfer (Brazil) or concurrently with the announcement of the promotion/transfer (USA).

In both cases the effectiveness of the promotion/transfer will be conditioned to the result of the BCK.

4. What is the time range covered by the BCK survey?

In general, the analyses cover the period of 7 (seven) years prior to the date of the survey. This period may be altered by specific legislation applicable to each case.

5. How long is the BCK valid for?

The BCK result is valid for 3 (three) years. Once this period has expired, a new analysis is automatically performed, in accordance with the Employment Agreement for Applicants from Brazil. The same process applies to the USA, with the difference being that the Applicants will be notified in advance to grant their consent to update the BCK, unless the consent granted at the time of the first search is still valid (evergreen agreement).

Applicants submitted to BCK who have not been hired or who have been terminated from Incognia more than six (6) months ago, must be submitted to a new BCK survey in cases of hiring or re-hiring.

6. How long are BCK results stored at Incognia?

The BCK results are stored for a period of 5 (five) years.

7. Who performs the BCK surveys?

BCK surveys are performed by third party companies hired by Incognia, namely Idwall and SPC (Brazil), and HireRight (USA), or any other similar companies to be hired by Incognia. In Brazil, academic background and professional reference analyses may be carried out directly by the People team.

8. Who has access to the results of the BCK surveys?

BCK surveys are treated in an extremely confidential manner. Only members of the Ethics Committee representing the People area have access to it and, in some cases, other members of the Ethics Committee can have access to the results for discussion and decision-making purposes.

In specific cases the Candidate's manager can also be involved for decision making.

9. What are the legal grounds for authorizing the processing of Candidate data for BCK purposes?

In the USA the BCK survey can only be conducted by collecting the Applicant's consent, while in Brazil the survey is conducted based on legitimate interests of Incognia.

10. What transparency measures are applied in BCK research?

In the case of hiring in Brazil, the Applicant will be notified about the BCK through the e-mail in which he/she is informed about his/her approval for the Cultural Fit stage. The e-mail will provide general information about the types of data to be processed, purposes, periods, and other to comply with the transparency of the process. If the Applicant is hired, the Employment Contract will also include provisions for periodic BCK, or in cases of promotion/transfer (when he/she becomes eligible).

In cases of hiring in the USA, the Applicant will be made aware of the BCK concomitantly with the receipt of the offer letter and must consent to it. He/she will also be informed about the BCK at the time of the periodic checks or when there is an eventual promotion/transfer.

In all cases (Brazil and USA) all Candidates have access to this Policy.

11. What rights do Applicants have?

As per local law, U.S. Applicants will receive a copy of the BCK results and may submit explanations to compare any negative results, request data correction and update data.

Applicants from Brazil can request access to the BCK results, as well as request data corrections and updates.

All rights under applicable local laws will be guaranteed by Incognia.

12. How will Incognia evaluate the BCK results?

Incognia will treat all Applicants fairly and lawfully, making hiring/promotion decisions based on the totality of each individual's qualifications, merits and results analysis. A criminal record does not automatically disqualify an Applicant from consideration for employment, promotion or internal transfer. However, a criminal record may be a relevant consideration depending on the nature of the conviction and the specific position for which the Applicant is being considered.

The analysis of the BCK's results will take into account the relationship between any adverse report and the duties to be performed by the Applicant, the date of the facts, the impact it may have on the company's reputation and on the Applicant's daily activities, as well as the criticality and risks that such a report may subject the company to.

Any decision by Incognia not to hire or not to promote the Applicant due to the BCK result must be deliberated by the Ethics Committee.

Whenever there are negative notes in the BCK, the person responsible at the People area must register in a specific document the justifications that supported the decision to hire or not hire the Applicant.

In the case of U.S. Applicants, Incognia must previously notify the Applicant through a Pre-Adverse Action Letter, so that he/she can present the justifications, according to the particularities required by the law of the state where the hiring is being done. If, even after the justifications, Incognia chooses not to hire the Applicant, then a final Adverse Action Letter must be sent.

13. What steps can be taken if an employee's periodic BCK check returns negative results?

If during the periodic BCK checks (every 3 years) any negative result related to the Candidate is identified, the same process described in the previous item must be followed and the Ethics Committee must deliberate on the options of reallocating the professional to another compatible position/activity, without changing salaries, or even deciding for his/her dismissal.

Responsibilities of Applicants

Applicants must not provide false, incomplete or misleading information in an application, clearance or authorization. All information provided must be accurate and complete and the individual must not omit relevant information necessary for Incognia to make a decision.

Those who knowingly provide false information or omit information relevant to the sound procedure of the BCK may be terminated from Incognia, if they are current employees, or will no longer be considered for the position, if they are Applicants for a new hire.

Final Provisions

No offer of employment, promotion or internal transfer is final or binding until all necessary screenings are completed and the People Team notifies the hiring manager that a final offer can be made.

All reviews will be conducted in compliance with applicable Brazilian and U.S. laws, as well as case law understandings and best practices.

This policy does not limit the company's right to hire, discipline or discharge any employee.

If you have any questions about this Policy, the BCK procedure, or to request rights, please contact the members of the Ethics Committee.