Carnival Cruise Line Guest Screening Policy re: Guests with Specified Felony Convictions
Carnival Cruise Line (“Carnival”) reserves the right to use consumer reports prepared by a third-party consumer reporting agency, to conduct a criminal background check for guests who have booked a Carnival cruise. This criminal background check will be done to safeguard Carnival guests and crewmembers. Given that cruise vessels are at sea, with many guests and crew in close contact for an extended period, Carnival has a legitimate business purpose for conducting these background checks.
The Fair Credit Reporting Act (“FCRA”) regulates both providers and users of consumer reports. A member of Carnival’s Security Services Department or a member of Carnival management may arrange for the services of a consumer reporting agency to conduct a criminal background check for persons convicted of felonies involving aggravated physical and/or sexual assault, armed robbery and related offenses, and other violent crimes. Carnival may deny boarding to guests with these felonies on their records. No background checks will be performed by Carnival until a guest has booked a cruise.
Carnival will provide a notice of adverse action to guests in the event it denies passage based on information in a consumer report. That information will be disclosed via email to the booked guest at the email address on file for the booking. Carnival will also provide guests notice of the right to obtain the consumer report and required contact information for the credit reporting agency, as required by FCRA.
Consumer reports generated by the consumer reporting agency will be shared solely among members of Carnival’s Security Services Department and with limited members of management on a need-to-know basis only. Persons to whom a consumer report is disclosed will be given a copy of this policy along with the consumer report. The department head of Carnival’s Security Services Department will conduct an audit of these disclosure restrictions every six months to ensure that security personnel and management are aware of this policy.
Consumer reports received by Carnival will be retained for a period of three years from the date of the end of the relevant planned cruise. During such time the consumer reports will be accessible only, as described above, on a need-to-know basis. At the end of this period, Carnival will ensure that all paper copies of the consumer reports have been shredded in secure facilities and that all electronic copies of the consumer reports have been deleted and made irretrievable. This information will be collected, used and retained in compliance with Carnival’s privacy guidelines and will be handled per Carnival’s privacy notice.
Unauthorized use or disclosure of consumer reports by an employee of Carnival outside the scope of this policy may be grounds for disciplinary action, including dismissal.