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Supplemental IDV Tool Notice for Job Candidates

Effective Date: September 28, 2026

1. Scope of This Notice

This supplemental notice applies to West Monroe Partners, LLC’s and its affiliates’ (collectively, “West Monroe”) use of automated tools in its hiring process for job candidates who are asked to complete, or are otherwise evaluated through, the covered identity and fraud verification process. These tools may include automated decision-making technology, or ADMT, and automated employment-related decision technology, or AEDT, where applicable. Certain state-specific rights may apply depending on, among other things, where you reside. It covers West Monroe’s use of:

• Recruiting platform fraud detection and identity verification tools.
• Background screening and identity verification tools used at later hiring stages.

This notice explains how these tools are used for candidate identity verification and fraud prevention. It does not replace West Monroe’s broader privacy notice, background check disclosures, or other hiring notices. Those notices describe West Monroe’s broader practices for collecting, using, disclosing, retaining, and protecting candidate personal information.

2. Why West Monroe Uses These Tools

West Monroe uses these tools to help confirm candidate identity, detect possible impersonation or hiring fraud, and protect the integrity of the recruiting process.

West Monroe's recruiting platform tools may include fraud detection, identity verification, spam controls, and process support used only for identity verification, application integrity, and fraud-prevention purposes. These tools may flag suspicious applications by analyzing signals such as phone number, email, IP address, and location, and may help confirm that applicants are who they say they are. Identity verification tools may include matching a candidate’s selfie to a government-issued ID and corroborating details across trusted sources. The tools are used to support identity and fraud review and are not used as the sole basis for final hiring decisions.

Identity verification tools used at later hiring stages may include government ID validation, liveness-based selfie checks, device fingerprinting, forensic document analysis, and device or network intelligence.

3. Personal Information Used by the Tools

West Monroe may process the following categories of personal information for this identity and fraud verification process. These categories may come from you, your application materials, West Monroe's recruiting systems, recruiting platform providers, fraud detection providers, identity verification providers, background screening providers, and device, network, application, or verification records generated as part of the process:

West Monroe uses sensitive personal information in this process only for identity verification, fraud prevention, hiring integrity, legal compliance, and related recruiting purposes. West Monroe does not use sensitive personal information collected through this process to infer characteristics about you, and does not sell or share candidate personal information collected through this process for cross-context behavioral advertising. Section 10 describes additional commitments that apply to biometric identifiers and biometric information.

4. How the Tools Work and How Outputs Are Used

The tools may generate verification results or fraud-related signals. These may include:

• Identity verification status.
• Mismatch indicators.
• Suspicious application or network signals.
• Duplicate profile or impersonation indicators.
• Document validation results.
• Selfie, face-match, or liveness results.
• Device, network, IP, or approximate location risk signals.

The tools assess personal information by looking for identity-match results, inconsistencies across application and identity information, duplicate or suspicious application patterns, device, network, IP, or approximate location risk indicators, document validation results, and selfie, face-match, or liveness results. The specific signals and weighting may vary by tool and workflow, and West Monroe does not include security-sensitive details that could compromise fraud prevention, system security, or candidate safety.

West Monroe uses these outputs as inputs for human review and recruiting process decisions. An output may cause West Monroe to request additional verification, ask the candidate for more information, route the candidate for human review, or, if an adverse outcome is being considered, provide the human adjudication and review process described in Section 5 before the outcome is finalized.

West Monroe does not use an automated fraud or identity verification signal as the sole basis to reject, deprioritize, pause, or remove a candidate from consideration. West Monroe’s process provides that fraud-related status or signals are validation triggers for further review and are not used as the sole basis for rejection, interview prioritization, deprioritization, or a security-concern disposition. West Monroe provides this notice for transparency and, where applicable, to support pre-use notice obligations without conceding that any particular tool or process is subject to ADMT, AEDT, or similar legal requirements, which depends on the tool, the process, the jurisdiction, and the degree of human involvement. West Monroe’s process is designed so automated outputs are used as validation triggers and, if identity verification signals are not positive, the matter is routed to human adjudication before any final adverse outcome. If an automated output is considered in a final adverse outcome, West Monroe will provide the appeal process described in Section 7 where available.

5. West Monroe’s Human Review Process

West Monroe’s process is designed to keep trained humans in control of hiring decisions and any adverse outcome that may be informed by identity or fraud signals.

• Recruiters assess minimum qualifications before considering automated fraud status.
• A fraud-related status or signal may route the candidate to identity verification.
• A clean identity verification result allows the candidate to continue in the hiring process.
• A failed, negative, unresolved, inconsistent, or otherwise non-positive identity verification result triggers human adjudication before any final adverse outcome materially based on that result.
• An identity verification result used at a later hiring stage that is failed, negative, unresolved, inconsistent, or otherwise non-positive will be routed for human review before any final adverse outcome materially based on that result.
• Before any final adverse outcome that is materially based on an identity or fraud verification result, West Monroe will give the candidate a reasonable opportunity to provide additional information or documentation.
• If you require an accommodation to complete a selfie, face match, or liveness check, West Monroe will offer an alternative identity verification method.

The human reviewer will be trained to interpret the ADMT output, will review the output together with other relevant candidate information and any information the candidate provides, and will have authority to change or overturn the outcome. West Monroe will document the human reviewer’s consideration of the output and the basis for the final outcome. Adjudication is West Monroe’s internal pre-decision review process for non-positive identity verification results. An appeal is a candidate-initiated request for further review after the candidate is notified of an adverse outcome or otherwise exercises an available appeal right.

6. Jurisdiction-Specific Rights

This section describes rights that may apply to candidates under applicable local law, including California, Colorado, Connecticut, and Illinois. For California purposes, these rights apply when West Monroe uses ADMT to make a significant decision, including a decision that results in the provision or denial of employment opportunities or compensation, and the ADMT replaces or substantially replaces human decision-making. West Monroe provides this notice for transparency and, where applicable, in connection with automated tools that may be subject to ADMT, AEDT, or similar notice requirements, depending on the tool, process, jurisdiction, and degree of human involvement. Subject to applicable exceptions, California candidates may have the following ADMT rights:

• Access: You may request information about West Monroe’s use of ADMT with respect to you, including the purpose of the ADMT, information about how it processed your personal information, the output generated, and how the output was used.
• Appeal and human review: If an ADMT output could adversely affect your candidacy, you may appeal to a trained human reviewer with authority to change or overturn the decision.
• Opt out or appeal, where applicable: The CCPA regulations generally provide a right to opt out of ADMT used to make significant decisions, unless an exception applies. For this workflow, West Monroe does not use automated identity or fraud signals as the sole basis for an adverse hiring decision. To the extent an opt-out right would otherwise apply, West Monroe relies on the human-appeal exception and will provide an appeal process through which applicants may seek review by a human reviewer with authority to change or overturn any adverse hiring decision, in lieu of a separate opt-out right.
• Non-retaliation: West Monroe will not retaliate against you for exercising your CCPA rights.

For Colorado candidates, automated tools may be used in a manner that could constitute covered ADMT if an output materially influences a consequential employment decision. If covered ADMT materially influences a consequential employment decision that results in an adverse outcome, you may request instructions for accessing and correcting factually incorrect or materially inaccurate personal data used in the decision. For Colorado purposes, ADMT materially influences a consequential employment decision when the ADMT output is a non-trivial factor that affects the outcome, including by constraining, ranking, scoring, recommending, classifying, or otherwise meaningfully altering how the decision is made. Colorado law does not require correction of opinions, predictions, scores, or protected evaluations. You may also request meaningful human review and reconsideration of the consequential decision, to the extent commercially reasonable. Colorado law does not provide a general right to opt out of ADMT used in employment decisions.

For Connecticut candidates, beginning October 1, 2027, automated tools may be used in a manner that could constitute covered AEDT if West Monroe uses an output generated by the tool for the purpose of making, or as a substantial factor in making, an employment-related decision concerning you in Connecticut. For Connecticut purposes, a substantial factor is one that meaningfully alters the outcome of an employment-related decision concerning an individual in Connecticut. This notice describes the purpose of the automated tools and the nature of the employment-related decision, the categories and sources of personal data analyzed, how the personal data is assessed in reaching the decision, and West Monroe contact information, where applicable.

West Monroe may identify the specific trade names of the tools in its Illinois Notice of AI Use or another linked or accompanying notice, provided that notice is made available with this supplemental notice or before the relevant decision. Connecticut law does not provide a general opt-out right for AEDT used in employment decisions.

If you are a candidate in another state or locality that provides rights relating to automated tools used in hiring, West Monroe will honor those rights to the extent required by applicable law. You may contact West Monroe using the information in Section 7.

Finally, depending on where you live, you may have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, including decisions about employment opportunities. To exercise that right, contact [email protected].

7. How to Submit a State-Specific Request or Appeal

Where available under applicable law, you may submit an ADMT access request, post-adverse-outcome information request, AEDT inquiry, or appeal by contacting West Monroe at:

• Email: [email protected]
• Mail: 311 W. Monroe St., 14th Floor, Chicago, IL 60606 ATTN: Recruiting
• Telephone: 1-800-828-6708

You may provide documents, corrected information, explanations, or other context for West Monroe’s human reviewer to consider.

If a Colorado candidate receives an adverse outcome resulting from a consequential employment decision in which covered ADMT materially influenced the decision, the candidate may have rights under Colorado law to receive information about the decision and the role the covered ADMT played in the decision. The candidate may also request additional information about the covered ADMT and the inputs used in the decision, including, to the extent available to West Monroe from the applicable provider, the name of the covered ADMT, the covered ADMT version number if applicable, the developer of the covered ADMT, and the types, categories, and sources of personal data used in the decision. West Monroe may withhold trade secrets or information protected from disclosure by state or federal law and will notify the candidate if information is withheld for that reason.

West Monroe will acknowledge California ADMT access and appeal requests within 10 business days and will respond within 45 calendar days. If reasonably necessary, West Monroe may extend the response period by up to an additional 45 calendar days and will explain the extension.

Separate timing may apply to Colorado post-adverse-outcome disclosures, and other requests where required by applicable law.

8. Service Providers and Vendor Sharing

West Monroe may provide candidate personal information to recruiting platform, identity verification, background screening, and related service providers or contractors to operate the identity and fraud verification process.

This supplemental notice does not describe all other categories of service providers, contractors, or third parties that may receive candidate personal information outside this identity and fraud verification process. Those disclosures are addressed in West Monroe’s broader privacy notice.

9. Retention of Automated Tool Information

West Monroe retains automated-tool-related identity and fraud verification information only for as long as reasonably necessary for the purposes described in this notice, including identity verification, fraud prevention, recruiting integrity, legal compliance, audit, dispute resolution, and recordkeeping, and in accordance with West Monroe's applicable retention schedules and broader privacy notice as it applies to applicants.

10. Biometric Information

Some identity verification tools described in this notice may collect or generate biometric identifiers or biometric information, such as a scan of face geometry derived from a selfie image or a government-issued ID image, or information generated by a liveness check. To the extent that West Monroe or a service provider acting on West Monroe’s behalf collects biometric identifiers or biometric information from a candidate, West Monroe:

• does not receive candidate biometric identifiers or biometric information; West Monroe's identity verification provider collects and uses that information for identity verification, fraud prevention, hiring integrity, and legal compliance, and not to assess a candidate’s job qualifications, characteristics, or performance, and not to infer any other characteristic about the candidate;
• does not sell, lease, trade, or otherwise profit from candidate biometric identifiers or biometric information;
• discloses that information only to service providers acting on West Monroe’s behalf under written contract, or as otherwise required or permitted by applicable law; and
• stores, transmits, and protects that information using a reasonable standard of care and in a manner at least as protective as West Monroe uses for other confidential and sensitive information.

For clarity, West Monroe does not receive any candidate biometric identifiers or biometric information in connection with the identity verification process. It may receive limited verification result data, such as pass, fail, incomplete, expired, declined, unresolved, or similar status information, limited identifiers, and related information needed to support the identity review workflow.

Please review our biometric notice for job applicants and candidates for more detailed information regarding these issues.

11. Updates to This Supplement

West Monroe may update this supplemental notice if its tools, identity verification process, rights request process, or legal obligations change. The effective date above shows when this notice was last updated.