6. Verify that the vendor is certified in states that require background screening firms to be certified or require a private investigator license.
7. Does the vendor have a clearly demonstrated process in place to fully explain limitations of national or multi-jurisdictional databases to clients and have a written procedure in place for how criminal hits received from such sources will be re-verified?
8. Does the vendor maintain records regarding how often their databases are updated and make this information available to clients upon request?
9. Will the vendor assist you in developing an effective Background Screening Policy, if needed, or if one already exists, will they review your policy and make recommendations for improvements?
10. Does the provider give you projected hit rates (what you can expect) based on your industry, nature of the jobs you recruit for and geographic scope of your recruiting for the following categories:
- Criminal background; -
Dispute rate (discrepancy with reported information); and - Resume verification discrepancy rate.
11. Ask the provider to describe how their company responds to candidate disputes and their problem escalation process.
12. Ask the provider about the steps that they take to ensure accuracy of the information they report. 13. Ask if the same record is reported from multiple sources, how many times is it noted on the report.
“The FCRA requires background screening firms to provide the maximum possible accuracy in information so make sure you evaluate how a provider goes about ensuring they are meeting this requirement.”
II. Legal Compliance
1. Require the vendor to certify their compliance with all applicable federal, state and local discrimination, consumer reporting, privacy protection, data destruction and other governing laws.
2. Verify that the vendor has written procedures in place to ensure that all information sent to the client will comply with the law, e.g., arrest records, sealed or expunged records, etc. In addition, does the vendor provide all necessary FCRA forms, procedures and training in how to appropriately use, as needed?
3. Does the vendor have an established process in place to monitor and ensure that all ‘data furnishers’ as defined by FCRA/FACTA, that supply them information about individuals have instituted reasonable policies and procedures that (a) ensure the accuracy and integrity of furnished information and (b) allow individuals to formally dispute the accuracy of certain information that has been provided about them?
4. Does the vendor certify that their employees and sub-contractors who have access to personally identifiable information, sign a confidentially and non-disclosure agreement that meets your company’s requirements? This should include language that addresses new hires and employees leaving the firm. Have your legal counsel review the agreements.
5. Does the vendor have a written policy and procedure that clearly articulates the process to be used when an adverse criminal record is discovered that complies with the FCRA? At minimum, this should include their process for re-verifying the information and/or notifying the applicant at the time the information is reported as required by law.
6. Does the vendor have a written policy that details how they investigate and certify that all of their sub- contractors are bona fide businesses involved in the legitimate processing of personally identifiable information for a permissible purpose as defined by the FCRA?
7. Does the vendor’s policy state that consumer reports will only be issued after a client certifies it will comply with the FCRA and applicable federal and state laws? Also, does the policy affirm that access to personally identifiable information will only be provided to an authorized representative of your firm as prescribed by the FCRA?
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