V. Training and Client Onboarding
1. Does the vendor have a documented training process in place for all staff that will be involved in processing or will have access to personally identifiable information? This training should be offered at the time of hire and on an on-going scheduled basis to ensure competency levels are maintained. Training should, at minimum, cover:
- Legal requirements for conducting background screening; - Effective data protection and privacy to ensure security of information; and
- The essential elements of a background screening policy and key elements of an effective employment background screening program.
2. The vendor should also be required to provide periodic reports that demonstrate that the training is occurring as scheduled.
3. Ask the vendor to describe their process for implementing the transition to their services.
4. Does the vendor have procedures and processes in place to advise, train and educate clients regarding: - Their legal responsibilities in conducting background checks; - How to order, retrieve, read and understand the information provided in a consumer report; and
- Appropriate forms including providing sample documents, which are needed to legally conduct background checks.
VI. Data Protection, Privacy and Security Measures
1. Does the vendor have a written Information Security Policy that adheres to known best practices and provides a high level of data protection? Ensure that the vendor policy addresses at minimum the following:
- Details the purpose of the collection of an applicant or employee’s personally identifiable information;
- The intended use and how the information will be shared, stored and destroyed;
- Creates an audit trail of who has accessed information and has a procedure in place to detect, investigate and respond to intrusions; and
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Identifies a specific position or person(s) that is responsible for implementing, managing and enforcing the information security policy.
2. Have your Information Technology staff verify that the vendor and any sub-contractors that are involved with processing personally identifiable information:
- Have system security in place that fully meets your data security requirements and meets background industry standards; and
- Have procedures in place to mask some or all of the social security number from all reports, as well as obscure the year of birth.
“Ensure that the vendors’ employees and their sub- contractors are held to the same screening standards you have established for your employees.”
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