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Implementation
The human resources department should set up
program with
vendor’s assistance. Each organization will develop its own forms and procedures based on its own requirements and goals. This will entail a variety of personnel protocols, establishing contacts and liaisons between
company and
vendor, determining time requirements, and such basis mechanisms as fax numbers.
File Maintenance
Investigative Consumer Reports (screening reports) should never be maintained in
employee’s jacket, but should instead be kept under lock and key with limited access by authorized management personnel in separate file facility and in alphabetical order. The files should be maintained for
seven-year statutory period commensurate with employee file retention.
Background information forms contain confidential subject data, including date of birth and other information, and should not be maintained by
human resources department. The vendor should do this as part of their service, and in
event
form is required for court purposes, should provide it upon request for up to seven years.
Interpretation
Parameters on how to interpret information should be established at
outset of
program, and should be undertaken by
same personnel to ensure consistent application of theorems of qualifiers for continued candidacy or hiring. This area is open for discussion and, of course, varies with each environment.
As you can undoubtedly imagine, in order to properly implement any factual screening program one needs to start with forms which allow
candidate to provide thorough information such as name, address and so forth. These forms should be
starting point for any intelligent screening program. Just about everyone has an employment application, or some form of release/disclaimer used in
initial application process.
Many screening firms are turning to some form of independent release form for their clients, after long conducting checks without them. The forms vary in substance and content, and you would be well advised to learn as much as possible about
philosophy of
form before using it in order to avoid trouble from an unsophisticated form. The information requested should include
following:
Full Name Current and prior addresses Ancillary name forms Social Security number Date of birth (Yes, this absolutely legal if it is being used for criminal file identification purposes, and
applicant is made aware of this sole use. You must also not keep a copy of this form anywhere in
employee’s file in case
EEOC auditor doesn’t see things quite
way you do.) Driver’s license number Criminal history disclosure section (This varies from state to state, and must be constructed in accordance with guidelines and standards for
disclosure, acquisition and release of criminal information under applicable state law.) Agreement and consent to obtain consumer information (Some of
more sophisticated forms now in use have some effective, built-in disclosure inducement items which are
result of investments in psychological research and testing. These are designed to get more than just a regurgitation of subject identifiers.) We have purposely not provided a sample form with this article due to
proprietary nature of
good ones in existence. Also, since each business environment is different, it is possible that a “generic” form might be used improperly.
Conclusion
At this point, you should have a basic familiarity and comfort level with
world of factual employment screening and its ramifications. The key things to remember are as follows.
Establish an intelligent and consistent policy of factual employment screening, drug testing, and/or personality evaluation.
.Perform a thorough job of screening your employment candidates.Rely only upon tried and true methods of employment screening, as trendy or new wave methods, which are untested, can land you in court very quickly.
.Use common sense and rely on your intuition. Good, solid factual employment screening is not
ultimate decision maker – you are. The final report should only serve to reinforce your evaluation of
candidate, nothing more.
.Run your screening program with compliance in mind at all times. If you don’t, it is certain that labor attorneys, EEOC auditors, and others will confront you. In a nutshell, employment screening is like any other sensible management policy. If you are careful, smart, thoroughly qualify your vendors, and implement a viable common sense program, you will not only get better people in
organization, but also have less opportunity to exercise your workplace violence contingency plans or initiate fraud examinations.

Thomas C. Lawson, CFE, CII is President and Founder of APSCREEN International, the world’s leading full service Consumer Reporting Agency since 1980. Lawson is called “one of the real pros” as he has helped to reshape laws including those for employment screening, permissible credit reporting, asset discovery and fraud examination. Tom is a Life Member of: ACFE, ASIS, SHRM, PIHRA, PNRRA, PRRN, CII, WAD, WIN, FCAOC and OCEMA.