In last week’s blog, we discussed the importance of ongoing screening of current employees and how crucial periodic checks can be to maintaining a company’s safety and welfare. Keeping abreast of an employee's criminal record, motor vehicle record, and potential drug habits can eliminate big and disastrous surprises.
Keep in mind, however, there are a few rules that must be followed to ensure company compliance with the FCRA.
Here are some slight ‘tweaks’ to add to your screening policy when implementing post-employment or ongoing screening:
The first recommendation is to make sure the policy is clearly defined. Decide on what timeframes and upon which actions you will screen current employees. Some of these may be:
Annually: once a year, every employee is screened with the pre-defined criteria that has been set in place in advance.
Reasonable suspicion/A change in lifestyle: This can be either in an upgrade in lifestyle such as the acquisition of large material goods, but also in a downgrade in lifestyle. Such signs can be in terms of physical appearance, punctuality, or declines in overall productivity, which are often the sign of either substance abuse or domestic crises of one sort or another.
Random: you may periodically choose a certain percentage of your employees and screen them.
Once the perimeters have been decided, be sure the information is added into your Employee Handbook- and any other hiring materials- that specifically explains the policy of periodic or ongoing background checks.
The second recommendation is to utilize an Applicant Release form that is evergreen. This is the form the applicant signs to authorize the initial background check during the hiring process. This form needs to contain a statement noting that by signing the form the applicant is giving the employer permission to perform a pre-employment check, and ALSO any additional background checks in accordance with the company policy, if the employee ends up being hired. (Keep in mind that California does not allow Evergreen forms. If you are conducting business there, you will need to get a form signed each year).
The third recommendation is to practice consistency! HR needs to be trained in depth on every aspect of the policy. Require and continually encourage HR to apply this policy across the board to each and every employee, with appropriate penalties being set in advance should an employee background check require actionable procedures.
If your company has decided to perform ongoing or periodic background screening on current employees, it is advisable to take a little time to set perimeters in place to ensure that all practices are compliant. It is worth a little effort up front to protect the safety of your workplace and business.
~~Susan McCullah is the Product Development Director for Data Facts, Inc, a 23 year old Memphis based company. Data Facts Inc -an NAPBS accredited company- is a leading provider of employment screening solutions. Check our our website for a complete explanation of our services.