The Physical Inspection: What it is, Why and How We Do It

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The Physical Inspection: What it is,
Why and How We Do It

Few EmployeeScreen IQ clients are surprised to learn that all screening candidates must sign a release form, or that they must keep all information provided by a Consumer Reporting Agency (CRA) confidential between HR staff, hiring managers, and the candidate her/himself. Virtually all hiring and security managers are aware of the Fair Credit Reporting Act (FCRA) and the importance of observing its requirements to protect the privacy of their candidates and the integrity of their hiring decisions.

What frequently comes as a surprise to new clients is that CRAs must conduct a physical site inspection of the commercial business location before initiating any services on behalf of that client. Since July 2003, the credit bureaus have mandated that all CRAs must physically inspect all client locations that will receive Consumer Reports. For multi-site organizations that screen employees on a decentralized basis, or local levels, this means each facility that receives, maintains, or houses consumer reports must be inspected. CRAs originally had the discretion to decide whether to conduct this inspection on their own, or hire a third party service to conduct it. In October 2005, the credit bureaus removed this discretion; now all CRAs must use one of a select few organizations, approved by the credit bureaus, to conduct these physical site inspections.

What Can I Expect?

The inspection itself is a straightforward process. It simply represents validation that the organization setting up the account is a legitimate business entity with a permissible use for Consumer Report information, and that it is reasonably apparent that the information will be used for employment decisions. At the present time, there is no existing technology that could be used to automate this process. The mere existence of a business might be reasonably established by researching the internet. However, that does nothing to stem one of the most notorious causes of identity theft: criminals attempting to set up an account with a CRA by fraudulently claiming to represent a legitimate business when they in fact have no connection to that business. The inspection serves to validate the existence and physical location of the business, that the individual(s) setting up the account intends to obtain Consumer Reports for employment purposes, and that reasonable security is present at the facility to protect the privacy and confidentiality of consumer information.

Why All the Drama?

Information contained in Consumer Reports is personal in nature and could be used for many purposes that are not permissible or legal under the FCRA. Examples include loan decisions by predatory lenders who have been barred access to credit information or identity theft by criminals who are able to gain access to consumer information. The intent, obviously, is to provide an additional measure of security and protection to consumers such that their personally identifying information will not be used for illegitimate purposes.

Our Responsibility

As a Consumer Reporting Agency, EmployeeScreen IQ holds no responsibility higher than that of representing our clients as professionally as possible, and protecting the privacy of the individuals we obtain information on in the course of that representation. Observing the strict letter of the myriad federal and state laws nationwide, as well as non-legislative industry mandates provides unsurpassed risk management for our entire client base and ensures any job applicant screened by EmployeeScreen IQ receives the full rights and recourse allowed under the law, and then some.

Rob Thomson is Communications Manager and Senior Account Executive for Cleveland-based EmployeeScreen IQ, a best practices provider of pre-employment screening services throughout the U.S. and worldwide. Rob can be reached at (800) 235-3954 ext. 438 or rthomson@employeescreen.com.*

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