As many of you know, I’ve been working closely with the team from Appriss for the last several months offering my expertise when it comes to employment background screening and the CRA market.
I am truly excited about the potential true continuous monitoring of incarceration records has for both CRA’s and their end-user clients and see this as the next great innovation in employment background checks.
These real-time incarceration alerts are an early indicator of risky employee behavior that could potentially threaten a business and its employees. Incarceration alerts equip employers with the knowledge needed to proactively mitigate business risks that stem from an employee’s criminal activity.
That said, I think there are some key compliance considerations that we should all pay attention to when adopting such a program and I’ve articulated them in a guest blog just posted on Appriss’ site titled, “7 Compliance Considerations when Implementing a Continuous Monitoring Program“.
These considerations include:
- Modifying existing employment policies for end-users
- How and when to seek consent from employees
- Maintaining maximum possible accuracy is prescribed in the Fair Credit Reporting Act (FCRA)
- Limiting the information employers see based on their adjudication policies
- How and when an employer can take adverse action based on an alert
- Maintaining compliant adverse action requirements
By no means are any of these show-stoppers or deal-breakers. Just things you’ll want to think about and discuss with your legal counsel before getting started.
Previous Post
