| It is Certified Employment Screening, Inc.'s (CES, INC.) policy
to treat each and every background report order as an investigative
report as defined in the Federal Fair Credit Reporting Act. For any
company to order or for any company to conduct an investigative employment
background report, federal law requires that the subject of the report
be informed of the process and that they give their written authorization.
CES, INC. feels that client companies do not receive suitable depth
of research unless an investigative background report is developed.
It can also be easily argued that, without written authorization
and release to conduct a pre-employment background report, companies
ordering such reports are indirectly accepting an unnecessary amount
of risk. Needless to say, CES, INC. would also be at greater risk,
legally, if they were conducting unauthorized investigative pre-employment
background reports.
Secondly, the Federal Fair Credit Reporting Act demands that all
such reports be kept CONFIDENTIAL. If all of the ordering parameters
are submitted through this open medium, the Internet, it is hard
to argue that the company doing the ordering or the Consumer Reporting
Agency preparing the report are accepting their full responsibility
regarding CONFIDENTIALITY, so we utilize a virtual private network
or modem to modem access both utilizing encryption.
Thirdly, the Federal Trade Commission (FTC) has recently recommended
new legislation to further protect the rights of the applicant (consumer).
Reference the 9/24/96 edition of any major newspaper such as USA
Today. The proposal is very clear. It requires the applicant's written
authorization for any background report that includes Social Security
number, former names, date of birth, and former addresses. Needless
to say, nearly all orders for pre-employment background reports
require former names, date of birth, Social Security number, and
former addresses of residence. CES, INC. strongly supports this
FTC legislation. The privacy rights of every job applicant need
protection and deserve full support in this legislative process.
To meet all of the current and proposed federal requirements for
investigative pre-employment background reports, CES, INC., as a
matter of policy, demands the applicant's authorization signature
be obtained for each order and saved according to FCRA guidelines.
All employees at CES, INC. are required to maintain CONFIDENTIALITY.
All reports are ordered and returned via password protected encrypted
windows based software or via confidential fax.
This is a brief description of CES, INC. policy regarding very
important issues in this industry. It is not a full legal discussion
of the FCRA, EEOC, ADA, or other federal laws or state or local
laws regarding this subject
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