Well, first, I think it is poor performance for a consulting group to walk into your shop and make such a complex recommendation and not give you the background and guidance you need to execute on the recommendation. I would look for a different vendor in the future.
Second, while you need to make sure that you have written permission from your existing employees to pull their credit reports before pulling the reports, that is just the first step. You need to develop your procedures to ensure that you comply with the other aspects of the FCRA if you choose to take adverse action against the employee. Additionally, I would also recommend that you develop specific criteria regarding what you will do if you locate any derogatory information in the credit or background check. For example, what are you prepared to do under what circumstances. The consultation of a good employment attorney is also recommended during the development of this policy and associated procedures.
First published on BankersOnline.com 5/15/06
Credit Checks on Employees with Access to Sensitive Info
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Question:
We recently had a network assessment completed. The vendor recommended that we do "periodic" background and credit checks on employees who have access to sensitive information. Besides the IT staff, who else would you recommend we include in this "periodic" check and how often should it be done? We thought annually, would be that be sufficient?
Answer: