Transcript
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
CI’s Coffee ChatWith your host: Courtney Caola
11/20/2014
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Client Audit Would your organization be prepared for an audit by Commercial Investigations LLC?
Here is what you should know so you will be!
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Client Duties Under the FCRA
1. Make disclosure to and obtain authorization from the subject
2. Provide a certification to CI3. Comply with the preadverse and adverse
action requirements
Client AuditFCRA
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Disclosure and Authorization
CI’s Consent Forms
Requirements:• Clear, Conspicuous and in writing• Document solely the disclosure• When the subject applies or starts
employment
Additions:• Permitted for the duration of employment
Client AuditConsent Forms
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Client AuditConsent Forms
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Certification to CI
Requirements:
• Has permissible purpose
• Obtained subject’s consent
• Will comply with preadverse and adverse action
• Will comply with all applicable laws
Client Audit Certification
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Preadverse and Adverse Action
• Only When Not Moving Forward• Copy of Report• Summary of Rights• Waiting Period• Adverse Notice
http://commercialinvestigationsllc.com/CIWebinarSeries.html
Client AuditAdverse Action
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Record Retention Periods
How long do I need to keep consent forms on file?
How long do I need to keep the background
investigation on file?
How long do I need to keep the pre-adverse/adverse
information on file?
Client AuditRecord Retention
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Document Destruction
Obligations:• Burning, Pulverizing or Shredding• Destroy or Erase Electronic Data
Recommendations:• Outsource to Document Destruction
Company
Client AuditDestruction
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Adjudication Parameters
What do you do with adverse information reported in your backgrounds?
How do you track your decisions to avoid discrimination allegations?
Client Audit Adjudication Parameters
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
New York State Corrections Law Article 23-A
Requires employers to post and give applicants notice of
their rights under 23-A.
CI Article 23-A Poster CI New York Consent Forms CI Adjudication Parameters Worksheet
Employers who reject applicants with criminal convictions
must give written notice of the reasons for rejection within
30 days of a request.
Client AuditArticle 23-A
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Client Audit Client AuditArticle 23-APosterLocation
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Client AuditArticle 23-APoster
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Client AuditArticle 23-APoster(Cont.)
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
CI Adjudication Parameters Worksheet
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
CI Adjudication Parameters Worksheet (cont.)
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Q & A:Client Audit
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
About:CI’s Compliance Team
Michelle, Courtney, Melissa and Craig
Continuously watch federal and state legislation concerning background investigations
Provides client assistance with FCRA regulations
Available to assist you
Contact:
800-284-0906
staff@commercialinvestigationsllc.com
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
About:MichellePyan
Michelle Pyan – President and Owner
Started Commercial Investigations LLC in March 2004
Licensed Private Investigator
Ran her first background investigation in 1991
Received her Fair Credit Reporting Act Advanced Certification in October of 2014.
Contact:
800-284-0906 Ext. 202
michellepyan@commercialinvestigationsllc.com
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
About:CourtneyCaola
Courtney Caola - Client Services Specialist
Joined Commercial Investigations LLC in December of 2013
Masters Degree from John Jay
Six years working as an Investigator with the Federal Government conducting background investigations
Total of 12 years working with government agencies in various roles
Contact:
800-284-0906 Ext. 214
courtneycaola@commercialinvestigationsllc.com
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Melissa Ramsey - Investigator
Joined CI in October of 2011 as a data entry and call center representative and is currently an investigator focusing on initiating our clients’ requests.
Melissa received her Fair Credit Reporting Act Advanced Certification in April 2014.
Graduated from Siena College in May 2011 with a Bachelor of Arts Degree in Sociology.
Contact:
800-284-0906 Ext. 211
melissaramsey@commercialinvestigationsllc.com
About:MelissaRamsey
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
Craig Wigand - Investigator Joined CI in August of 2011 as a data entry
and call center representative and is currently an investigator.
Received his Fair Credit Reporting Act Advanced Certification in October of 2014.
Graduated from South Colonie Central School District in 1996. Attended SUNY Plattsburgh.
Contact:
800-284-0906 Ext. 204
craigwigand@commercialinvestigationsllc.com
About:Crai gWigand
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
About Us:Commercial Investigations LLC
Commercial Investigations LLC (CI) is a certified woman owned enterprise and licensed private investigative agency.
Our vision is to be the most innovative and educational background investigations partner.
Hosted by: Courtney Caola and the CI Compliance Team
(800) 284-0906www.commercialinvestigationsllc.com
facebook.com/commercialinvestigationsllc
twitter.com/CI_LLC
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info@commercialinvestigationsllc.com
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The information provided in this presentation does
not constitute legal or accounting advice. It is for
information and discussion purposes only.
This presentation may not be reproduced without
the written consent of the author.
CI’s Coffee Chat: Client Audit
Commercial Investigations LLCwww.commercialinvestigationsllc.com
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