CI's Coffee Chat - The Client Audit

CI’s Coffee Chat: Client Audit

Commercial Investigations LLCwww.commercialinvestigationsllc.com

CI’s Coffee ChatWith your host: Courtney Caola

11/20/2014





Client Audit Would your organization be prepared for an audit by Commercial Investigations LLC?

Here is what you should know so you will be!





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



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



Client AuditConsent Forms



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





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







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



Document Destruction

Obligations:• Burning, Pulverizing or Shredding• Destroy or Erase Electronic Data

Recommendations:• Outsource to Document Destruction

Company

Client AuditDestruction



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



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



Client Audit Client AuditArticle 23-APosterLocation



Client AuditArticle 23-APoster



Client AuditArticle 23-APoster(Cont.)



CI Adjudication Parameters Worksheet



CI Adjudication Parameters Worksheet (cont.)







Q & A:Client Audit



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

[email protected]



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

[email protected]



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

[email protected]



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

[email protected]

About:MelissaRamsey



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

[email protected]

About:Crai gWigand



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

linkedin.com/company/commercial-investigations-llc

[email protected]

http://pinterest.com/proactivetruth/

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 - The Client Audit

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