Occasionally, clients are surprised that their background screening providers use vendors to provide global screening fulfillment. The expectation by such clients is that the screening company providing the global service is obtaining information in some 240 countries by themselves.
Any company providing a full suite of global background screening services is using a supplier somewhere. It is not possible for a screening company to cover the world with no help.
Here are some of the major reasons why global background screening providers rely on local fulfillment entities:
- Some global searches require the requesting party to be in the country. For example, Canada National Criminal Records (CPIC) must be ordered by a company in Canada who has the appropriate agreements in place with the source. There are several searches that have this requirement.
- The sheer size of some countries makes it difficult, if not impossible, to cover the entire country, even with a huge workforce. Consider the size of the United States. Screeners in the United States use suppliers to gather criminal record information, even if it is only to supplement searches in some court houses. India is a huge country as well. When background searches are done manually, such as criminal record checks via police stations, address verifications via physical verification, or education verification via in-person visits, it would take an enormous workforce for one company to cover the entire country.
- Local fulfillment entities better understand the cultural complexities of their area. In some countries, making repeated calls every day for five days may be seen as acceptable. Yet in other countries, this same action may be seen as pushy and will result in the calls being ignored.
- Conducting searches, especially verifications, in the local language is often more successful. Not only are the questions and answers better understood, but there some sources who take offense to requests made in other languages, such as English.
- Managing time zone differences is difficult for a single company to do, even with multiple offices. Using local suppliers can help speed up searches, since they are working in the same time zone as the source.
- Fees and other payments are often required to be in local currency. Most fees must be paid in advance. Some sources may require fee payments in specific forms, such as bank drafts or money orders. Managing these fee payments from other countries adds to the complexity of the search process, to the cost, and to the turnaround time.
- Some searches originating from specialized databases must be purchased from specific suppliers. For example, programs that validate IDs or interrogate MRZ codes on IDs come from companies that specialize in these services. The same is true for adverse media databases, sanctions databases, and credit bureau files.
When clients express concern about the use of vendors in the screening process, discuss what is driving that concern. My experience is the client is concerned about the loss of quality and consistency. They may also be concerned about how well the supply chain is vetted and contracted. With the upcoming data protection regulation change in the European Union, vendor vetting and contracting is getting a lot of attention lately. This is a good opportunity for background screening companies to explain their supplier selection criteria, vetting process, and standard operating procedures for global search fulfillment. (If you are a screening company without these, it may be time to create these documents as client-facing support tools.) If the client is concerned about their data leaving their home country or region, such as a concern in the U.S. about “offshoring”, then a bigger conversation must be had about the nature of global screening. It is not possible to conduct a background search in another country without the data leaving the home country.
I have been fortunate to have been associated with several wonderful suppliers during my years in global screening. They have taught me about screening in their countries, put up with my incessant line of questioning, and provided nuanced details about ordering requirements. I learn something from them every day, and I’m honored by how well they care for our clients.
|Kerstin Bagus – Director, Global Initiatives|
Kerstin Bagus supports ClearStar’s Global Screening Program as its Director of Global Initiatives. She has more than 30 years of background screening industry experience, working for a variety of firms, large and small. Kerstin is one of the few individuals in the industry who is privacy-certified through the International Association of Privacy Professionals (IAPP) for Canada, the EU, and the U.S.
Kerstin is a passionate participant in the Professional Background Screening Association (PBSA, formerly NAPBS) and is a current member of the Board, in addition to participating on several committees. She also participates on IFDAT’s Legal Committee, with a primary focus on global data privacy.
At ClearStar, we are committed to your success. An important part of your employment screening program involves compliance with various laws and regulations, which is why we are providing information regarding screening requirements in certain countries, region, etc. While we are happy to provide you with this information, it is your responsibility to comply with applicable laws and to understand how such information pertains to your employment screening program. The foregoing information is not offered as legal advice but is instead offered for informational purposes. ClearStar is not a law firm and does not offer legal advice and this communication does not form an attorney client relationship. The foregoing information is therefore not intended as a substitute for the legal advice of a lawyer knowledgeable of the user’s individual circumstances or to provide legal advice. ClearStar makes no assurances regarding the accuracy, completeness, or utility of the information contained in this publication. Legislative, regulatory and case law developments regularly impact on general research and this area is evolving rapidly. ClearStar expressly disclaim any warranties or responsibility or damages associated with or arising out of the information provided herein.