Practical Guidance

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June 13, 2019
Practical Guidance for Credentialing Clients
This document is intended to set forth strategies for CRAs in credentialing their clients. Section 607 of the Fair Credit Reporting Act (FCRA) imposes several compliance obligations on consumer reporting agencies (CRAs). The first of these obligations involves client credentialing, often referred to as client vetting. Under 607(a), prior to furnishing a consumer report, CRAs must maintain reasonable procedures that at minimum require the CRA to obtain from the prospective user: (1) the prospective user's identity; (2) certification for the permissible purpose that forms the basis for the user's request for consumer reports; and (3) certification that the information will be used for no purpose other than the permissible purpose provided. Following the above, every CRA must make a "reasonable effort" to verify the identity of the user and the uses certified by the prospective user prior to providing a consumer report to such user.
July 26, 2018
Recommended Strategies for Developing Reasonable Procedures to Assure Maximum Possible Accuracy
Section 607 [15 U.S.C. 1681e(b)] of the Fair Credit Reporting Act (FCRA) prescribes specific compliance procedures of Consumer Reporting Agencies (CRAs) and end-users of consumer reports. Subsection (b), Accuracy of Reports, is one of the key provisions of Section 607, outlining a CRA's obligation to "follow reasonable procedures to assure maximum possible accuracy of the information" of consumers about whom it prepares reports. This accuracy requirement applies to all consumer reports and all consumer reporting information in those reports, not just public record information. In addition to the legal requirement to comply with Section 607, which is intended to protect consumers, customers of CRAs also expect accurate information which they in turn use in determining eligibility for matters such as employment, housing, or volunteer positions. This document is intended to set forth recommended strategies for CRAs preparing consumer reports for delivery to end users.
July 26, 2018
Recommended Strategies for Procedure in Case of Disputed Accuracy
Consumer Reporting Agencies (CRAs) are required to adhere to specific dispute procedures prescribed by Section 611 [15 U.S.C. 1681i] of the Fair Credit Reporting Act (FCRA) whenever a consumer disputes the completeness or accuracy of any item of information contained within their file. CRAs must conduct a reasonable reinvestigation to determine whether the disputed information is incomplete or inaccurate. The reinvestigation must determine the correct and current status of the disputed information and if inaccurate or unverifiable, it must be deleted from the file. This document is intended to set forth recommended strategies for receiving, reinvestigating, and resolving disputed information.
July 26, 2017
Insurance Policy Considerations for Screening Companies
Consumer Reporting Agencies (CRAs) generally rely on Errors & Omissions or Professional Liability Insurance to provide protection in the event of a background screening lawsuit. However, too often CRAs do not realize until it's too late that their insurance policy does not provide meaningful coverage. CRAs are well advised to make sure that they understand the details of their prospective or actual policy to ensure that they are not surprised later.
April 26, 2017
International Provider Recommended Practices
This document is intended to be a listing of baseline recommended practices for providing data and services to background screening companies, to and from all NAPBS member geographic regions. These services may include the legal and customary checks of private or public information. Such private or public information may include but is not limited to criminal records, employment, academic, credential, credit, and other research services. This document is intentionally broadly written with the understanding that practices and regulations may vary by country and regions. It is expected that all services will be delivered in compliance with local laws and regulations. It should be viewed as an initial reference tool in an effort to clarify worldwide practices. Following these recommended practices, when possible, may help to instill confidence and better understanding in the international background screening process.
March 19, 2017
US Provider Data Security & Privacy Guidelines
Consumer Reporting Agencies and their supporting information and service providers are routinely entrusted with PII on individual consumers in the course of providing services to their clients. Accordingly, the purpose of this document is to establish minimum guidelines that NAPBS Providers should follow in order to protect such PII from unlawful or unethical use.
May 21, 2014
Criminal Record Provider Guidelines
Guidelines intended for research providers in the background screening industry
March 19, 2014
Use of the Social Insurance Number in the Employment Screening Industry
Practical guidance for using Social Insurance Number

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