An essential element of any due diligence plan is a yearly audit of your current practices.  In the event of a worst case scenario, and an employer hires someone that is unfit, unsafe or unqualified, the best defense is that the employer exercised due diligence in its hiring practices, including the choice of a screening firm.  ESR has developed a checklist, provided below, that can be used to send to a screening provider every year to document your due diligence and to measure the effectiveness of your current screening program.  For a Word version, contact Jared Callahan at 415-898-0044 or email him at [email protected].  More information is at .

This is a yearly process to document that our company is utilizing due diligence in its employment screening processes.  Please fill out and utilize additional paper if necessary.

  1. Have there been any material changes in the past year that would adversely affect your ability to provide industry standard employment screening reports?
  2. Is all work performed in the USA to protect privacy and control quality (i.e., nothing sent offshore to India or other places)?  If not, please explain in detail how privacy is protected. (See: http://www.concernedc
  3. Are all employment and education checks conducted by professionals in a controlled, call center type environment, so that nothing is sent to at-home workers?  If not, please explain how data privacy and the quality of work are monitored.
  4. For employment verifications, are anti-fraud procedures in place, such as independent verifications of all past employer phone numbers instead of relying upon an applicant supplied number?
  5. For education verifications, are steps taken to verify whether a college or university is accredited and to watch out for Diploma Mills?
  6. Are criminal searches conducted using the most accurate means, which normally means on-site (no database substitutes)? (See:
  7. Do you search for both felonies and misdemeanors when available?
  8. When a criminal hit is reported, does a knowledgeable person in your firm review the findings to determine whether there are any legal issues in reporting the findings to the employer (as opposed to having the information entered by a court researcher)?
  9. When there is a criminal “hit”, do you contact the employer immediately to advise that there is a potential problem?
  10. Does your firm take measures to ensure that ALL legal and relevant criminal records are searched, as opposed to just going back “seven” years?
  11. If a client orders a “multi-jurisdictional” database search, do you re-verify any criminal “hit” at the courthouse level for maximum accuracy, instead of relying on notifying the applicant of a potential hit? 
  12. Do you notify your clients of changes in the FCRA and other applicable laws?
  13. Do you at least, on a yearly basis, conduct an internal FCRA compliance audit?
  14. Do you offer international background checks? If “yes,” please describe
  15. Is your firm “Safe Harbor Certified” to perform screenings of applicants from the EU (European Union)?
  16. Do you have data protection, privacy security and data breach policies?  If so, please provide information.
  17. Are you a member of the background screening trade association, the National Association of Professional Background Screeners (NAPBS), and does your firm actively participate and support professionalism in the screening industry?
  18. What is your average turn-around time?
  19. If there is a delay for reasons that are out of your control, are your clients notified online with in-depth notes and the anticipated ETA of information?
  20. Are your clients provided with written documentation and resources on safe hiring, due diligence and legal compliance issues?
  21. Are your clients provided with upgrades in technology that would enhance workflow, such as the ability to have applicants consent online or integration with an ATS or HRIS system?
  22. Please describe your initial training program for team members that work on our account, as well as any ongoing training.


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