As the gloriousness that is the beginning of 2016 gets underway, the business world faces projects galore. From year-end-payroll, to office-wide file-backups (Australia has a great year-end checklist here), all the way to planning/holding strategy meetings for the coming year, these important projects have a way of sneaking up on us as the New Year starts gaining momentum.

Among this veritable ocean of priorities is the need for companies to fortify their hiring processes for the years to come: a business is only as good as its employees, and this time of year is great for taking stock. With specific regards to pre-employment background screening, it is vital to evaluate the existing practice and make sure the essentials are covered.

What’s more, once the pillars of a solid screening process are firmly in place, it becomes a piece of cake to enhance the overall effectiveness through augmentation designed to build upon the initial pre-employment screen, making it easy for businesses to keep tabs on employee records well beyond the initial screen.

Rescreening employees on a regular basis is one of these augmentations: this simple addition not only works to provide companies with information over the course of employment for all staff members, but implementing a rescreening schedule also helps companies go beyond the bare minimum of only screening employees at the beginning.

Rescreening considerations:

  1. Language:
    Language designed to specify the rescreening policy must be included in the consent form / applicant authorization. This works to clearly define for prospective employees the possibility of conducting additional screening at any time during the term of employment. Note: if adding this as a new policy, existing employees may need to sign a new consent form as an official acknowledgement of the change.
  2. Cost: 
    As this type of screen does not necessitate running the full scope of a standard background screen (7 years tends to be the norm, but may differ based on industry requirements), the overall cost is often reduced significantly from the initial screen.
  3. Set-up and Scheduling:
    Depending on the needs and preferences of HR and the company as a whole, the process of getting the rescreen schedule off the ground has a few things to consider:

    • The rescreen policy itself must be written into the official hiring P&P for the company and run by legal counsel if appropriate before moving forward with the actual rescreens.
    • After the P&P manual is updated, the decision has to be made with regards to setting the overall frequency and scope. For example, HR could choose to run company-wide rescreens on an annual basis and set the scope back to the individual’s last rescreen.
    • The inaugural rescreen will have additional one-time considerations, such as screening back to the original hire date for employees already on the books.
    • After the first rescreen is performed, it becomes a simple matter to leapfrog the screens back to the last rescreening occurrence.
    • For the rescreening schedule itself, it is up to the discretion of HR and the possible need for the company to adhere to industry standards (see below). This schedule could be set on an individual employee basis for set time frames after their initial hire date—after 90-day probation, for work anniversaries, etc.—or again this could just be a company-wide event every 6 months, every year, and so on.
  1. Industry Standards:
    Various industries, job types, and their regulatory agencies—government, industry-specific, international, and otherwise—have requirements which necessitate regular and varying levels of rescreens for these types of employees. This list is by no means exhaustive, but here are a few common examples of industries and company types commonly associated with rescreening procedures:

    • Government:
      Vendor contracts and the vendors’ employees often have to pass more stringent background checks when fulfilling government contracts, which can lead to the need for rescreens.
    • Financial:
      Underwriters, mortgage lenders, banking positions, etc., and especially anyone who is licensed to have regular access to the sensitive information thrown around in the financial industry. A common rescreening practice for these companies is to make sure their employees have not found themselves on exclusion lists, such as those housed by the FDIC, FRB, OCC, and the NCUA to name a few.
    • Healthcare:
      Any and all medical-based positions and licenses should be routinely checked for disciplinary actions against an individual, as well as medically-based exclusions databases (such as the one stored by the OIG)
    • Transportation:
      Employers who have positions requiring regular access to company vehicles and equipment can benefit from a regular screen of at least their employees’ MVRs. This, combined with a solid random drug screening practice, can help to create a working environment characterized by ongoing preventative strategy.
    • Education:
      Solid rescreening practices are crucial to those whose jobs require regular interaction with vulnerable populations such as children. Teachers and volunteers are just two of the positions in education to monitor on a regular basis to make sure their records are staying clean.
Referenced Works and Resources

New Year’s Eve 2015 live: Fireworks and pictures from around the world as we welcome in 2016
Essential tasks at End of Financial Year (EOFY)
New Year Business Marketing Plan & Annual Strategy Goal Update
5 Action Steps You Can Take Today to Protect Your Business From Discrimination Lawsuits
NationSearch Blog: See the Difference, Rescreen.
Why Re-Screening Current Employees is Important
NationSearch: Disclosure Regarding Background Screening
4 Ways To Improve Your Hiring Process