UPDATE: FCRA Compliance

Dear Clients,

Our friends at the Fair Trade Commission (FTC) are never far from our radar. As I’ve stressed before, compliance is critical and not optional.

Many states have limitations on the reporting period for criminal records allowed for employment suitability screening. Of those states that do, a few of them place the proposed salary as the determining factor of the limitation of the reporting period; i.e. above a certain income threshold the limitations are off.

When faced with this challenge in the past, an email was dispatched to the employer requesting the proposed income, therefore providing what we need to know. We have been advised by our legal counsel that by sending that request to an employer we unintentionally could be placing a seed of doubt in their mind about that applicant. That act then could result in an adverse hiring decision even if the record was not reportable because it did not meet the proposed income threshold.

Those states involved have a very modest income qualifier, orientated to entry and mid-level positions. Our corresponding packages targeted for those positions are our Basic Profile category. The solution for all variations of our Basic Profile packages is that you’ll be asked to list the proposed salary. The other packages in our product assortment do not have this requirement as they most likely represent positions beyond any income threshold currently in place.

Thanks for looking to HireSafe for your background screening needs. We really appreciate your business.

Al Firato
(916) 226-2550