PlusOne Solutions’ Michelle Leblond Announced as Chairperson of PBSA Board of Directors

Michelle Leblond, Executive Vice President of Compliance and Privacy at PlusOne Solutions is the new Chairperson of the Professional Background Screening Association’s Board of Directors.

Her one-year term officially commenced following the formal announcement during the 2020 PBSA Annual Conference, which was held virtually this year.

After joining PBSA more than 10 years ago when the Canadian Chapter was forming, Michelle’s involvement with the organization has been both progressive and global in nature. She has worked at the Committee and Leadership level within the Canadian Chapter including leading the Government Relations Committee (Canada), as well as on the Background Screening Credentialing Council (BSCC), Global Advisory Council and Membership Committee before joining the Board more than five years ago. Her new role will be focused on the governance and oversight for the Association which counts over 815 member companies and 6,000 individual members around the globe.

“Being the first global Board Chair for our industry Association is an honor and a responsibility that I am excited to take on,” Michelle said. “The pace of technology, the importance of our work in protecting our workplaces, homes, and communities, and the evolution of regulation, demands a dedicated and passionate advocate to represent our members and work with an equally talented Board of Directors. I welcome the opportunity to bring the same energy and motivation I have shown in my work at PlusOne Solutions to PBSA as it continues to realize its mission to become the trusted global authority for the screening profession. I am privileged to support an Association whose mission it is to advance excellence in the screening profession and my unique combination of operational, technical, data privacy and compliance skills make PBSA well suited to deliver on our strategic goals to educate, advocate and impact legislation in the best interests of our members.”

In addition to her 25 years of experience in the background screening industry, Michelle is also a current member of Human Resources Professionals Association (Ontario), Society for Human Resource Management, and International Association of Privacy Professionals. She also holds Certified Information Privacy Professional (CIPP) designations in both the U.S. and Canada.

“The PlusOne Solutions team is honored that Michelle has honed her experience and drive to lead PBSA to new heights in which every organization in our industry will benefit,” said Craig Reilly, Founder and CEO of PlusOne Solutions. “With Michelle’s leadership and her knowledge of the global stage, Michelle energized our company by developing new programs to raise our compliance, privacy, and security disciplines and driving us to meet the highest standards in the industry. We’re excited to see just how high Michelle can elevate our industry through her role with PBSA.”

 

About PlusOne Solutions

For more than 15 years, PlusOne Solutions has been an industry leader in the risk management field by specializing compliance programs that meet the complex challenges of geographically dispersed contractors, vendors, and employee networks. PlusOne Solutions protects companies from possible financial, legal, and reputational risks associated with contractor and vendor relationships while creating safer work environments for everyone and is an Accredited Background Screening Agency by the Professional Background Screening Association.

 

About PBSA

Founded as a non-profit trade association in 2003, the Professional Background Screening Association (PBSA) was established to represent the interest of companies offering employment and tenant background screening services. Just as importantly, however, the initial members wanted to establish and promote a high level of ethics and performance standards for the screening industry. The Association currently represents over 815 member companies engaged in employment and tenant background screening across the United States. Member companies range from Fortune 100 companies to small local businesses, conducting millions of employment-related and tenant background checks each year as part of the hiring and leasing process. PBSA Member companies are defined as “consumer reporting agencies” pursuant to the Fair Credit Reporting Act (FCRA) and are regulated by both the FTC and CFPB.

 

 

Contents are provided for information purposes only and should not be construed as legal advice. Users are reminded to seek legal counsel with respect to their obligations and use of PlusOne Solutions services.

 

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Interested in learning more about our compliance services? Contact us at (877) 943-0100 or send us a message using the form below.



PlusOne Solutions now offering driver record searches in Canada

PlusOne Solutions, a compliance and risk management solutions specializing in contractor networks, announced the expansion of their driving record search service to Canada*.

Officially called Motor Vehicle Reports (MVR), driving record searches provide companies the opportunity to confirm eligible drivers have an active license. Since anyone driving for a company could potentially put the organization at risk, MVRs help distinguish between safe drivers and potentially unsafe drivers.

“Before you let an employee or contractor get behind the wheel of a company car, it’s a good idea to run an MVR search to ensure they are a safe driver,” said Michelle Leblond, EVP of Compliance & Privacy at PlusOne Solutions.  “Expanding our driving record search service to Canada will allow our Customers to mitigate the risk of hiring and contracting drivers.”

The MVR search includes the class of the license, citation history, accident history, suspension information, license restrictions, and the current status of the driver’s license. The search scope changes depending on the individual jurisdiction; however, the search will go back at least three years but could potentially show more historical information depending on the province.

“We’re excited to offer our MVR search service in Canada and to continue helping more companies commit to safety on the road,” Leblond said.

*MVR Search is not available in Alberta.

 

About PlusOne Solutions

For more than 15 years, PlusOne Solutions has been an industry leader in the risk management field by specializing in compliance programs that meet the complex challenges of geographically dispersed contractors, vendors, and employee networks. PlusOne Solutions protects companies from possible financial, legal, and reputational risks associated with contractor and vendor relationships while creating safer work environments for everyone. To learn more, visit http://www.PlusOneSolutions.net.

 

For more company news, read the past announcements:

 

Contents are provided for information purposes only and should not be construed as legal advice. Users are reminded to seek legal counsel with respect to their obligations and use of PlusOne Solutions services.

 

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Interested in learning more about our compliance services? Contact us at (877) 943-0100 or send us a message using the form below.



What is in a Name? Millions of Dollars in Settlement Funds, Apparently!

Those with the last name Smith, Williams, Reilly, or even Clark know they are unique, even if their names are not.

The challenge with background check reports, however, is that they rely heavily on names. People with more common names are at a higher risk of getting caught in situations where background screening results are issued with little to no regard for the complete and accurate confirmation of whether the record belongs to the correct individual. This means criminal records can potentially be reported incompletely or worse, incorrectly, on an individual who is completely unaware of the implications of such an error.

 

Identification Process for Background Checks

When working with a Consumer Reporting Agency (CRA), it is important to know how they handle the identification and review process for names and what their matching criteria are for reporting criminal records. Attributing a record to an individual who does not have a criminal background, or worse, missing a record that does belong to them can have significant adverse impacts on their eligibility for contracts, employment, and their life overall. This record matching process is important with unique and novel names but becomes increasingly relevant when dealing with a common name like those noted above.

 

FCRA Regulations Promote Accuracy

CRAs are required under the Fair Credit Reporting Act (FCRA), to have practices in place to assure maximum possible accuracy when reporting records and reviewing results in a consumer report. This means that when a record is received, standard operating procedures should require the review of all identification data – names, date of birth, address, or other identifiers – to confirm whether the information in the record does indeed belong to the individual being screened. Although the FCRA contains provisions for disputing incorrect information before any adverse action is taken, this is not the failsafe CRAs should use for confirming their records. It is not up to the individual to prove a record is not theirs but rather on the CRA to provide sufficient evidence that it is the same individual.

Additionally, if the individual has a name identified as common by the U.S. Census, additional steps should be taken to confirm the individual’s identity as there is an increased likelihood of a false record being attributed to them.

 

Ways to Identify the Individual Being Screened

In a typical policy, a CRA may use at least two identifiers as their criteria for matching.

  • First/Last name match – counts as one identifier only
  • Full Date of Birth
  • Address Match – this can be current or previous addresses
  • Full or partial Social Security Number (SSN) match

When dealing with common names, the threshold raises to at least three identifiers which may include the following, in addition to those noted above:

  • Middle name / Initial
  • Alias names or Nicknames provided in the record or with the submission
  • Demographic information provided on the record
  • DL number
  • Other personal identifiers (scars, tattoos, hair color, etc.)
  • Partial date of birth

 

Interestingly, while the focus tends to be on using the above criteria to confirm the individual’s identity, a fulsome policy should also use the same information to negate the individual. For example, if the individual’s name is Chris Clark and they are known to be a female with the full name Christine Clark, if any information returned to indicate this individual is a male with the name Christopher, that is sufficient to determine that there is not a match and the potential record should not be attributed to that individual. This use of data to confirm the individual is not the same is often overlooked by CRAs and in many cases creates the matching problems that result in litigation and significant settlements.

 

Tips to Improve Quality and Accuracy of Background Screening Results

So how can an organization improve the quality of the results they receive and reduce the chance they will find themselves in such a predicament? When submitting screening requests, an organization should:

  • Submit all known legal names
  • Review spelling and order of names for accuracy
  • Provide complete names, including middle names or at least the middle initial – or indicate NMN (no middle name) when no middle name exists
  • Confirm Date of Birth provided is accurate and day and month have not been transposed
  • Ensure accurate entry of SSN information as it will pull associated names 

 

In addition to improving the data entry of background screens, work with your CRA to understand their matching criteria and operational processes. When submitting requests, ensure you include a Person/Identity Search in your package. This search will pull any names and addresses as well as dates of birth, that have been associated with the SSN provided. This can be very useful when reviewing criminal records which may contain references to previous names or addresses. It also serves to verify that the name(s) and date of birth that have been submitted are accurate and consistent. The CRA should review this Person/Identity Search information for discrepancies and amend the order and demographic information as needed to ensure a complete and accurate search is being conducted.

 

One last consideration is how much automation is used in the review of records and the way results are evaluated. Several cases have arisen lately indicating that while automation does have its benefits, the risks inherent in using only algorithms and static rules needs to be balanced by a manual, in-person review of data. The most prudent approach uses a combination of technology and people to review records for accuracy, and not return that burden to the individual being screened or the organization requesting the information, to clarify any issues.

 

As you can see, “John Smith” takes on a whole new meaning, with notably increased risk exposure, in the background screening world!

 

Contents are provided for information purposes only and should not be construed as legal advice. Users are reminded to seek legal counsel concerning their obligations and use of PlusOne Solutions services.

 

To learn more about background checks, read these blog posts:

 

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Quarterly Compliance Update, Q3 2020

CA Licensing Reform and Criminal Records, compliance during COVID, and FCRA training are all included in this quarter’s compliance update.

Each quarter, PlusOne Solutions provides a compliance update to keep you abreast of changes and updates in legal developments as well as company news. This information is provided for education only and does not constitute legal advice.

Maintaining Compliance and Delays with COVID-19

Throughout the last six months, PlusOne Solutions has continued to work with Customers to ensure strong compliance levels. We have recently seen a lot of the courts reopen and drug labs resume more fulsome hours of operation. Much of the backlog of delayed criminal record checks have now been completed. We continue to encourage any individual that needs to be rescreened to submit their background screening before the expiration date, the individual will continue to report in compliance.

For unique situations or additional questions, please contact us at screenings@plusonesolutions.net for more information.

 

CA Licensing Reform and Criminal Records

Effective July 2020, California enacted AB-2138 which is designed to make it easier for residents with criminal records to obtain professional licenses from 37 agencies within the Department of Consumer Affairs (DCA). In this state alone, 30 percent of all jobs (1,773 different occupations) require licensure, certification, or clearance from a DCA oversight board or agency. DCA boards have licensing authority over many professionals ranging from medical doctors, nurses, and pharmacists to accountants, architects, contractors, engineers, auto mechanics, and hairstylists.

Among the guidelines are strong reminders for any hiring / contracting decisions:

  • Restricts the discretion to use prior criminal history as grounds for denying a license.
  • Criminal convictions older than seven years may not be the basis for licensure denial.
  • A criminal conviction must be “substantially related” to the qualifications or duties required by the license or profession to deny, revoke, or suspend a license.
  • Licensing boards may no longer deny licensure due to a conviction that was expunged, dismissed, pardoned, or if the applicant made a showing of rehabilitation for a felony conviction.

This move is designed to provide more opportunities for individuals with criminal histories and support their re-engagement into society. In many cases, the nature of the record is not relevant to the role they will hold and for this reason, the record creates a barrier to productive contribution to society.

 

 

FCRA Training 2020 Reminder

PlusOne Solutions has sent out its annual training module for all Customer users regarding the Fair Credit Reporting Act (FCRA). This training covers the basics of the law, the responsibilities of requesting and using consumer reports as well as obligations for the destruction of information. Please watch for this notice and complete the training.

Why does this matter? As a Professional Background Screeners Association (PBSA) Accredited agency, PlusOne Solutions requests an annual certification from Customers to ensure their partnership in remaining compliant with FCRA obligations. Completion of this training constitutes certification and keeps Customer users updated on their obligations when using consumer reports.

 


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Clear and Transparent Background Screening Programs Help Protect Companies, Networks and Consumers

Rolling out a background screening requirement as part of your Contractor Compliance Program is only successful if it is understood, transparent, effective, and adhered to. Recent news has again highlighted the challenges that can arise when background screening programs are too complex, misrepresented, or rely on an “honor system,” versus independent validation, to demonstrate compliance. Further, if your organization is asked by the media, an attorney, or even an individual being screened about your program, you better be sure you have answers at the ready. The past 15 years of working with thousands of contractor servicing companies has taught us a few things that we would like to share.

 

Background screening is a key component to a Contractor Compliance Program, but if you can’t prove it was done, the program loses its value.

If those responsible for the program cannot explain or verify the program’s effectiveness, the ensuing reputational, operational, and litigation risks can be insurmountable. Compounding this confusion and lack of knowledge is the detrimental impact such an issue can have on consumer confidence for your organization. There is a definitive expectation by consumers that when they engage with a known organization – retailer, manufacturer or servicing company – they will be safe. This extends from the known entity, through to all their contracted partners.

Offering complicated packages or searches that will not meet the needs of the contract help no one. Not only are there federal and state laws that govern the clear disclosure to the individual being screened of what and why searches are being done, but also companies can’t just claim screenings are being done. Companies need to be able to provide definitive proof that background screenings have been done.

When setting up a background screening program, a Customer will establish the key searches and requirements that must be met, such as:

  • What type of criminal check?
  • Will driving checks be needed?
  • What about drug screening?

Understanding the benefits of the different services, what information they do or do not contain, and their proper definitions are an important part of establishing a successful compliance program. A formal compliance program should be structured to ensure the required screenings are conducted and individuals are screened to the correct requirements. To read more about our screening components, check out our article Anatomy of a Background Check.

Clear communications at the outset of the Compliance Program to ensure compliance, and then proactive notices to ensure continued compliance according to the needed rescreen schedule are two valuable ways to strengthen your program.

 

 

Define ‘Background Screening’

To simply say “all our techs are background checked” leaves a lot to the imagination. The average individual isn’t likely to know the different types of background searches , so it is incumbent on the company claiming to do background screens to be clear, descriptive, and open about how they define background screening.

 

About 90 percent of homeowners assume in-home service providers passed a background check, according to a survey conducted by Mindspot Research. While the general expectation is that consumers expect anyone coming into their home to have been background screened, hanging your hat on that assumption is not an acceptable approach for any company. Clear and readily available descriptions of exactly which background checks are conducted on a service network are the best approach to guard against misrepresentation or misunderstanding when it comes to background screening. Understanding the role the individual will hold and whether they will be in consumer homes and unsupervised will also impact the nature and type of background screening.

 

Transparency is Key

The correct consumer reporting agency partner should provide transparency to all players in the contracting lifecycle – the Customer, the contracting company, the individual, and even the consumer – to see the status of a screening. The nature of the searches being conducted, as well as what is required and what is optional, is clearly outlined for the individuals being screened so they are aware of what will be done and can relay that information to anyone who may ask. Working with service networks on the rescreen schedule to ensure screenings are redone at the appropriate timeframe and there is no lapse in coverage should be a joint effort between your organization and any partner you engage with. Any partner should also provide sufficient written materials and support to help you explain your program, answer questions about the searches you do, and remain responsive to any queries.

 

Know your program, follow your program, and enforce your program – that is the best way to have a successful Compliance Program.

 

Contents are provided for information purposes only and should not be construed as legal advice. Users are reminded to seek legal counsel concerning their obligations and use of PlusOne Solutions services.

 

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If you have any questions about screening compliance, we are always happy to help. Contact us for answers at customercare@plusonesolutions.net.



11 Ways to Improve Service Network COI Management

Protecting your organization when working with third-party contractors can be complicated. There are many pieces that must be managed to protect both your business and the business of your contractor.

Many things can go wrong when ensuring that you have properly mitigated your risk through the management of certificates of insurance (COIs) and your compliance program. Confirming proper coverage and requirements, missing or incorrect COIs, proper communication and enforcement can be a challenge.

The following suggestions cover the most common problems found in the collection, evaluation, notification, management, and monitoring of COIs along with tips on how to avoid them. If you are looking to focus on the importance of proper insurance coverage and learn some best practices for mitigating risk in your contractor network, then you’re in the right place. Keep reading.

 

 

1. Establish Appropriate Insurance Coverage Requirements for your Network

 

Having a COI in hand does not necessarily mean you have properly protected yourself against risk, and one size does not fit all scenarios across your business.

Determine the relative risk that each contractor may pose, then develop insurance coverage guidelines aligned with the nature of the risk, the type of work they will be doing and best practices for the industry. There may be different insurance coverage requirements and limits if a contractor is working on different programs for you. Being able to identify this and create standard requirements across program is important. Also, you will want to find the right balance between keeping operations flowing and protection. As such, you will want to work with your operations team and what they hear from the network as well as consult with your insurance broker and/or risk manager to determine proper coverage. You will find that both will pull you in opposite directions, this is where you may need to strike a balance.

 

 

2. Ensure that the insurance requirements are in the contract or agreement

 

Once you have established appropriate insurance coverage, make sure that it is stated in your contractor agreement.

This will be your best line of protection if you find yourself in a lawsuit or claim. Ensure that you have done a review of older agreements with existing contractors and that you have an executed agreement with your current insurance requirements. An updated contract may be necessary at this point.

 

 

3. Ensure Coverage is in Place Before the Insured Begins Work

All too often vendors begin the job before you have received all the necessary paperwork. Not only does this demonstrate your lack of seriousness about the issue but it puts you at great risk and eliminates any leverage you may have over the contractor to get the required documents. If you are already giving them the work, why should they bother to provide the COI? It is important to establish a formal, consistent procedure for processing all COIs from the contractor before work begins.

 

4. Enforce the Rules for Insurance Coverage

A contractor who is currently in your network but not compliant with the insurance coverage needed should be addressed immediately. Any gap or lapse in coverage exposes your business to risk.

Review how often the contractor works for you and consider the type of work being completed to determine the level of risk you are exposed to. For high volume, high-risk work, you will want to ensure that the contractor consistently comply.

When you have a network of contractors, minimizing gaps in coverage means lines of communication must be established with your contractors, written expectations for appropriate coverage should be provided and procedures should be in place to make certain the contractor responds and complies with your requirements. Without enforcement of your policy and procedures, your program is not protecting you and puts the reputation, financial and operational wellbeing of the organization in the hands of your service network.

 

5. Make Someone Responsible for COI Management

Insurance coverage is not a “one and done” effort that you complete when engaging a contractor in your network and then never revisit. The COI process is something that needs to be actively managed.

Because this process can be menial or other priorities take the forefront, it often doesn’t get the attention it deserves. COI management includes the collection of the COI, confirmation that the contents, coverage, and policy information meet the contractual requirements, that the proof of insurance isn’t fraudulent, random rechecks to ensure coverage presented at onboarding remains correct and in place, and then reminders and recollection of the data at the end of each expiration period. Designate a specific individual, or individuals, to take possession of this important business process and hold them accountable for ensuring they meet standards.

 

6. Understand Certificates of Insurance and Declaration Pages

Does the team managing your compliance program know the difference between auto combined single limit or split limits? How about cargo versus bailee coverage or garage liability versus garage keepers? Whether these coverages apply to your network or not, being able to understand applicable limits, policy types, endorsements, and other insurance information is critical to knowing whether or not the documentation provided fulfills your requirements and provides the coverage that you need to minimize risk.

Ensure that the team managing your program is trained to understand the nuances of insurance. Consider consulting with your company’s insurance broker, risk manager, or a COI management company to gain knowledge on how and what to identify when processing proof of insurance such as certificates and policy declaration pages.

 

 

7. Understand Additional Insured Endorsements

As well as the standard policies and coverage limits, you may also need to understand additional insured endorsements, such as completed and ongoing operations or broad form vendor.

Both endorsements contain sections to be completed by an insurance underwriter (not the insurance broker or agent) to define who the additional insured is and under what circumstances. These endorsements alter the coverage provided in the insurance policy. Compliance with requirements can be at risk if the appropriate language and endorsements do not fulfill the policy requirements.

A review of the full insurance documents is required to ensure requirements are being met. This should be done by someone who has knowledge and experience in reviewing endorsements.

 

 

8. Obtain Renewal COIs Before Expiration

COIs expire at the end of the policy period and they must be reissued for another period. A period is typically one year but may vary by coverage or provider.

Obtaining this documentation is part of the active management of the COI process, as noted earlier. It is also important to ensure coverage is in place to cover the entire time a contractor is working on a job. Helpful reminders and working with the contractor and Agent/Broker directly yield much success as the Agent/Broker has a vested interest in ensuring the proper policy is in place and the contractor is likely too busy with their operations to handle the nuances of the coverage they need.

Do you have a system in place to monitor this important information and act upon it? Is it working? These are important questions to ask yourself if you’re looking to improve your company’s COI management.

 

9. Keep COIs Even After They Have Expired

When a policy expires and is replaced by an updated policy, retention of the previous policy is still very important. You may need a copy of that expired COI to prove the insurance was in place to protect you against the claim and help you recover damages. It also provides the necessary information on which carrier to contact. This further supports the concept that insurance is a management program and an ongoing process.

 

10. Measure Progress

Can you evaluate the success of your current COI management program? How successful are you at renewals and compliance metrics? If you cannot answer that or don’t know how you’re doing you probably aren’t doing the best job possible. Compliance rates will change over time, but a fulsome and efficient program will ensure that those changes result in increased compliance levels.

 

 

11. If You Can’t Do It, Partner with Someone Who Will

There are a lot of moving parts to COI tracking, and you need a certain level of insurance knowledge and discipline to do it properly. Be honest about your capabilities, the time and expertise you have available to dedicate, and whether this is something you want your organization responsible for.

Following these basic steps can make all the difference between best-practices of risk transfer versus potentially catastrophic risk exposure. In our litigious and media-driven society, proper insurance coverage, and a solid insurance management program is an important way to mitigate the risk of engaging the services of an uninsured or underinsured party.

 

Contents are provided for information purposes only and should not be construed as legal advice. Users are reminded to seek legal counsel with respect to their obligations and use of PlusOne Solutions services.

 

To receive these updates directly in your email inbox, sign up for the newsletter

 

Interested in learning more about our compliance services? Contact us at (877) 943-0100 or send us a message using the form below.



Using Your SSN as a TIN Puts You at Greater Risk of Identity Theft – Use an EIN instead

Every day companies share the owner’s personal information, including Social Security Numbers (SSN), personal names, and home addresses. This kind of information is vulnerable to identity theft and not protected in the business world.  Fortunately, there is a safer way to go about this.

Instead of using the SSN as your Federal Tax Identification Number (TIN), you can use an Employer Identification Number (EIN). This better protects you, your business, and your commercial dealings with others.

Keep reading to learn more about the benefits of using an EIN.

Privacy Protection and Federal Tax Identification Numbers

Sole proprietors, smaller family-owned businesses, and Single-Member LLCs typically use their SSN as their TIN. When the SSN is used as a TIN, all the protections of federal or state privacy legislation are lost as privacy legislation is designed to protect individuals, not companies. Company information does not have the same protections as personal information, even when it is your personal SSN. Companies that use the owner’s SSN for business identification are freely and willingly sharing information that can be used for identity theft and is no longer protected under these federal or state privacy laws.

Privacy protection of a SSN is meant to reduce personal identity theft, protect your personal assets, and keep information confidential. If your SSN or personal information is compromised at any time, replacing the number, and correcting the damage can be a time-consuming and administrative nightmare. If you are still using your SSN as a TIN, this brings unnecessary risk to you personally. Fortunately, there is a simple and quick alternative to protect your personal information – the EIN.

What is an Employer Identification Number (EIN) used for?

Individuals can eliminate their risk of sharing personal information via the business by using an EIN instead of an SSN. EINs are provided free of charge from the IRS and are used by companies to protect the privacy of an owner’s SSN and other personal information.

An EIN is the most used TIN by companies who employ individuals. However, you do not need to have employees to utilize an EIN. An EIN is not linked or associated with your SSN. As such, it provides additional personal privacy protection by using a different number than your SSN for reporting purposes. You can easily apply online for the EIN through the IRS.

In addition to privacy, there are other advantages to obtain an EIN. You may discover later that you need one – mainly if you plan to expand or restructure your business to a corporation and/or hire employees. If you form a corporation later, you will need an EIN. You also need an EIN when your organization issues employee-related tax forms, such as W-2s. Employers are required to issue W-2s to their employees after the end of each tax year. All payroll-related reports contain your EIN – including monthly, quarterly, and annual tax forms, whether completed by your business or another provider. Not only will your business need an EIN for various purposes, but your employees will also need it when they prepare their tax returns.

Here is how you can get your EIN:

  • By phone:(800) 829-4933 / 267-941-1099
  • By fax or mail:You can find Form SS-4 here and locate the fax number and mailing addresses for your location on the IRS website.
  • On the IRS website: IRS Website EIN Link  You can file the SS-4 form online or participate in an “interview-style” live chat that will ask you questions and issue you a EIN if you require one.

How long does it take?

  • By phone: immediate
  • On the IRS website: immediate
  • By fax or mail: up to 4 weeks

Other common tips to protect your SSN:  

  • Ask why and how the SSN will be used or handled
  • Leave your SSN card at home, not in your wallet
  • Shred mail and documents with personal details that include your SSN
  • Never use your SSN as a password.
  • Monitor bank and credit card accounts
  • Monitor your credit report and any changes

 

Additional Resources:

Contents are provided for information purposes only and should not be construed as legal advice. Users are reminded to seek legal counsel with respect to their obligations and use of PlusOne Solutions services.

 

To receive these updates directly in your email inbox, sign up for the newsletter

 

Interested in learning more about our compliance services? Contact us at (877) 943-0100 or send us a message using the form below.



What is the Fair Credit Reporting Act (FCRA)? Everything You Should Know

What is the FCRA?

First enacted in 1970, the Fair Credit Reporting Act (FCRA) is comprehensive federal legislation to regulate the collection, dissemination, and use of consumer information. This legislation is the basis of consumer rights in the U.S. and no additional comprehensive privacy legislation yet exists. For this review, we will focus on consumer reports for employment purposes.

 

What is a Consumer Report?

A consumer report is a written, oral, or other communication from a consumer reporting agency (CRA) that reflects a consumer’s creditworthiness, credit standing, credit capacity, character, or general reputation. This information is obtained by entities for eligibility for personal credit, insurance, employment, or other purposes authorized by 15 U.S.C. § 1681a(d). This report can also include criminal and civil records, driving records, civil lawsuits, reference checks, and other information.

A consumer report is much broader in scope than just a credit report or a background check. These reports shared among subsidiary and parent corporations are still protected by the FCRA legislation.

 

Roles in the FCRA Applicable to the Employee / Contractor Screening Process

Consumers – Are individuals, not corporate entities, about whom the report pertains. The individuals we background screen are considered consumers.

Consumer Reporting Agency (CRA) Any person which, for monetary fees, dues, or on a cooperative nonprofit basis, regularly engages in whole, or part, in the practice of assembling or evaluating consumer credit information or other information on consumers to furnish consumer reports to third parties, and which uses any means or facility of interstate commerce to prepare or furnish consumer reports. By this definition, credit bureaus, employment screeners, and tenant screeners are all CRAs. PlusOne Solutions is considered a CRA.

End User A person, or entity, that intends to make use of the information contained in a consumer report for a permissible purpose, under the Act. The employers and contracting Customers are considered End Users.

Furnisher Persons or entities who supply needed information to CRAs. Examples: Banks and other credit grantors.

 

Consumers Rights Under FCRA

Certain steps that must be followed before an entity gets a Consumer Report. Additionally, these steps apply before and after an adverse action is taken based on that report.

  1. Disclose on the nature and scope of the searches to be completed should be a single document that is “clear and conspicuous” and provided to the consumer before any consumer report being requested.
  2. Consent and authorization by consumers must be provided in writing.
  3. Maintain accuracy of reporting.
  4. Adverse Action Process, which includes A Summary of Rights and copy of their report.
  5. The process to dispute the accuracy or incompleteness of information.
  6. Provide access to copies of any report(s) or files held on them.

 

Responsibilities of CRAs, End Users, and Furnishers

Except for the consumer, who has rights under the FCRA as above, detailed below, each role has responsibilities:

  • CRAs – maintain reasonable procedures to assure “maximum possible accuracy” when reporting results per with guidelines; ensure a “permissible purpose” exists before releasing a consumer report; handle reinvestigations when consumer disputes results; make disclosures to consumers; proper disposal of information
  • End Users – ensure disclosure is made and authorization is obtained from the consumer; comply with pre-adverse/adverse requirements and provide certification to the CRA regarding the permissible purpose of the consumer report request.
  • Furnishers – must report accurate information and ensure reinvestigations are conducted in a thorough and timely manner.
Limitations on Report Contents

When CRAs are providing information in the final consumer report, there are some exclusions to be considered. For example, convictions can be reported indefinitely while arrest records and other adverse information (for example, negative credit data, collections, civil judgments) may be limited to seven years only. If an employee is reasonably expected to make more than $75,000, some of these restrictions may not apply. Positive information, which will not cause an adverse impact on the consumer, can be reported without limitation. These guidelines must be followed to ensure compliance. A CRA, such as PlusOne Solutions, must comply with these restrictions when reporting data to end users.

 

FCRA Enforcement

The Federal Trade Commission (FTC) and Consumer Financial Protection Bureau (CFPB) jointly share enforcement authority for the FCRA. The EEOC is not a player in the FCRA; however, they influence the contents of the consumer report from the perspective of Title VII and ensuring the information in a consumer report is not used in a discriminatory manner.

Since the FCRA is a federal statute, it is typically prosecuted in federal district court. Claims must be brought either within two years after the consumer learns of the violation, or five years after the violation occurs. Constructive knowledge is all that is required to start the two-year clock.

Additionally, no harm must be proven to file a lawsuit. As a result, “technical” violations of the FCRA, which do not result in an adverse action against a consumer, are now the subject of litigation.

 

Penalties and Plaintiffs

There are two groups of plaintiffs for FCRA actions – FTC/CFPB can bring enforcements and individual consumers can also bring lawsuits known as a private right of action. Adherence to these procedures is important because the FCRA provides for recovery of actual or statutory damages of $100 to $1,000 for each willful or deliberate violation of the statute, plus unlimited punitive damages. These penalties can result in significant settlement leverage for a case because the exposure for a company is potentially catastrophic.

The FCRA is a fee-shifting statute; so, prevailing plaintiffs can recover their reasonable attorney’s expenses as well. Plaintiffs have a right to a jury trial in FCRA cases; so, in most cases, the amount of damages is determined by the jury. FCRA errors are perfect fodder for one or more plaintiffs (also called class representatives) to bring a lawsuit on behalf of a group or “class” of people. Having a group of plaintiffs provides the potential for larger payouts and greater financial losses for non-compliant organizations.

Considerations Beyond the FCRA: State Regulations

The efforts to comply with the FCRA are important, but there may also be state consumer reporting requirements to consider as well. There are almost 20 states with some version, or overlap, of the FCRA rules or components of the legislation. Some of these requirements are preempted by the FCRA, but others may stand.

These state regulations include limitations on what, and how long, certain records may be reported. Additional limitations on reporting credit information, special disclosure or notice requirements, or needs such as offering free copies of reports to the consumer may exist. These laws are often quite detailed with exceptions based on positions being hired for, salary information, or job-relatedness requirements for criminal record reporting. States, municipalities, and even cities can have their versions of consumer reporting acts. While the FCRA is getting all the press these last few years, the state requirements should not be overlooked.

 

Why do our Companies and Customers Need to Know About the FCRA?

The FCRA requires organizations to follow certain procedures when using a consumer reporting agency to obtain a consumer report on current or prospective employees and contractors. When PlusOne Solutions is completing a consumer report on individuals in a contractor network for our customers, our work is regulated by the FCRA. There are obligations around the accuracy and reporting of data, ensuring appropriate disclosures are made and authorization has been obtained, confirming the purpose of the report and the reasonable purpose for obtaining the information in the report and other requirements. Working with our customers, we ensure the required steps are followed and that the consumer’s rights are upheld and respected at all steps of the process.

 

Additional Resources

 

Contents are provided for information purposes only and should not be construed as legal advice. Users are reminded to seek legal counsel with respect to their obligations and use of PlusOne Solutions services.

 

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Interested in learning more about our compliance services? Contact us at (877) 943-0100 or send us a message using the form below.



Anatomy of a Comprehensive Background Check

Background checks are an essential part of an organization’s employee onboarding process and contracting compliance program. If background checks are new to your organization, you may not know this key piece of information – not all background checks are created equal. Understanding the various components of a thorough background check will help you make an educated decision when choosing the right background check to fit your needs.

The information in this article will help you start down the road to selecting a background screening package while understanding the basic facts about what a background check is, why they are important, and the various searches that compose a comprehensive screen.

What is a background check?

A background check, or background screen, is a review of public record information about an individual. This information can be pulled for many reasons, with the focus of this article being for contracting or employment purposes.

The type of information included in a background check is called a “search” or “search components” and cover areas such as a criminal record search, a driving record search, basic identity confirmation, drug testing, government sanction and watch listings, or even a Sex Offender Registry search.

The screening results are then compiled into a report called a consumer report. The individual whom the background check pertains is the “consumer.” That data is then given back to the end-user who will review it and make the decision on how to proceed, which is often a decision of whether or not to hire/contract with the individual. The decision to be made is predicated on whether there may be any risks associated with working with the individual, and also to verify if the information they have provided is accurate, complete, and appropriate for the role for which they are being considered.

There is a role for everyone; however, not everyone is suitable for every role. The focus needs to be on the risk an individual may bring to an organization, its customers, consumers, and the overall network.

How are Consumer Reports Regulated?

In the U.S., the results from a background check (the consumer report), its contents, and use are regulated by the Fair Credit Reporting Act (FCRA). There is no comparable consumer reporting legislation in Canada, however many of the same principles of consent, open access, ability to dispute the information, and other accountabilities are included in privacy legislation.  There are guidelines and regulations surrounding background screening that add another layer of regulatory compliance as well. The reference to compliance at PlusOne Solutions, for example, has two meanings – one related to the ability to meet the expectations in the contract with the Customer, (“compliance program”), as well as legal and regulatory compliance requirements.

While each Customer will ultimately have their own needs when determining the search components in a background screening package, there are some general criteria that most will include. Most commonly, a background check will include a criminal record check. Based on the jurisdiction of the screening – for example, the U.S. or Canada – the options available will be reflective of the criminal system structure of that area. For this summary, we will focus on the US options only as they are more varied.

Criminal Records Can be Checked at Various Levels

Criminal records in the U.S. are available at three different levels – county, state, and federal. Criminal systems for states across the U.S. divide crimes into several different categories depending on the severity of the crime. The major categories are infractions, misdemeanors, and felonies. For background screening purposes we focus primarily on felony and misdemeanors, as infractions, or violations of a rule or ordinance, are the least serious and are and are not consistently included in criminal record searches. The information used to search these three levels of criminal records is the individual’s name, date of birth (DOB), and address history. The information that is returned when a criminal record is located may include case number, charge classification (felony/misdemeanor), charge type, disposition, disposition date, and sentencing, or other penalty information.

The county-level search is a thorough search of records held at the county-level and is the most comprehensive and popular criminal record search ordered. This is where most records for an individual will occur as there are more than 3,000 county courthouses across the U.S. The depth of these searches is typically seven years of residential address history which means that for every county where the individual has lived in the past seven years, from today’s date, a county criminal record search will be done. The county-level criminal record search is considered primary source data and is the main source of information that should be used.

The state-level criminal record search is very similar to the county-level, though it may not be available in every state. The state search is an aggregate of the details at the county-level search; however, the statewide search is typically a database search – meaning that it is reliant on information provided to it from each of the counties. This often results in information that may be incomplete, out of date, or not as accurate as the information available at the county-level. When ordered, except for New York, the statewide should be in addition to a county-level search, not instead of a county-level search. Not all counties may be included in the state repository, and there may also accuracy and completeness concerns as noted previously. The benefit of this search is that it does cover a larger geographic radius than just the individual’s jurisdiction of residence. New York is a unique situation whereby its Office of Court Administration (OCA) is the preferred source of information and covers all counties in the state as the primary source search and by law includes all those jurisdictions. As a result, county-level searches are not conducted in NY, only the NY OCA search is completed. Other states do not have this same requirement in place and therefore gaps appear in the coverage and date available in the statewide database.

The federal-level search, unlike the county and state level searches, is done through another system that is compiled by the U.S. Government including charges prosecuted under federal criminal law in federal courts. This is not a national search nor is it a search of all the county jurisdictions across the U.S. The Public Access to Court Electronic Records (PACER) criminal record system covers 94 federal jurisdictions. Most states are divided into 3 or 4 federal jurisdictions, while some other states may only belong to one federal jurisdiction. Federal searches include crimes against federal employees, crimes committed on federal land, crimes that cross state lines, and other specific categories such as tax evasion, fraud, or embezzlement. This search is often ordered in addition to the county-level search and the scope focuses at least on the current jurisdiction of residence. One note is that due to federal rules of civil procedure, these records often have very limited personal information in them which makes matching of records more difficult.

National Criminal Databases

The national criminal database search is an additional criminality-related search that is also available, though its contents are not limited to just U.S. sources. This search is done using the individual’s name and DOB against a large database of the available county and state criminal information, the state reported sex offender records as well as fugitive, Department of Corrections, U.S. and international government databases covering numerous watches and sanctions listings. Records may be updated weekly, monthly, or on another timing schedule but vary from search to search. Since these records are from databases, the accuracy, completeness, and content are not considered direct source information and any information returned should be validated. Like the statewide search, the key benefit of the national database search is that it expands the scope of records beyond just the individual’s residential history. The other watches and sanction listings are also helpful to understand if there are other risks to consider that may not be uncovered with a criminal record search. Oftentimes, the national database search is offered on the market for a low price. Since it is a database search, the results (if any) return quickly. However, we caution Customers against solely using this search as the concerns of incomplete and often outdated information outweigh the value.

Sex Offender Registry Searches are Recommended

Most of our Customers are using a service network that is often inside homes and on-premises with little or no supervision, which raises other risks and concerns. For that reason, one of the most important searches to conduct across a contractor service network is a Sex Offender Registry search. Unknowingly putting a sex offender in a customer’s home is among the top scenarios our Customers are trying to avoid. The existence of registration on a sex offender registry is a defensible pre-adverse condition if job relevant. While the national database search includes aggregate data submitted from most state sex offender registries, a search of the individual against the U.S. Department of Justice, National Sex Offender Public Website (NSOPW) is also recommended. If a record is located, comparisons are made against criminal records and other database searches we have completed. Sex Offender Registry searches only report the individual’s registration as a Registered Sex Offender and may not contain the actual criminal conviction(s) which resulted in their inclusion on the registry. For that reason, we also recommend running records at the county jurisdiction when a sex offender registry is identified.

Identity Searches Verify You are Screening the Correct Person

Since each search is reliant on starting with accurate identifiers – name, DOB, and address – every background screening should include an identity search. This is a search of the demographics an individual provides against databases that may include credit bureau header information, USPS address forwarding, utility bill records, voter registration data, licensing and registration data, and various aggregate sources. Search results may return additional names, residential address history, and other reported dates of births associated with the subject. This will also confirm when and where the SSN was issued, that the SSN does not belong to a deceased person or was not issued before the DOB of the subject. Developed names, alternate DOBs, and addresses may be identified and used to identify other court systems to search.

PlusOne Solutions goes to great lengths to verify the identifiers that a background report is based on because if there is an error with that data, the rest of the report is also questionable. We use various sources to verify and validate all names – given, alias, and developed from other searches. DOB is a common identifier that can be changed by applicants to evade the location of records. Verifying that the day and month, as well as year, are accurate further reduces the chances of missing records and information and/or assuming the background of another individual with a similar name.

Driving Record Searches Provide Valuable Information

When the individual will be required to drive for the role they will be holding, whether their own or a company vehicle, a Motor Vehicle Record (MVR) search, as it is typically called, may also provide additional information. As well as providing driving history information, the MVR search is also very helpful as an identity tool. Since the MVR is issued by a government authority, it is often a reliable source of an individual’s proper and complete legal name. The record information also includes address, DOB, and other demographic information that can be used to cross-reference it to other data in the file. Depending on the customer PlusOne Solutions is working with, the driving specifics may or may not be of relevance. Some Customers want only to verify that an active license is in place while others may have a greater interest in reviewing driving infractions, incidents, and other related information.

In-Depth Comprehensive Background Checks Should Utilize Multiple Searches

Every search included in a background search serves a different purpose and provides different values. The approach we take at PlusOne Solutions is to consider the combination of searches to ensure the most useful and thorough search to protect our Customer’s network. This may include conducting two different sex offender checks, using national criminal database and county criminal records to improve the likelihood of locating records, and thoroughly investigating any discrepancies in identifying information used to conduct the searches.

There is never a guarantee that all records and negative information on an individual will be found, but a strong Contractor Compliance Program and demonstration of due diligence is a solid way to mitigate risk. A program will also not guarantee issues will not occur in the future but if an individual knows about the requirements, they are more likely to meet and respect them. Working with service networks already keeps Customers at least one step away from the individual doing the work on their behalf. Using the available public record information, and proper consent, to conduct a background check is one way to demonstrate diligence.

 

Contents are provided for information purposes only and should not be construed as legal advice. Users are reminded to seek legal counsel concerning their obligations and use of PlusOne Solutions services.

 

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To learn more about PlusOne Solutions or to discuss your screening program please call us at 877-943-0100 or fill out our contact form and someone from our team will reach out to you.



Marijuana Legalization and Drug Testing Your Contractor Network

Summary: Marijuana is becoming more popular across the US and its legalization is a trend that will only continue. Currently, it is still possible to drug test in all states although marijuana is considered a banned substance at the federal level. Marijuana is part of a panel included in all current PlusOne Solutions drug tests but testing positive is not an automatic barrier to participation in a service network. We work with the individual to ensure proper documentation to support legal marijuana use and focus on the safety risk associated with its overuse. This is an evolving topic and we will continue to monitor and respond to changes in legislation.


With 33 states having legalized medical marijuana and 11 states, and the District of Columbia, also legalizing recreational marijuana, questions are arising on how this may impact contractor networks. The landscape for organizations that drug screen potential contractors and employees is changing. The original intent behind the effort to decriminalize medical marijuana use was geared to individuals with serious and debilitating medical conditions where a physician prescribes the use of marijuana for therapeutic purposes.

While states may have taken a more lenient approach to marijuana, the reality is marijuana is still illegal at the federal level. It is still categorized as a prohibited substance under Schedule I of the Controlled Substances Act (CSA), 21 USC 801, et seq. for various reasons. This inevitably puts the states in conflict with federal legislation, giving rise to the current challenge for organizations on how to handle marijuana in their organization and testing practices.


 

 

 


Drug Testing for Marijuana in a State Where it is Legalized

Regardless if marijuana is legal or illegal in your state, businesses still have the right to establish a drug-free policy to maintain a safe work environment for workers and customers. However, this can change in the future, so we recommend staying informed on the latest news.

States allow organizations to maintain safe work and drug-free environments for their workers, contractors, customers, and others. This means they can enforce a drug-free workplace policy in the face of marijuana legalization. The organization is not required to accommodate the use of medical marijuana and they are allowed policies restricting the use of medical marijuana. The message in these situations remains that the individual may use cannabis on their own time but not while at work or while working for the organization.

 

How Does Marijuana Drug Testing Work?

The basic fact to be aware of is that drug testing is legal in every state. This means that even with the legalization of marijuana, testing is still permissible and in fact, is still very important. The reason that most of our Customers include drug testing in their compliance program is to determine if someone is under the influence of drugs. It is important to distinguish under the influence from the term impairment, the latter of which tends to be a legal classification. Drug testing cannot test for impairment. Instead, it tests for the presence of drugs in an individual’s system which when detected at certain levels, may impact their work performance.

The two natural compounds in the Cannabis (marijuana) plant. When we talk about drug testing, we are focusing on the detection of tetrahydrocannabinol (THC) and cannabidiol (CBD).

  • THC is the main psychoactive compound found in the marijuana plant that gives the high, as it is often called. THC can be consumed by smoking marijuana or found in oils, edibles, tinctures, capsules, and more.
  • CBD can be extracted and generally contains less than 0.3 percent THC and is not normally detected in the drug testing process. The strength of marijuana today is more potent than it was even five years ago and there is no consistent THC level in the various marijuana products sold.

The Department of Health and Human Services (HHS) has established specific cutoff levels that define a positive result for the workplace. When a specimen result is returned as “positive”, it means that the amount of drug(s) detected in the individual is above an acceptable cutoff level. These values were developed to help eliminate false-positive results (e.g. poppy seeds causing positive opium results, “second-hand smoke” claims). Values below the cutoff levels are reported as negative, which can lead to false-negative results. These values from the HHS were established for the workplace only and vary from other commercial settings where levels may be different. A positive test does not necessarily mean that someone is under the influence at that moment, but rather that THC, the high inducing chemical in marijuana, is still in the body.

 

Considerations – Who Should be Drug Screened for Marijuana?

This is a key question to ask when determining whether drug testing is appropriate for your organization – Is there is a health and safety risk if someone is under the influence of drugs while on the job? If so, individuals who are asked to operate vehicles, use heavy equipment, work with chemicals, or handle fuels such as electricity or gas, can create a significant safety risk to themselves and others. Performing any of these activities, or entering private homes and businesses, while under the influence creates a significant risk to the entire supply chain. When the presence of drugs would interfere with the individual’s ability to take adequate care in carrying out the job duties or pose an immediate risk of death or serious harm to themselves or another, the health and safety threshold has been met.

A drug test will screen for drugs currently in a person’s system at a level that would impair judgment and therefore possibly create a safety-related risk. Testing is not a commentary on someone’s activities outside of work but rather a means to ensure they are acting safely and responsibly while working. Driving while under the influence of alcohol, marijuana or any other controlled substance like a prescription could pose a significant safety risk not only to the individual but also to others around them.

 

How Should You Handle Positive Drug Test Results?

Every organization continues to have the right to test for marijuana and maintain a company policy outlining prohibited behaviors in the workplace. They also have the right to determine how, when, and what they test for as well as the consequences for policy violations. The position about whether an individual can have or use marijuana in the workplace should be clear. It should also be clear if the detection of any amount is a violation of policy.

The PlusOne Solutions operating procedure for Customers continues to enforce a strict, no-tolerance policy, meaning that any result over the acceptable cutoff levels must be substantiated. A written prescription, presentation of marijuana card, or other official documentation is requested when an individual tests positive for one of the controlled substances in a drug test. This is done to determine the individual is a legally authorized or registered user of marijuana. If such documentation can be provided, the individual is deemed to have met the compliance requirements. If documentation cannot be provided, they will be considered not authorized to work in the Customer’s network. This allows for the same reasonable accommodation requirements as those afforded individuals who may have other prescription drugs.

Some states are putting in protections for reasonable accommodations for medical marijuana users. By following the approach outlined above, PlusOne Solutions remains in compliance with those requirements and works to ensure Customers do not discriminate against an individual simply for being a medical marijuana user. These protections are evolving, and Customers are encouraged to monitor these changes as well.

 

Recommended Position

Any organization should carefully consider its position for drug testing in the workplace and ensure there is a valid permissible purpose for conducting testing, such as safety issues or other risks. Ensure that written job descriptions are accurate concerning the essential duties of the job and whether they are safety-sensitive and whether medical marijuana use can potentially be accommodated in the position.

Some considerations include the specific responsibilities of the role the individual will hold, whether the individual is operating a vehicle or heavy machine, and whether they will be working in private homes. These situations are all legitimate and justifiable reasons to have a drug testing policy in place.

Since marijuana is still illegal under federal law, most organizations have not changed their policies to accommodate these new state laws. While many states have either accepted marijuana for medical or recreational purposes, the tendency for most of our Customers is to defer to the federal level definition.

NOTE: The Department of Transportation’s Drug and Alcohol testing regulation – 49 CFR Part 40 – does not authorize the use of Schedule I drugs, including marijuana, for any reason.

 

Looking Ahead – How Will Marijuana Drug Testing Change in the Future?

There will likely be more recreational marijuana drug bills introduced, and possibly passed. Interested parties will continue to advocate for the federal legalization of both medicinal and recreational marijuana, although it is unlikely this will become law any time soon.

We will continue to monitor these activities and keep our customers updated.

 

Contents are provided for information purposes only and should not be construed as legal advice. Users are reminded to seek legal counsel concerning their obligations and use of PlusOne Solutions services.


 

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To learn more about PlusOne Solutions or to discuss your contractor screening program please call us at 877-943-0100 or fill out our contact form and someone from our team will reach out to you.