Since there is usually a two-year timeframe between background screenings, Customers were searching for a solution to monitor potential criminal activity between these screening cycles. To add an interim and proactive element to the background screening process, PlusOne Solutions launched a new Continuous Background Screening program in late 2019.
After a full year of offering this ongoing background screening monitoring service to several Customers, we uncovered more than 550 criminal activity alerts on a network of more than 25,000 individuals.
Instead of just reviewing historical criminal record results like a traditional background check, continuous monitoring is the ongoing process of identifying criminal records. Continuous Criminal Monitoring provides notice within 24 hours of an arrest, incarceration, or booking event and allows Customers an additional layer of due diligence, and provides a way to identify potential behavior that may pose a risk to their business, consumers, or brand reputation.
Companies that rely on contractor networks of varying sizes are challenged with maintaining compliance throughout their relationship with a contractor. Although they conduct background checks on their network every two years, how do they know if something happens in the meantime?
Self-reporting options are a great addition to a contract but are often not enforced or followed. Changing the frequency and content of background screenings can be costly, frustrating, and time-consuming for both Customers and their service networks.
We have helped several of our Customers overcome this challenge. The companies range from different industries involving contractor networks, including two large appliance repair and service networks, the local delivery sector of an international appliance manufacturer, an energy consulting and installation organization, and a home warranty services organization. Combined, their programs include nearly 25,000 individuals.
These organizations joined the continuous criminal monitoring program because they were interested in knowing about potential risks within their network that may impact their reputation, increase their risk, lower network credibility, or the availability of contractors.
Once each Customer decided to include continuous criminal monitoring in their product suite, the implementation was efficient and straightforward as all data was already available to PlusOne Solutions.
Provided there is a complete authorization on file and the individual is both active and eligible, the population for each Customer can be pulled from our internal system and uploaded into the monitoring program.
In each implementation, aside from reviewing expectations around managing relevant alerts, there was little required from the Customer.
Continuous criminal monitoring is the ongoing process of using the individual’s name, date of birth, and social security number to access near-real-time incarceration data for US booking records from county jails and Department of Corrections facilities. By reviewing records on an individual, Customers may flag internal threats and safety concerns.
While not nationwide coverage, sources cover more than 90 percent of the population and are quickly filling a need for organizations to keep tabs on their service networks. The monitoring program also provides Customers another risk mitigation tool throughout their relationship with a Service Provider, and their techs, to ensure that the requirements of their contract are upheld, and consumer safety and property are protected. Each Customer maintained their regular onboarding, screening, and rescreening processes and added monitoring to that program.
Each alert is closely reviewed upon receipt to verify the alert is about the individual we are monitoring and not just another person by the same name. After, we review the nature and gravity of the offense and also cross-reference that information with our internal database to determine if the individual is still active in the network.
Due to the monthly timing of our populations and the constant changes that occur in the network, confirming the individual is actively working for the Customer is important before we proceed with verification of any monitoring alert.
If an alert is relevant to the individual’s eligibility in our Customer’s network, we will then proceed with ordering a county criminal record check for specifics. It is only when we have this direct source search completed that we truly know if we have a monitoring event that may require action. When that determination is made, we work closely with the Customer and review each alert on a case-by-case basis.
In a few very serious incidents, such as that noted below, we have worked with the Customer before this process is complete to provide the relevant information and updates.
During the last year, we have received more than 550 alerts on a combined population that numbers more than 25,000. While that may not seem like a large number, those alerts have been extremely valuable to maintaining and protecting consumers. The alerts covered approximately 440 unique individuals. Just like criminal records, some “repeat offenders” occur with monitoring as well.
Since the individuals being monitoring were employed and active in the service network and subjected to bi-annual rescreens, there was a general expectation that the arrest activity alerts would be minor issues. However, the nature of the alerts proved to be more significant than the Customers anticipated.
Among the most significant alerts, we have received are two felony first-degree murder charges. In one case, the individual was no longer in the service network at the time of the alert, however, in the other, the individual was still actively working service jobs.
This second case was crucial because the service provider, the individual’s employer, was not aware of the criminal issues, the situation, or what was happening. Although this was in the local media, due to pandemic restrictions and lockdowns, the individual had not been in the office or accepting many jobs. Given the severity of having a consumer recognizing the individual, or seeing the information on social media, our Customer took action to remove the individual from the network even before a complete conviction or criminal record was available.
For Customers focused on protecting consumers in their homes, any alerts related to violence, theft, or dishonesty are going to be the most important. Below is a sampling of the alerts that we have received across our Customer’s network populations:
The level of risk associated with individuals who may perpetrate these crimes is greater than those that remain in the program with no alerts.
We also see a range of drug-related issues which could include possession, use or distribution, paraphernalia, or even intent to use, distribute, or manufacture. Given the changing legal landscape surrounding the legalization of marijuana, Customers, and even legislation, may not be as strict in this area. However, cocaine possession, significant quantities of marijuana, or other Schedule I substances are very much relevant and carefully reviewed. Aside from the criminal side of the issue, we are also working with customers to reduce safety risks in their networks which may arise from substance abuse or other impairment concerns.
Additionally, since many of those in the Customer networks are required to drive, any driving related items, such as Driving While Impaired, Driving Under the Influence, Driving without Privileges or on a Suspended, Revoked, or Restricted License, are going to a concern. In some cases, our Customer will move the individual to a “helper” status and retain them, meaning they are still eligible to remain in the network but must only work in a helper capacity to a licensed driver. This is often sufficient to address the issue while it is being resolved and ensuring no unlicensed or unsuitable drivers are engaged.
These alerts have value to the Customer because they provide details on activities occurring in the network, allow us to take a closer look at some individuals, and remind the service network of the diligence and compliance requirements of our Customer’s program.
As outlined above, many alerts may not end up having an impact on the Customer’s network. Alerts can sometimes be a false positive due to a common name, incomplete identifiers, or geographic or demographic mismatch to the individual. In some cases, the alert may be for an incident that is not of impact – traffic issues, payment/support issues not related to their work, minor or isolated incidents that are not relevant to the individual’s overall eligibility.
However, there is great value in having a continuous monitoring program in place to identify any issues as soon as possible rather than waiting for an individual’s time to renew a background check.
PlusOne Solutions has been an industry leader in the workforce compliance and 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, operational, and reputational risks associated with contractor and vendor relationships while creating safer work environments. To learn more, visit https://www.plusonesolutions.net/.
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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