Federal, state and local laws, along with credit bureau requirements, mandate that all Consumer Reporting Agencies (CRA) know their customers, their permissible purposes for use of consumer reports and how their businesses work. The Fair Credit Reporting Act (FCRA), as amended by the Fair and Accurate Credit Transactions Act (FACTA), and the Gramm-Leach-Bliley (GLB) Act are examples of the regulations that CRAs must adhere to. In addition, credit bureau policies typically reinforce the regulatory requirements and underscore the importance of adopting practices that protect the privacy of consumer information. In addition to its regulatory and contractual obligations, First Advantage is dedicated to the protection of consumer data as it adds value through integrity of the overall hiring process.

Prior to providing services for employment purposes, First Advantage qualifies each prospective client. This step is mandated by the FCRA and the GLBA (Safeguard Rule). More specifically, Section 604 of the FCRA (15 U.S.C. §1681b) (see http://www.ftc.gov/os/statutes/031224fcra.pdf) mandates CRAs to substantiate the legitimacy of prospective end users of consumer reports and the appropriate utilization of that data. The requirements listed in this section are typically referred to as the “permissible purposes” for accessing and obtaining consumer reports. As a corollary to these “permissible purposes”, Section 607 of the FCRA (15 U.S.C. §1681b) sets its focus on compliance procedures and responsibilities of the CRA and the prospective client. For instance, Section 607 requires that the CRA must limit the provision of consumer reports to the purposes listed under Section 604, and it must verify the identity of a prospective client and the uses certified by the prospective client. Similarly, the prospective client is required to certify the purposes for which the information is sought and that it will be used for no other purposes. To ensure that these requirements are met, First Advantage's prospective clients must complete an application and, in most instances, have a physical site inspection performed. Physical site inspections are performed by unbiased, third-party vendors with screened and trained professional inspectors who have been approved by one or more of the credit bureaus.

Here is an overview of what a prospective client should expect during a physical site inspection. The physical site inspection generally takes less than 30 minutes and is non-invasive. During the physical site inspection, the inspector will look for locking filing cabinets, password-protected computers, evidence of shredders, lockable doors and other security requirements aimed at protecting personally identifiable information. The physical site inspection will also look for indicators of a legitimate organization. Prospective clients should also expect to have at least three photos taken of, but not limited to, permanent signage, building structure, file cabinets and computers. The purpose of the photos is to help confirm that the appropriate security is in place to protect consumer files and reports. The physical site inspection does not involve reviewing customer files or proprietary information.

First Advantage appreciates the opportunity to provide your organization with a comprehensive suite of employer solutions specifically designed to reduce the time and cost associated with recruiting, hiring management, screening and retention processes. Our qualification process is designed to be non-invasive but thorough, proving First Advantage's commitment to safeguarding both your organization’s information and that of consumers with whom you interact.