Full Credential process by First Advantage (FADV)
(Not applicable to new registrants)
Customer: I am being asked to complete full credentialing with FADV. Why do I have to do this?
Response: This is part of the ongoing improvements we have been implementing to Aspen iRecord which are aimed at putting more control in the hands of our customers. This is also something that many of our Aspen iRecord® customers have been asking us for this for some time.
In order to be fully compliant with the FCRA, you need full access to your background check reports. Your background check company, First Advantage, will only make these reports available to you after you have completed their credentialing process. This process simply shows that you are an entity prepared to handle background check reports in line with FCRA guidelines.
Customer: Why do I need access to the background check reports to be compliant with the FCRA guidelines?
Response: If your applicant receives a result of IC01, you probably do not. If your applicant receives a result of IC02, IC03, or IC04, they are placed in a pre-adverse period for a minimum of 6 business days. This period allows the applicant to dispute any inaccuracies, or appeal the result, and the FCRA and EEOC recommends that you, as the employer, carry out an individualized assessment of the applicant during this time. This is when having access to your background check reports is important. For further information on your responsibilities under the FCRA, it is always recommended that you seek independent professional advice and/or use publically available sources of information such as this.
Customer: But I am not the employer of many of these people, they are independent contractors (1099’s) who work for me.
Response: We are not in a position to provide legal advice on such matters. However, our understanding is as follows; Under the FCRA, the term employer is given a wider meaning than that used in a normal employer/employee relationship and responsibilities when applying for a background check are given that wider interpretation. You should however confirm this with your own legal advisors.
Customer: What if I do not need or want access to my background check reports? I only use IC01s anyway, so I do not really care about the IC02s, IC03s, and IC04s. They will not work for me.
Response: This is where the most risk exposure to your business occurs, when using a background check to decide if someone gets work or not. It is important to be sure that all FCRA guidelines are being considered and followed.
Customer: But what has changed? Why do I need to be credentialed now? Am I not compliant now/was I not compliant before this change?
Response: Your obligations have not changed. These FCRA requirements have been in place. Up until now, when you needed to review a report, you were probably asking the applicant for his or her copy to perform the individualized assessment. We have been advised that it is the best practice for you to have full access to your background check reports for this purpose. Over the coming weeks, we will be working with all Aspen iRecord® customers to upgrade their accounts to full credentialing.
Customer: Well, I have not been doing this / My documentation didn’t mention this before / Aspen never told me to do any of this.
Response: Your Aspen iRecord® account helps you with some of this already. Adverse action notices are sent directly to the applicant by the background check company. These notices outline the applicant’s rights and provide instructions to challenge the result if they so choose. The 6 day grace period is built into your account functionality. You also have the ability to release or not release the score to your Aspen iRecord® account effecting the visibility to your client.
However, it is not Aspen’s position to inform you of your obligations under FCRA guidelines. We are a technology company. Through the Aspen iRecord® Application and the Terms and Conditions you agreed to, you continually confirm that you are aware of your obligations and accept that Aspen is simply the technology company assisting you in your interaction with your background check company. If this is new to you, it is always recommended that you review these terms and conditions and seek independent professional advice and/or use publically available sources of information such as this.
Customer: Is the credentialing process the same with all background check companies?
Response: Yes. Going forward, every Aspen iRecord® customer must be fully credentialed with their background check company of choice to receive access to that background check company’s portal and their background check reports.
Customer: I have heard that Quick Search has an easier process. Is this true?
Response: There was a time when the Quick Search Process was significantly different and easier than FADV’s but not anymore. FADV will send you document which you can simply sign electronically and then a link to an online verification app. This should be downloaded and completed – it only takes 15-20 mins and you’re done. Quick Search has a slightly different credentialing process but you are still required to complete documentation. If you decide to switch, you will lose the ability to access your current and historic background checks. It may be easier for you to simply complete the credentialing process with First Advantage. That way you will not be impacted if you need those reports in the event of an audit.
Customer: What happens if I don’t / decide not to complete this process?
Response: We hope you wouldn’t make such a decision. Unfortunately, this is a mandatory process. In the short term nothing will change, but if you fail to complete this process by the end of 2018 you will be unable to process any further background checks on Aspen iRecord® and you will become non-compliant in the eyes of your work providers.
Customer: Is there a cost to complete this credentialing process?
Response: No, there is no cost to you. Aspen has negotiated with First Advantage on behalf of all of our customers to have the normal credentialing fee waived.
Customer: First Advantage tell me that I haven’t passed their credentialing process.
Response: That’s unfortunate but it's okay, we have a solution. You will have to enroll with the other background check company we are affiliated with and complete their registration process.