4 Components of a Solid Employment Screening Policy

Michael R. Gaul, Vice President, Business Development, Proforma Screening Solutions

Editor’s Note: NCPA invited our Protect Your Pharmacy Now! partners at Proforma Screening Solutions to share tips on employment screening. Proforma Screening Solutions offers discounted packages to NCPA members on employee background screenings. This blog is part of a weeklong series on pharmacy safety and security during Protect Your Pharmacy Week. For more information on how to receive NCPA discounts, please contact Valerie Briggs at valerie.briggs@ncpanet.org.

Creating a consistent, compliant, cost effective employment screening program is not easy but it would be nearly impossible without a well-designed employment screening policy. An employment screening policy offers necessary guidance throughout the organization as to how screening should be performed.

A well-devised employment screening policy will instill consistency and efficiency into the hiring process, which will ultimately:

  • reduce hiring risks,
  • avoid litigation,
  • and reduce operating costs.

Taking the time to create a meaningful policy now will mean less time (and money) defending it later. Your policy should be constructed with input from your own legal counsel but can also benefit from the guidance and experience of an employment screening company.

Essential components of an employment screening policy include:

  1. Defining the purpose and scope of the background screening policy
  2. Designating organizational responsibility and authority to conduct screenings
  3. Describing legal parameters and guidelines to be followed in the process
  4. Outlining the specific process that will be used to perform the background checks

Purpose & Scope of the Employment Screening Program

Employment screening policies are typically designed to protect people and property your employees will come in contact with, including fellow employees, customers, contractors, and the general public. Your policy should explain the purpose of background screening and also define the scope of the program, or the types of positions that will be subject to background checks.

Responsibility & Authority for the Employment Screening Process

Your employment screening policy should designate the people or person responsible for implementing and managing the program. It should define the types of employment decisions that can be made by each individual involved in administering the program. There are almost always situations that require “judgment calls” and it’s important to define who will make those decisions.

Legal Parameters & Employment Screening Guidelines

A background screening policy must consider any federal, state, or local laws that affect how the organization will conduct screening. In many instances these laws require background checks within specific criteria for certain positions.

In your policy you should specifically outline how the organization will adhere to Fair Credit Reporting Act requirements, EEOC guidelines, anti-discrimination laws, and any other related screening laws. The policy should give clear direction as to how results of any background check should be applied in a consistent and equitable manner across all applicants and employees.

The Employment Screening Process

Any good policy can get stuck in the mud without an equally well-defined process. The process describes exactly how the background screening policy will be implemented. In other words,

  • what type of check will be performed,
  • how often,
  • on which positions within the organization,
  • and what are the criteria that will separate “acceptable” from “unacceptable” screening results?

For example, in most organizations those in positions of significant trust (those with unsupervised access to people or property) will be screened at a higher level than those with a high level of direct supervision. Likewise, the types of “flaws” found in an individual background check will vary based on the requirement of the job. It may be acceptable to hire someone with a criminal record for a well supervised position.

An important point to consider in creating an employment screening policy is to ensure the policy is consistently applied across all affected individuals. Equally important is to avoid any type of policy that automatically disqualifies any person for any position on the basis of a criminal record. Be sure all checks are job-specific and that, throughout the process, you protect the privacy of employees and applicants.

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