Guide to Evaluating National Criminal Database Solutions

Transcription

1 Guide to Evaluating National Criminal Database Solutions Privately-owned national criminal databases have become a necessary part of a background check, and it s difficult to evaluate these databases without conducting an anonymized data test. Anonymized data tests are the best way to get a good understanding of the capabilities of a national criminal database as compared to the other databases you are considering, and can provide you with insight regarding the effectiveness of the data being provided and how that data is being managed to ensure you are getting the most accurate and timely information. Anonymized tests are necessary and relatively simple once you know what to ask and what to do. Guide to Evaluating National Criminal Database Solutions GIS HireRight info@geninfo.com www@geninfo.com page 1

2 Best Practices Ask for an anonymized test, which allows you to see what types of details are available in the database. You will need to give each provider a list of all individuals, completely with PII and random identifiers for every individual. Once this has been sent, you will be required to delete your copy of the information. The provider will then send you the results with no PII; just your chosen random identifiers. This allows you to compare the results across providers while maintaining FCRA compliance. Use a robust sample size (approximately 1000 individuals) to receive statistically significant results. Use a national sampling of applicants to ensure that you are evaluating the provider s strength in multiple jurisdictions. Use applicants that have already been cleared by your current provider to easily evaluate their past performance. Score Card Questionnaire Require results be returned within 2 business days so that test participants have just enough time to run your file through the database and exclude information that shouldn t be included. Check results to ensure that certain types of hits, e.g. submisdemeanors, driving records, etc, are being excluded appropriately. Build a scorecard to help you objectively compare the results from the providers. Most database providers are going to claim to be the best and they ll provide carefully selected data to back up that claim. To combat this, you ll need to ask providers specific questions to get specific answers so that you can compare apples to apples. While the questions below seem to give the best overview of a provider, don t be afraid to ask follow-up questions if one provider offers more details on a process than does another. 1. How many data sources do you have? 2. How many sources have you added in the last 12 months? 3. How many criminal conviction records are currently in the database? 4. Are you (or the provider of the database) a member of the Expungement Clearinghouse? If not, how do you proactively ensure that expunged records are being removed from your database? 5. What is the overall percentage of coverage by counties? 6. What is the overall percentage of coverage by population? 7. What is your standard refresh rate time frame for adding new records? 8. How many FTEs are dedicated to acquiring sources and updating records? Guide to Evaluating National Criminal Database Solutions GIS HireRight info@geninfo.com www@geninfo.com page 2

3 Sample Score Card* Provider X Provider Y Provider Z Number of data sources Number of sources added past 12 months Number of records 463,927, ,000, ,000,000 How expunged records are handled Expungement Clearinghouse Consumer or legal representation to notify us of expungements No clear process established at this point in time Percent US counties covered 64.3% 42.6% 51% Percent US population covered 74.7% 52.6% 61% Refresh rate (days) Number of FTEs dedicated to source acquisition and record updates Number of subjects with initial hits Number of subject hits after exclusions** Notes * Please note scorecard is populated with sample data for demonstration purposes only. ** exclusions should include cases that have been dismissed, are classified as Sub-Misdemeanor, Restricted States, Out of Scope, Non-matching identifiers. Communicating the Scope Prior to submitting your file for the test, formally advise providers on the scope and your expectations regarding best practices and the timeline for returning results. SAMPLE COMMUNICATION TO DATA TEST PARTICIPANTS: Please note the following requirements for this blind data test: Results should be provided no later than [Time & Date] Results should be direct hits found in your database product, not a blending of database hits and traditional searches Do not include employee PII in the Anonymized Test Results Records that have been dismissed, are classified as Sub-Misdemeanor, are subject to state specific restrictions, are out of scope, or have non-matching identifiers should be identified, counted and excluded from the final hit rate percentage. Guide to Evaluating National Criminal Database Solutions GIS HireRight info@geninfo.com www@geninfo.com page 3

4 Formatting Your File & Uploading Your Data Providers may have differing specifications for the formatting of your data. They should provide you with a detailed file & data format specification document so that you may prepare your data for upload into their systems. Our detailed file and data format specifications are shown in Appendix B. Once the data is formatted, you will need to send it to the providers. Test data should never be sent via , so most providers will offer you specific login information and instructions for safely transferring your data to them for testing (i.e. through a secure FTP site). If a provider expects you to send test data via , this is a red flag that should call into question the provider s security practices. Processing Your File Providers should begin processing your file as soon as it is received. Blind criminal database tests typically do not contain hit information that has been validated using a traditional jurisdiction search. The reason for this is that you are required by law to obtain authorization from your applicants/employees before processing a full criminal background check investigation. When testing the data contained in a national criminal database, the process stops short of validating any hits found at the jurisdictional level to both ensure compliance with federal and state laws regarding criminal background check authorizations and to provide the true measure of the data contained in a provider s database. If you have decided that the scope of your data test will include validated criminal hits and detailed results including your employees personally identifiable information, you should consider engaging in a pilot/test rather than an anonymized test. The Return of Results A summary report of hits returned will be provided. Because this report will contain no PII, it can be returned to you via . This summary indicates how many total criminal hits were returned from your test batch. If you have test requirements which include a breakdown by criminal offense category and job title or hourly/salary designation, then you will have provided that information in the ReferenceID field of the test file you uploaded to the provider. The additional analysis and grouping by special parameters that you define will take additional time to complete. Guide to Evaluating National Criminal Database Solutions GIS HireRight info@geninfo.com www@geninfo.com page 4

5 It is very important that each test participant provides a count of excluded hits in the Anonymized Test Summary Hit Report. It is equally important that they do not combine traditional jurisdiction search hits with hits found in their database to inflate their final hit percentage. A final hit percentage skewed by these factors can result in a situation where you as their client could end up missing hits or paying for more searches than are necessary in order to find all past criminal history for your applicants. As an employer, this could expose you to unnecessary risk and unnecessary cost. A detailed hit report should also be provided, listing out any available information from the record such as: Subject ID (unique identifier assigned by you) Sentence Court Decision State Probation Offense Date Source Confinement Arrest Date Description Arresting Agency Sentence Date Disposition Originating Agency Disposition Date Degree of Offense Plea File Date Background Screening Offerings Once you have the results from the anonymized test for each provider, you can complete the scorecard above. Because providers often have differing methodology in place for both the initial search and any excluded information, it is very important that you are able to compare not only the results, but also the diligence behind them. This element can be quantified by also reviewing each provider s normal operational procedures associated with database searching and testing. Again, it s important that you feel ask clarification questions as necessary to ensure that you are getting accurate and complete information. Provider X Provider Y Provider Z Number of data sources Number of sources added past 12 months Number of records 463,927, ,000, ,000,000 How expunged records are handled Expungement Clearinghouse Consumer or legal representation to notify us of expungements No clear process established at this point in time Percent US counties covered 64.3% 42.6% 51% Percent US population covered 74.7% 52.6% 61% Refresh rate (days) Number of FTEs dedicated to source acquisition and record updates Number of subjects with initial hits Number of subject hits after exclusions** Notes Dismissed, Sub- Misdemeanor, Restricted States, out of scope, nonmatching identifiers all excluded Direct Employees 0 due to reseller status Provider indicated that they did not exclude submisdemeanor & dismissed cases Guide to Evaluating National Criminal Database Solutions GIS HireRight info@geninfo.com www@geninfo.com page 5

6 Appendix A Below is a checklist that can be used to help you cover all of the chronological steps involved with conducting a blind data test. Select providers for the data test Send the providers your scorecard questionnaire (Questions provided on Pg. 2) Use provider answers to fill in your scorecard (Example shown on pg. 2) Formally communicate the scope of your test to providers (Template provided on pg. 3) Request data formatting and upload instructions from providers (Details on pg. 3) Add provider results information to your consolidated score card (Example shown on pg. 5) Select your provider based on your scorecard and clarifications Guide to Evaluating National Criminal Database Solutions GIS HireRight info@geninfo.com www@geninfo.com page 6

7 Appendix B Below is a checklist that can be used to help you cover all of the chronological steps involved with conducting a blind data test. Anonymized Test Formatting Instructions An Excel spreadsheet of subjects to search should include the data shown below in the order shown below. Files may be provided in txt, csv, xls, and dat formats. Reference ID *Lastname *FirstName *DOB State Smith Robert 01/10/1975 SC Formatting Your Data Column one Reference ID: In order to be FCRA compliant, the reference ID should be completely randomized so that you are unable to tie it back to the employee in any meaningful way. This should be consistent across all providers so that you can determine if one provider found information where another provider missed it on the same subject. Column two Lastname: There must be only one last name with no spaces or punctuation. Last names with hyphenations (i.e. Smith-Jones) or spaces (i.e. De La Garza) should be reformatted as demonstrated in the tables on the next page. Column three Firstname: The first name field must contain only a single first name consisting of at least two letters with no middle names or initials. First name s that do not meet this requirement should be reformatted as demonstrated in the tables on the next page. Column four DOB: The DOB must be in the format MM/DD/YYYY. Column five - State: State abbreviations should be used. Your Employee Data Reference ID *Lastname *FirstName *DOB State Galford Kimbrew Melissa 07/02/1973 SC Bruce Mary Jo 07/24/1943 OK Aguilar-Green Angela 07/23/1967 CA Bilton-Smith Mary Catherine 11/24/1954 MN Guide to Evaluating National Criminal Database Solutions GIS HireRight info@geninfo.com www@geninfo.com page 7

8 Your Employee Data Reformatted Properly for Smooth Upload into Our System Reference ID *Lastname *FirstName *DOB State Kimbrew Melissa 07/02/1973 SC Galford Melissa 07/02/1973 SC Bruce Mary 07/24/1943 OK Bruce Jo 07/24/1943 OK Aguilar Angela 07/23/1967 CA Green Angela 07/23/1967 CA Bilton Mary 11/24/1954 MN Bilton Catherine 11/24/1954 MN Smith Mary 11/24/1954 MN Smith Catherine 11/24/1954 MN Secure Upload of Your File to Initiate a Blind Data Test GIS HIRERIGHT provides SAEP (Secured Automated End-to-End Processing), which uses TLS encryption, as a facility for our clients to upload data securely. The SAEP site is designed for clients to manually upload batches for background check ordering and to pick up results. In this case, we will just receive and process the data only for the test. We typically process files with txt, csv, xls, and dat extensions, so if your test file has a different extension, it will upload but will give you an error that you can ignore. Log-in details will be provided once the test has been agreed upon. Guide to Evaluating National Criminal Database Solutions GIS HireRight info@geninfo.com www@geninfo.com page 8