Rate our help center and provide feedback HERE and don't forget to rate this article using one of the REACTIONS at the bottom of your screen.

Policy Name: Background Check Screening Policy

Lauch Date: 3/1/2017

Last Update: 5/2/2019

Author Name: Stuart McIntire

Author Title: VP of HR

Version: 1.6

POLICY

All EZ Messenger employees, Affiliates and In-Network (Compliant) Independent Contract Process Servers (Vendors) are required to undergo a pre-engagement background check. The process for each type of worker may vary depending on the category of each worker and their level of access to the company’s systems. Each

respective process is to assure the greatest level of safety and security for the respective category depending on their interaction with sensitive information as well as the public.

RESPONSIBILITIES

Human Resource Department

Vendor Recruiting Department

ESCALATION POINT OF CONTACT

VP of Finance and HR

TYPES

Level 1 Background Check

All personnel listed in section 1 of this policy undergo a level 1 background check. This includes:

1) A 10-year multi-county criminal check: Search of available and legally reportable felony and misdemeanor convictions, including pending records, for a Consumer’s most recent address information that is returned by a SSN Trace or revealed in a National Criminal Database search. This search uses a network of professional court and record researchers to perform county level searches for felony and misdemeanor level criminal records in each identified county. This search will utilize reputable electronic databases maintained by governmental organizations or their agents in jurisdictions where available and conduct physical court searches in jurisdictions where performing electronic searches of reputable databases is not possible.

2) National Criminal Check: A multi-jurisdictional database search to locate records and addresses for the searched individual. This multi-jurisdictional database search (sometime referred to as a “National Criminal Database search”) is an automated search of commercial databases that consist of both publicly available and purchased criminal records complied from a variety of state, county and other proprietary sources. The National Criminal Search includes retrieval of data from national security sources, numerous federal databases, and arrest and criminal data from various local, county and state agencies including: Administrative Office of Courts; Departments of Corrections; Individual County Courts, State specific Criminal Records Repositories; and Criminal records from multiple states. This tool is used as a pointer and then all records are verified at the source before being reported.

3) Address History/SSN Check: A search utilizing credit bureau header and footer information and public records databases using the name and social security number provided by the Consumer. This search provides associated names and address history as a pointer of jurisdictions and name to search. This search does not match an individual with a number but verifies whether a SSN has been validly issued by the Social Security Administration.

4) Sex Offender Search and Global Watch. The Sex Offender Registry is a search using the Dru Sjodin National Sex Offender Public Website (“NSOPW”), maintained by the United States Department of Justice, and then verifying each record with the state sex offender registry. The results will show whether the Consumer searched is currently on a sex offender registry. The Global Watchlist is a search of various US and international government watch lists, which shall include, for example: FBI Most Wanted Lists, Interpol’s Most Wanted Lists, Office of Foreign Asset Control Sanctions List, Denied Persons Lists, Department of State Sanction Lists, Specially Designated Nationals Lists; as well as various Us Drug Enforcement Administrations Wanted Fugitive Lists.

Drug Testing

All EZ Messenger employees are screened for drug use prior to being hired. All EZ Messenger affiliates who will have access to accounts that require drug testing are required to have drug testing prior to being granted access to FAST (our proprietary workflow system). This test includes a Urine-10 panel Non-DOT + Alcohol test that screens for Amphetamines, Cocaine, Opiates Phencyclidine PCP, Barbiturates, Benzodiazepine, Methadone, Propoxyphene Alcohol, Cannabinoids and Methaqualone.

Employment Verification

All EZ Messenger employees undergo a previous employment verification. We have contracted with American Checked to obtain, at a minimum, 2 previous employment verifications or employment history for the past 3 years if only 1 employer is available. The items verified are dates of employment and position held.

Background Check Providers

Employees - American Checked

Affiliates - American Checked

Independent Contractors/ Process Servers - Checkr

PROCEDURE

Employees

Once an employee applicant has been interviewed and becomes a preferred candidate they are referred to the EZ Messenger Human Resource department to start the background check process. A Human Resource Clerk will email an American Checked link that will walk them through entering their PII and previous employment information. They will also receive a link to choose the time and locations for their drug test. All required PII and authorization forms are obtained and securely stored by American Checked. The result is returned directly to the EZ Messenger Human Resources department for evaluation. The official report is securely retained by AmericanChecked.

Affiliates

When an affiliate has a need to have a new person access our system they will first have a level one background check preformed. If they also need to be cleared to access work for clients that require drug testing they will follow the procedure employees follow in the employee section above.

Independent Contractors/ Process Servers

Once a Candidate has been assessed and qualifies as a potential independently contracted process server they are sent a link for the level-1 background check that is done by Checkr. Once the results are obtained, if they pass, the resulting file number is returned to EZ Messenger via electronic transmission for automatic upload and storage in our FAST system. If there is anything to review on the background check a message is sent to the Vendor Recruiting manager to evaluate. If they fail, they are notified with the legally required paperwork. If they pass their record is updated and then transmitted to EZ Messenger’s FAST system for storage.

Client Specific Background Checks

When a client has additional background-check needs in addition to the EZ Messenger protocol, they must submit instructions, administer the process following government regulations and perform the check at their expense.

Pass/ Fail Evaluation Process

A background check can be returned with two different results. One is Cleared, which is when no violations are found. The second result is Review, which is when something has been found and needs to be reviewed by either the designated Human Resource Clerk or the Vendor Recruiting Manager.

EZ Messenger will not knowingly permit an individual to have access to company and client data if the employee or agent of Vendor:

1) Has been convicted of a crime or has agreed to or entered into a pretrial diversion or similar program in connection with a felony or a misdemeanor, involving dishonesty or a breach of trust;

2) Violence/harassment and crimes of dishonesty; or,

3) Uses illegal drugs.

Background Check Renewals/ Reinstatement

Renewal

All personnel listed in the 'POLICY' section are background checked on an annual basis. The employee and affiliate annual renewal is submitted to American Checked each year. A designated Human Resource clerk evaluates the results. If anyone does not pass the background check, they will be removed from the system and suspended until a conclusion is determined.

The vendors are sent a link from Checkr one month prior to their expiration date. The Vendor Recruiting Manager evaluates the results. The renewal date is entered into their access profile. If a vendor fails his/her renewal their access is restricted to the system, they are notified, and arrangements are made to have them return outstanding documents.

All renewals are a level-1 background check. Candidates/Employees who have failed the background check or who originally passed but have since been convicted of a crime which would mean the individual would not currently pass the background check cannot be allowed to perform services for Firm or access Firm data.

Clients can receive notified when a vendor or employee fails a renewal upon request.

Company Separation

All employees and affiliates who are separated from the company for more then 30 days will undergo a Level 1 background check. If the separation is over 90 days a drug test will also be performed. A vendor, if separated more then 90 days, will undergo a Level 1 background check and all documents that they have on file will be reviewed and updated prior to reinstatement.

Background Check Items by Company

American Checked

EZ Messenger 360 Package: 10 Panel Non-DOT + Alcohol, 10 Year Criminal Track Record, 10 Yr. Country Criminal Search, Employment Verification, National Homeland Security Alert including OFCR, Nationwide Criminal Database.

Checkr

Pro Criminal Package: National Criminal, Unlimited County Criminal, Address History, SSN Check, Sex Offender Search, Global watch with OFCR.