Presentation delivered by Aletheia Consulting Group on HR.com focused on best practices in international background screening for transnational organizations.

1. Presented by
Best Practices in International
Background Screening
for Today’s Transnational
Organizations

2. Presented by
Terry Corley, Managing Principal
Aletheia Consulting Group
• Aletheia Consulting Group (www.aletheiaconsultinggroup.co)
provides expert global advisory solutions for multinational
organizations human resource, compliance, and security
international risk management resource needs. Our primary
focus is on companies that have overseas operations that
seek to navigate the sometimes challenging sea of
international risk management.
Gary Clayton, CEO
Privacy Compliance Group
• Privacy Compliance Group
(www.privacycompliancegroup.com) is a data management
and privacy consulting service that provides the expert legal
knowledge necessary to align an organization's business
goals with its privacy, security, and compliance requirements.
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3. Session Objectives
What are today’s most common types of
international background checks and how do
they help organizations exercise required
due diligence?
What is considered a reasonable level of
due diligence according to prominent anti-
corruption laws affecting global trade?
How can multinational organizations
implement best practice international
screening programs that meet necessary
due care and legal compliance?
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4. Overview
A Way
Forward -
Overview of How to
Common how to
today's evaluate
Types of implement a
Typical International Legal what to
International best
Scenarios Background Landscape check on
Background practice
Check overseas
Checks international
Market candidates
screening
program
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5. TYPICAL SCENARIOS
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6. Players involved
Data Subjects
•Candidates/employees
Employers Potential Employers •Other 3rd Parties Customers
Third-parties
Consumer Reporting •data
Government •private investigators Works Councils
Agencies
Data Protection
Unions
Authorities
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7. Overview of the
International Background
Check Market Today
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8. Legal Landscape View
Overview of Regulatory
Environment,
Internationally
Data Provisions Corporate & Financial
• Privacy and Data Protection Governance
• Mandatory - what's required by law • Anti-Money Laundering
• Transfer - Transborder • Anti-Corruption
• Record Restrictions • Anti-Terrorism
• Purpose / Consent • Know-Your-Customer
• Financial Services / Regulatory
Authorities
• Other Regulated Industries
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9. Legal Landscape View (2)
Overview of Regulatory
Environment, U.S.
Data Provisions Corporate & Financial
• Privacy Governance
• Mandatory • AML
• Non-Transferable • FCPA
• Record Restrictions • USA Patriot Act
• Financial Services / Regulatory
• FCRA
• Bank Secrecy Act
• Purpose / Consent • Sarbanes OX.
• Other Regulated Industries
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10. Legal Landscape View (3)
• Consequences for
not getting it right
– Criminal
Prosecution
– Civil Action
– Enforcement Action
– Data Transfer
Injunction
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11. Case Examples
Case Examples
• Oil Company
• Financial Services
• Publicly Traded Companies
• Critical Infrastructure Organizations
• Data Processors
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12. Common Types of International
Background Checks
Right to work check –
Identity check – confirms
confirms candidate is
candidate is who they say
authorized to work in a
they are
given country
Address verification –
Education – confirms
confirms candidate’s
academic credentials
current residency
Reference check –
Employment – confirms
confirms professional
claimed work history
reputation
Professional credential –
confirms professional
certifications
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13. Common Types of International
Background Checks (2)
Criminal records history – determine if
Consumer Credit - evaluate candidate's
candidate has a propensity to engage in
financial responsibility
illegal activities
Regulatory and Compliance / Sanctions
Search – determine if candidate has been
Civil Records - determine if candidate has sanctioned by relevant regulatory
any judgments, bankruptcy, or liens. authorities, has been the subject of other
enforcement actions, or identified as a
possible politically exposed person
Adverse media – news articles that
Conflict of interest – evaluate if candidate
contain derogatory information the
may be involved in multiple interests
candidate
Trading Partner / Vendor Screening –
Drug Testing – determination if candidate
determine if vendor is legitimate and of
has a propensity to abuse illicit drugs
good standing
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14. How to determine scope
Risk Benefit Analysis
Answering the who, what, when where, how
and why questions
– Does it exist?
– Is it available?
– What is the purpose?
– What is the Relevance / Sensitivity?
– Where is it available?
– Who has it / what is the source?
– What is the reliability?
– What is required to get it?
– Is it transferable?
– What are the notice & consent
requirements?
– What are the data storage and
retention requirements?
– Do we or will we have the appropriate
procedures?
– Timeliness
– Cost Benefit
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15. How to determine scope (2)
• Who's involved in
making decisions?
– Gen Counsel
– Human Resources
– Compliance
– Security
– Risk Management
– Supervisor of
Candidate
– BOD
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16. A Way Forward - How to implement
• Priority, Authority,
Establish Responsibility
• Assess your privacy,
Assess compliance, and
cultural environment
• Organize your
resources
• Identify personnel
• Global HR
Organize • Regional / Local HR
• Compliance
• Security
• Legal
• IT
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17. A Way Forward - How to implement (2)
• Develop
Develop
Policies,
Practices &
Procedures
• Implement
Implement
Policies,
Practices, &
Procedures
• Maintain
Maintain
Polices,
Practices, &
Procedures
Manage
• Manage your
exceptions
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18. Q&A
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19. SERVICES
• Global Background
Reporting & Privacy
Assessment™
• Global HR Background
Screening Policy &
Procedure Guides
• Strategic Vendor Sourcing
of International Data and
Services Globally
• Human Resource
Technology Evaluation and
Integrations
• International Background
Check Provider Vendor
Evaluation and Audits
Aletheia Consulting Group is the trusted name for We provide the advice
today’s global HR,
global risk mitigation and privacy advice. Compliance, and Security
Aletheia Consulting Group provides strategic global risk management information professionals need when
technology advice to todays’ Global Organizations. We offer thought-leading integrated navigating the challenges
business and technology advice that drives risk mitigation and organizational faced with international risk
effectiveness. management programs.
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helping Human Resource, Security, and Compliance leaders achieve global success
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through the deployment of best-practice transnational solutions covering the people,
processes and technology supporting the global HR and risk management function. www.AletheiaConsultingGroup.co