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| Frequently Asked Questions What makes Cornerstone Applicant Screening (“CAS”) different from other applicant screening companies?
While most screening companies offer online access to their database, CAS goes the extra step and conducts the searches for the Subscriber, then compiles the data into a clear and concise Investigative/Consumer Report. What is the difference between a Consumer Report and an Investigative Consumer Report?
Per the FCRA, the term "consumer report" means any written, oral, or other communication of any information by a consumer reporting agency bearing on a consumer's credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living which is used or expected to be used or collected in whole or in part for the purpose of serving as a factor in establishing the consumer's eligibility for
(A) credit or insurance to be used primarily for personal, family, or household purposes; (B) employment purposes; or
(C) any other purpose authorized under section 604 [§ 1681b].
The term “investigative consumer report” means a consumer report or portion thereof in which information on a consumer's character, general reputation, personal characteristics, or mode of living is obtained through personal interviews with neighbors, friends, or associates of the consumer reported on or with others with whom he is acquainted or who may have knowledge concerning any such items of information. However, such information shall not include specific factual information on a consumer's credit record obtained directly from a creditor of the consumer or from a consumer reporting agency when such information was obtained directly from a creditor of the consumer or from the consumer.
What is the FCRA?FCRA stands for Fair Credit Reporting Act and is the law that governs users, providers and subjects of the information we provide. The complete law can be found at the following: http://www.ftc.gov/os/statutes/fcra.pdf
Is there a certain release form that needs to be signed by the applicant?
Yes. Depending on the purpose of the screening service, (i.e pre-employment, tenant screening, PHA Applicant/Participant screening) the appropriate release form/s will be supplied to the Subscriber by CAS. The Subscriber may elect to have other release form/s signed in addition to the form/s provided by CAS.
What type of service delivery do you use for transmitting information?
CAS can deliver data either by fax, email or US Mail.
What is your normal turn-around time?
Time to complete each applicant screening will depend upon the package chosen, written responses required, and individual state’s response time. However, most applicant screenings can be completed in 1-3 business days.
Do you require a contract?
A Client Agreement is required; however, there are no term limits to the agreement, and no membership or subscriber fees. Only a 30-day written notice to terminate the Client Agreement is required. Subscriber-requested services are performed on an “as needed” basis with no minimum orders required.
What disclosures and consents are required prior to requesting a investigative consumer report?
Before requesting a consumer report (such as criminal history records, driving records, etc.), CAS Subscribers must: (1) make a clear and conspicuous disclosure in a separate document to the applicant or employee that a report may be requested; and (2) obtain written permission from the applicant or employee.
A statement in the employment application that consumer reports may be obtained is no longer sufficient under the FCRA. Employers must make the disclosure in a separate document.
To comply with these disclosure requirements, the Federal Trade Commission ("FTC")1 has provided the following options to employers. (1) Make the disclosure in a separate document and obtain written authorization on the disclosure document. (2) If you include the disclosure and authorization in the employment application, you must also provide the disclosure on a separate document. (3) You may split the procedure into two parts by obtaining authorization in the application and by providing the disclosure in a separate document.
If you choose to combine the disclosure notice and authorization, identifying information (such as date of birth, social security number, driver's license number and current and former addresses) may be included in the combined form. However, the FTC has advised that the form should not contain any extraneous information.
Employers should also be aware that the FTC has also advised that inclusion of a waiver provision of any of the consumer's rights under the FCRA violates the requirement that the disclosure consist "solely" of the disclosure that a consumer report may be obtained for employment purposes.
What else is required before requesting an investigative/consumer report?
Before obtaining "consumer reports" or "investigative consumer reports" Subscribers must certify to CAS that the necessary disclosures have been made and the individual has authorized obtaining the report. The Subscriber must also certify that it will follow the procedures regarding adverse employment actions if it relies on information reported by CAS.
What must be done prior to adverse action being taken against an applicant?
Once the Subscriber takes the adverse action, (i.e denial of employment or continued employment, denied tenancy, denied admission or continued participation in a HUD housing program) it must provide certain information to the individual. This notice may be provided orally, in a written form, or electronically and must include 1) The name, address and telephone number of the agency that provided the report; 2) A statement that the reporting agency did not make the decision to take the adverse employment action and is unable to provide the specific reason/s for the decision; 3) A statement of the applicant or employee's right to obtain a free copy of the consumer report from CAS by making a request within 60 days; 4) Notice of the applicant or employee's right to dispute the content of the credit report.
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