The official CPNI has brought out a new, fifth edition of its pre-employment screening good practice guide.
As the Centre for the Protection of National Infrastructure (CPNI) point out, pre-employment screening is the foundation of good personnel security. It seeks to verify the credentials of those you are seeking to grant access to your sites. Such screening can confirm an applicant’s identity, nationality and immigration status, and to verify their skills and employment history. It may also raise concerns about their integrity, if they make false claims about their background on their CV, for instance.
For more details
To download the 50-page guide, and other material on personnel security, such as use of the internet in employment decisions, visit the CPNI website: www.cpni.gov.uk/advice/Personnel-security1/Screening/. CPNI also offers advice documents in cyber and physical counter-terrorism security; and security planning. The trade body the Recruitment and Employment Confederation has model policies free for members on such topics as whistle-blowing and drugs and alcohol in the workplace: visit www.rec.uk.com.
CPNI define pre-employment screening as verifying the credentials of job applicants and to check that they meet preconditions of employment; a test of character. While employers may go about it differently, they are after information, whether a job-seeker or someone being promoted and perhaps having more access to more sensitive corporate material. BS7858 is the British Standard for the security screening of individuals. As that standard suggests, checks take in the person’s identity (is he who he says he is?), details of his working life (did he go to the university he says he did?), criminal record check (is he telling the truth?) and financial check (ditto; does he have debts he’s hidden – which might not matter, but which might if the employer is in banking); and checking a character reference (again, is the applicant being truthful?).
As the guidance points out, pre-employment screening is not only about security, such as avoiding losses and disruption (if someone says they are a doctor or dentist for instance, but are not), but about being fair and efficient (if a bogus doctor gets a job in a hospital, that’s unfair on the genuine doctors who did not get the job – let alone the patients!?). An employer might not want to check everyone the same – a warehouse hand in the same detail as a finance director, let’s say. CPNI suggest as a minimum you verify identity; confirm residency and the right to work in the UK; and make sure that applicants complete a self-declaration criminal record form. The guidance then suggests a ‘medium level’ check, that takes in for instance a check of professional qualifications. And at the highest level, you might make more checks, including into the applicant’s finances. While the security department may be in charge of screening, human resources (HR) may do the recruiting and general managers may do the interviewing of job-hunters. CPNI is savvy enough about business to point out that those departments may have ‘competing interests’; let’s say, general managers may just want to get a likely-looking person in post as soon as possible. And if your business uses an outside recruitment agency, the guidance asks if they’re working to your (or any?!) standards.
The guidance stresses the need for screening according to a timetable, and a structure – so that, for example, you know what screening’s been done on whom; and it has to be reasonable and proportionate. The guidance adds that it shouldn’t be used as part of an investigation or disciplinary procedure.
The guidance suggests a standard application form as the basis of screening (including the applicant giving permission to undergo screening). Why might someone use a false identity? Because they are in fact a disqualified driver, a known criminal, or have a poor credit history; or they are using the false ID to get genuine documents. While CPNI do not offer a definitive list of identifying document, ideal ones are passports and driving licences. For higher-security checks, you (or through your commercial sector screening contractor) may want applicants to provide addresses going back five years or more; applicants may then have gaps they would rather not account for, if for instance they were in prison. The document also details how to confirm that someone has the right to work in the UK.
As for checking qualifications, CPNI suggest you may want to confirm even if an engineer or accountant qualified 20 years ago; and ‘always request original copies of any certificates’. If you haven’t the time or staff to check that much, for instance by contacting the institution that gave the certificate, you might at least make an internet search, to check the crests or logos look correct, and that the institution is not in fact one of the UK’s hundreds of online ‘degree mill’s that in truth offer sub-standard, bogus titles for a fee.
The guidance admits that employers may avoid giving any reference if it may cause a legal dispute: “Employers may be cautious to comment upon their former employee’s character, not least because of the risks of litigation from actionable statements. References tend therefore to focus on giving brief details of the employee’s dates of employment and job title.” But you can still check that the employer exists at all; and that they actually did provide that reference. As elsewhere, the guidance stresses the need for structure; in this case, recording that you have a conversation with the employer, or indeed anyone. The guidance goes on to criminal and financial checks; and checks on people who’ve worked overseas. As for interpreting the results, is the applicant a bad payer, or has an unsustainable lifestyle? Is the person at least making efforts to repay debts? CPNI recommends that you make ‘consistent and defensible’ judgements (let’s put it this way, if someone once had an ‘adverse credit history’, have they put it behind them and might you be over-cautious if you don’t hire them?).
An employer might consider an applicant’s ‘online reputation’, defined as their behaviour online and what they and others post. Is the applicant open to a conflict of interest? But such a search must be in line with data protection, human rights and employment law, CPNI warn: “Media searches must be necessary, proportionate and transparent. If the employer has no justifiable reason for conducting media searches, then they should not be done.” As the guidance points out, what’s unacceptable to you may be normal to the young online. In other words, what’s your threshold of what makes someone unsuitable to work for you? Again, the stress is here on having being fair and balanced in your policy. Are you going to reject someone because of drink or drugs you’re read online – how do you verify something online, posted by someone anonymous, anyway?!
While the guidance accepts screening companies have been growing, that might be faster and cheaper than you doing it in-house, the guidance asks you to think. Can the screener do what they say they can? As the guide puts it, a ‘competitive market increases the pressure on screening companies to produce results quickly’. The document also goes into screening contractors; what if, for instance, you are told something adverse – do you stop the contractor coming onto the premises?! How do you know that the contract worker screened is the person that turns up at your gates?
As that suggests, and as the CPNI guide covers, someone has to decide whether to employ the applicant. “Consideration should be given to the role that the applicant will be undertaking, their integrity, the severity and patterns relating to criminal records data, as well as mitigating circumstances.” Again, CPNI suggest you document what you decide, and why.
