Using Company Policy to Interpret Criminal Records

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Criminal Records are Consumer Reports?

According to the Fair Credit Reporting Act (FCRA), the definition of a consumer report is 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. Quite the definition, but what does it all mean? Once you begin a consumer report i.e. background check (after you have had the potential or current employee sign Authorization and Electronic Disclosure Forms which you can learn more about here) on a current or potential employee, you are looking for specific “red flags” or “hits” once the consumer report is returned. For example, driving records, credit score, federal offenses etc. but how do you know what’s important? You look to your company policy to see what the standards and expectations are for a current or potential employee. “But what if I don’t have a company policy?” If your company doesn’t currently have a company policy then start by using consumer reports, and a decision matrix to begin creating one.

What Goes Into Creating a Company Policy?

How do you know where to start when creating your company policy? Start with a decision matrix. A decision matrix is a form with a list of offenses that a company reviews to standardize which offenses are acceptable or not. When filling out the decision matrix, you base your decision on unique needs of the organization and all applicable federal, state, and municipal laws and regulations. Once you have created your decision matrix your company can begin to create a policy.

Need a decision matrix? Check out an example below, and for the full decision matrix please click below to download.


Your Company’s Policy

Having a company policy in place gives clarity to a consumer report. It allows you to know exactly what to look for on the report for a potential or current employee. For example, if there is a home cleaning company that requests a consumer report on a potential employee and a “hit” comes back that reveals that that potential employee has been arrested for home burglary then your company policy should tell you whether or not that offense is acceptable for that position. Having a company policy in place and using a screening agency that gives you accurate and detailed consumer reports is key to the success of your company to ensure you’re making the best hiring decisions, but to also provide your company with a defense if you ever have to turn away a potential employee.

Final Thoughts

To learn about our hardworking team that provides the consumer reports for our clients check out our blog “Quality Assurance – The Secret Sauce Behind Our Screening Accuracy” here. For any questions email me at For more great blogs and content please subscribe to our blogs here.