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#59743 - 02/06/03 10:46 PM Employee Account Review
cervesa Offline
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cervesa
Joined: Jun 2001
Posts: 56
Santa Fe, NM
We are developing employee account review procedures. At the time of hire, a prospective employee signs an authorization to pull a credit report. Can the authorization be modified to say that a credit report will be requested annually during the period of employment? Is there a legitimate business need that can be justified? What about reviewing the accounts of parties related to the employee? Is that allowed by law? Privacy issues? What are your procedures? Any comments appreciated.

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General Discussion
#59744 - 02/06/03 10:59 PM Re: Employee Account Review
Anonymous
Unregistered

I just have a couple comments, neither of which are based on legal fact or (of course) opinions of my employer. As a bank, you can kind of run credit on an accountholder any time you have a LEGITIMATE concern abount possible fraudulent or illegal activity. I would caution against an added disclosure about annual reports- I would actually lean more towards random reports. If an employee is doing something bad, knowing that a report will be annual is too easy. Also, at least in Illinois, make sure when you run a credit check at time of hiring, that you are pulling that report in the subscribed method that will not display an inquiry on their credit history. Again, all of this is my opinion as I head out the door for the day. My employer thinks I have left already anyway, so this can't be a reflection of them.

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#59745 - 02/07/03 12:11 PM Re: Employee Account Review
JMB Offline
Member
JMB
Joined: Mar 2002
Posts: 59
Michigan
I would be inclined to check with legal counsel on this one. I once worked for an institution that had a policy on "random drug screening". The problem was our counsel had was "who determines who gets screened and who does not." To apply that thought process to your question, would you really screen EVERY employee EVERY year? Or just some.....

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#59746 - 02/07/03 01:41 PM Re: Employee Account Review
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,590
On the Net
You cannot get credit reports unless the employees have been notified that reports may be obtained and have given their written permission. If the employees received notice previously and gave you permission to get reports during the course of their employment, no more notice or permission is required. If not, you must notify the employees and get their written permission before you get their report.

You must follow sections 604 and 615 of the FCRA, strictly.

As to reports on related parties to the employee, don't even think about it.
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#59747 - 02/07/03 05:06 PM Re: Employee Account Review
Uncle_Milty Offline
Gold Star
Joined: Jun 2002
Posts: 434
New Jersey
Our employees sign a form at hiring allowing us to run periodic credit reports. We run them for all employees approximately annually. We also review employee deposit accounts as part of our internal audit function, and include the deposit accounts of the employee's relatives. However, I wouldn't think there would be any basis/authority for running a credit report on the relatives.

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#59748 - 02/07/03 05:16 PM Re: Employee Account Review
Mickey Offline
100 Club
Mickey
Joined: Aug 2002
Posts: 167
FL
We get a form at hiring allowing us to pull a credit report any time during their employment. We only pull one if we feel there is a reason to. Don't forget to run on OFAC check too! We also do an annual audit of employee accounts, looking for suspicious activity. We do not touch relative accounts, not sure if that would be a good idea.
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