DATE: January 2012 - Primary Source Verification
One of the least understood compliance initiatives CI undertakes stems from section 613 of the FCRA. This section gives background
screening companies a choice when it comes to how they will handle the reporting of certain information about a subject. Such certain
information being public record (e.g. a criminal record), of which the information is likely to have an adverse bearing on employment
sought by the subject. The two choices for compliance are referred to in the background screening industry as “simultaneous notice”
and “primary source verification”.
The simultaneous notice option allows for the reporting of such information to the user (employer), if at the same time the information is
reported to the subject. What this ultimately means is that the information found in a criminal record database is not validated, it is
relayed to both the user and subject at the same time regardless of accuracy. This process is undertaken by the large data brokers in
the background screening industry. Imagine being John Smith and having a national sex offender registry search run on you. Then
the results being relayed with out further verification of other identifiers besides name match. And, with no verification of the
information through the primary source of the information (e.g. the county court).
The primary source verification option allows for the reporting of such information to the user (employer) once the background
screening company follows procedures to make sure the information that will be reported is complete and up to date. What this
ultimately means is that information found is compared to the subject against all available identifiers (e.g. date of birth, Social Security
Number, address, etc.). Those matches are then researched again at the primary source of the data (e.g. the county court that
actually heard the criminal case). So, if you’re John Smith and had a number of name matches in the national sex offender registry,
with primary source verification additional identifiers in the database are compared to the subject’s and any matches are researched
again at the primary source of the data (e.g. the state or local sex offender registry).
CI complies with section 613 by applying the primary source verification option. This part of our compliance processes closely follows
our main differentiator — background investigations with human intervention and an investigative approach. Because of all the
different ways identifiers are relayed in the various data searches of a background investigation, human intervention is absolutely
necessary to make a positive correlation between the subject and the person the data ultimately relates to. Our investigative
approach is looking at data from many angles and through many searches. Thus, the reevaluating of data found from one source with
the primary source makes sense to CI.
Another differentiator of CI is that we will not jeopardize quality for turnaround time. With simultaneous notice turnaround time is quick
and not affected because there is no additional verification or research. With primary source verification there will be a slight delay
while the information is validated and re-verified.
CI’s clients don’t have to conduct additional research on their own after getting an adverse report. CI makes positive identification and
obtains the primary source results for adverse data. This is a great example of the added value of utilizing CI’s background
To learn more about primary source verification and CI’s compliance processes contact a CI Representative at 800-284-0906 or