With more people working from home than ever before, remote work is expected to continue on its growth trajectory and become a mainstay of the working world. Recruitment and hiring processes will therefore also need to evolve to meet the changing needs of businesses.

We expect some of the future needs to be:

• a more transparent recruitment and hiring process
• global and streamlined hiring programs integrated into existing systems
• better hiring metrics, and
• increased digital capacity to drive efficiencies, deliver on business strategies and generally create a larger impact using technology.

Technology can help with the needs listed above and is developing at pace.

Here at Sterling RISQ, we believe in the potential of technology and we are constantly investing in innovation in order to continually improve the delivery of our services.

Say hello to Looker

We are therefore very excited to announce our new advanced reporting and analytics tool, Looker, which incorporates enhanced technology to allow the export of insightful data and reports.

With Looker you’ll be able to take control of your data and use visualisations and informative reporting to extract information that matters to you. Looker will vitally provide you with actionable insights that allow you to make more informed, more data-driven decisions about your screening programs and drive business productivity.

The interface of Looker presents easy-to-use toolbars, along with a suite of interactive and dynamic dashboards that provide comprehensive data insights. This will enable on-time management and optimisation of your screening programs.

What does it really mean for you?

• Holistic: get a 360-degree view of your background, identity and health screening programs all in one place.
• Fast: receive real-time updates on your screening requests across multiple devices.
• Smart: scan your data quickly and infer relationships within the data to provide informative insights.
• Convenient: access to accurate, configurable reports that are easy to read and comprehend.
• Easy: interactive dashboards with visualisations, allowing you to drill down into the data, gain more informative insights and understand the whole picture.
• Personalised: download complete dashboards and datasets to allow for self-service and access when you want it.
• Real Time Reporting

Don’t wait for problems to come to you – Looker’s data visualisation software makes it easy to detect changes and irregularities within your company data and is represented in an impactful way.

We understand that data matters, but actionable insights matter more.

Make more informed, data-driven decisions for your business and start building effective, action-oriented dashboards and presentations with Looker.

Get in touch today to discuss how you can gain access – contact us on info@sterlingrisq.com

On 14 May 2021, the Monetary Authority of Singapore (MAS) released a new consultation paper on proposed changes to mandate reference checks in the financial services industry.

This document was an extension of the proposals made in their 2018 Consultation Paper on Revisions to Misconduct Reporting Requirements and Proposals to Mandate Reference Checks for Representatives and builds on the feedback received from that consultation process.

The new consultation paper proposes to extend the mandatory reference check requirements beyond just applying to representatives to now apply to other employees as well.

MAS has invited comments and feedback from financial institutions and other interested parties on this new consultation paper.

Background

Reference checks provided by previous employers are used to verify information disclosed by candidates, and allow for an assessment of the character, integrity and track record of the candidate.

They help to ensure organisations are hiring suitable candidates and also protect against ‘rolling bad apples’. This bad apple theory refers to an individual who has engaged in misconduct at one institution and then moves onto another institution without disclosing earlier misconduct to the new employer/s.

Mandatory reference check requirements for the financial industry have already been introduced in jurisdictions such as the United Kingdom and Malaysia in recent years, and indeed on 3 May this year, the Hong Kong Monetary Authority released their consultation conclusions paper on the Implementation of Mandatory Reference Checking Scheme to Address the “Rolling Bad Apples” Phenomenon. You can download our key findings from their initial consultation paper.

Financial institutions in Singapore have previously been required to implement due diligence on prospective employees of an organisation, according to MAS guidelines which set out the fit and proper criteria applicable to all relevant persons. These regulations were last updated in January 2020.

Why a new MAS consultation paper?

The reasoning behind this consultation paper is due to a number of factors:

• there are employees other than those recognised as representatives whose misconduct has the potential to result in detrimental impact on a financial institution’s prudential soundness, reputation and customer interests
• there are differing standards in practices when conducting and responding to reference checks
• due to the movement of ‘bad apples’ across the financial services industry, it is believed that a collective effort and consensus is required to mitigate risk, and
• It’s important for all institutions to come to an agreement on the format of the reference check and a specified period of time within which the check should be conducted.

What are the proposed changes?

Taking into account the feedback they have received from their initial consultation paper in 2018, the MAS have proposed the following changes.

1. Increasing the scope of financial institutions covered by the requirements. The proposal is to include all banks, finance companies, insurers and more (see part 3 of the consultation paper for the full list of institutions covered).
2. Increasing the scope of reference checks to cover a broader range of employees. The proposal suggests senior managers should be included, defined as those employed in an executive capacity and are principally responsible for day-to-day management (see Annex A of the consultation paper), and also proposes two other options for the type of employees it could cover:
   1. Option 1 – all individuals in risk-taking functions, risk management and control functions, any individuals performing critical system administration, and any individual who can authorise or approve payments (excluding small payments).
   2. Option 2 – all individuals in functions that can directly cause or result in financial risks to the institution or to customers, but excluding certain roles and functions.

MAS also proposes a number of related changes to increase the consistency and to standardise reference check practices across the financial sector.

• Reference checks must cover certain mandatory information relating to the individual’s records in the past five years, based on calendar years not years of employment.
• Reference checks should include the following information: information relating to the individual’s employment history, compliance records relating to the individual’s fitness and propriety, last four balanced scorecard grades, and persistency ratio of insurance policies sold by the individual (if applicable).
• Institutions should provide the mandatory information no later than 21 calendar days from the date of receipt of a reference check request.
• Information provided in response to reference checks should be accurate, objective, clear, balanced and based on verifiable facts. To support this objective and facilitate a fair process, MAS proposes that institutions should provide the individual with the right to view the references prepared.

MAS acknowledges there are some challenges with the proposed reference checks, such as if the individual’s prior employment history was conducted overseas or in non-financial sectors. MAS suggests that reasonable steps should be taken to acquire the relevant information in order to satisfy themselves of the fitness and propriety of the prospective employee.

Due to the possibility of a whole range of employees being hired into roles that would be within the scope of reference check requirements, MAS proposes that financial institutions maintain records pertaining to all employees, except for ancillary service personnel, for a minimum of five years once the reference check requirements come into effect.

And to facilitate the provision of fair and accurate responses to reference check requests, a robust internal investigation and thorough disciplinary processes should be established to provide guidance on the actions that could be taken against employees.

Institutions will be expected to establish policies and procedures governing their investigation and disciplinary process, communicate the policies and procedures to all employees, conduct fair and objective investigations and disciplinary proceedings in a timely manner, and ensure proper documentation of the investigation and proceedings. Employees should also have the opportunity to explain or defend themselves against allegations during this process.

Summary

Financial institutions are already performing reference checks and due diligence for new hires but to varying standards and formats. Institutions have provided feedback that they often receive inadequate responses to checks hence failing to effectively prevent the ‘rolling bad apples’ phenomenon. MAS is proposing to implement mandatory reference check requirements in order to counter these issues and provide guidance to the industry.

MAS proposes to commence mandatory reference checks with a transitional period of six months after the notice/s issued under the relevant legislation is published. They will take into consideration the feedback received from this consultation paper when implementing the reference check requirements.

How Sterling RISQ can help

As the leader in global background checks and identity services, Sterling RISQ is at the forefront of legislation changes to ensure your business can hire fast and with confidence.

With the changes to Singapore’s financial institution’s reference check requirements, our advanced technology and industry-leading turnaround time will allow our clients to meet the mandated deadlines and increased need to perform reference checks on a new scope of employees within the financial services industry.

We are your partners in assisting you to comply with changes to legislation. Our ultimate aim is to assist you to obtain accurate reference checks and hire the right people for your business. Get in touch with us at info@sterlingrisq.com to discuss your needs.

Social networks have developed into an excellent communication channel between candidates and employers. The latest numbers show an astonishing 3.78 billion social media users worldwide in 2021 across a variety of platforms.

Each social media site has its own unique audience. LinkedIn, for example, is the go-to professional networking site for more than 750 million active users in more than 200 countries and territories.

With more than half of the world’s population on social media, recruiters and talent acquisition pros have come to rely on social media as a key part of the candidate screening process. According to a survey from The Manifest, 90 percent of employers use social media to evaluate candidates, and 79 percent have rejected a candidate because of their social media activity.

3 Ways to Improve Your Social Media Screening Process

While social media is certainly useful in screening candidates, it’s important to follow a few best practices when looking at applicants’ social media profiles. In a standard job application, you will have access to a candidate’s resume, cover letter, portfolio, and references. Social media screening introduces additional information to the equation, and you need to use it properly to make the most of it.

Whether you’re entirely new to social media background screening or are looking for ways to improve your existing hiring process, here some tips to keep in mind:

1. Define the top areas of risk at your organization: legal, brand, or culture? Everyone you hire is someone who will represent your brand, influence your customers, and have access to your company’s resources and assets. You need to tailor your social media screening policy toward the areas of most concern for your business. For example, if branding is your biggest area of risk, you want to look at how candidates’ social media activity reflects their ability to be positive ambassadors for your brand.
2. Assess your current background screening program to determine where changes may be necessary. Determine whether your program needs to be updated to address societal and/or environmental changes.
3. Work with a partner. Your screening process needs to be compliant with the Fair Credit Reporting Act (FCRA), a federal consumer protection law that governs consumer background checks. It can be tough to navigate that compliance alone, and working with a third party can help. A partner may also be able to assist you in creating a process that leads to ethical decisions through proactive risk identification and the recognition of social media behaviors that align with company culture.

Why You Need a Social Media Policy

In addition to a policy that governs how the company uses social media to screen candidates, you should establish a policy governing how employees and candidates behave on social media.

Many organizations have created social media policies for their employees to adhere to. These policies guide employees to ensure the content on their social media accounts reflects their company’s values. For example, some businesses want all employees to use a prewritten statement when describing their jobs online. Others ask employees to add disclaimers to their bios indicating the views expressed do not represent their employers.

It is helpful to have a social media policy in place so that company expectations are clear and your brand reputation can be protected. Work with your legal department to update your social media policy or create one if you don’t currently have one in place.

The Benefits of Effective Social Media Screening

A consistent and robust background screening process that lays out 1) collection and documentation of information, 2) FCRA compliance, 3) information accessibility, and 4) who is authorized to make decisions on the information protects your business from negligent hiring lawsuits.

As employment attorney Pam Devata told social media screening provider Fama, “In general, the same rules apply whether you are using social media or more traditional methods for conducting background checks. The keys are consistency, accurate recordkeeping, ensuring data accessed is not legally protected information prohibited from being used in employment decisions, and that any decisions are rooted in business necessity.”

Social media screening can yield many rewards when performed correctly. It can reveal crucial data that helps organizations make more informed hiring decisions, allowing them to ensure every hire they make is someone who shares the company’s values.

So much has happened over the past year. These events, experiences, and challenges have caused many organizations to be more mindful of the people they bring into their workforces. Adding social media screening to your background checks gives you a window into the people who make up your culture, your business, and your brand.

Vincenza Caruso-Valente is the general manager of the staffing, retail, and franchise business of Sterling.

Sterling is not a law firm. This publication is for informational purposes only and nothing contained in it should be construed as legal advice. We expressly disclaim any warranty or responsibility for damages arising out this information. We encourage you to consult with legal counsel regarding your specific needs. We do not undertake any duty to update previously posted materials.

Traditionally, global background checks were necessary for international organizations, businesses with offices in more than one country. Offices in each country needed to conduct background checks when hiring candidates for their local office. This is no longer the case. With the ease and appetite for travel rapidly increasing over the last two decades, it is common for individuals to live and work abroad, and sometimes return to their native country with a resume including years spent across different regions. Today global background check programs are frequently necessary for both international organizations as well as US organizations that hire a diverse set of candidates.

This can present a challenge for organizations not equipped to handle international background checks. When the situation presents itself, and a US-based organization needs to run a background check for a candidate that spent years outside the country, many are left scrambling to quickly identify a partner that can accommodate a global background check and develop a program that includes the requisite support.

Over the last ten years, we have worked with many companies to develop global programs. We’ve learned a lot from our customers, from our successes and from our mistakes. Today, leveraging our relationships and learnings we continue to build out world-class global programs for our clients. There are three components we have identified as critical to a successful global screening program.

1. Create A Single Center of Excellence with Representation from Every Region

Over the years, we’ve seen the pendulum swing in two vastly different directions. First, global programs were very US-centric. They were driven by the US region who determined the requirements, the programs and the process. Once defined, it was rolled out across all other regions.

Regions outside the United States really struggled to meet the requirements and implement a program that was defined with only the United States in mind. With major differences in every country from culture to local laws to languages, every region was struggling to adapt to the US defined program. There was a lot of resentment and regions pushed back.

This led to a geographic centric model, where every region defined their own requirements and their own process and programs. While this model provided autonomy in every region, with the ability of each region to develop a program that complied with their laws and requirements, this created its own set of challenges. Organizations did not have consistent policies across the globe and could not manage background checks at a global level.

Finally, we’ve settled on a hybrid, which has been very effective across the globe. While there needs to be a consistent set of requirements and standards supported across the organization, they need to be developed with an understanding of all the regions in which they will be implemented and supported.

Today Sterling works with clients to develop a single center of excellence, where the requirements are defined globally; however, while the center of excellence is physically in one location, it includes representatives from every region to ensure every region’s nuances are accounted for.

2. Develop One Framework with Flexibility in Execution

While there are many differences in background checks across regions, there are many aspects that can be consistent regardless of local laws or culture. It is important that an organization define a global program with a single framework by defining those attributes that remain the same and implement effectively across all regions while managing globally. This includes:

• Goals and objectives aligned with corporate values regardless of region or location
• Common set of defined terminology to enable organizations to have the same language and promote conversation globally across the organization
• Consistent client and candidate experience – regardless of country, every hiring manager is following the same process, and every candidate is leveraging the same software

Conversely, there are many differences across regions within the program execution. And so the program must support flexible execution of the framework across regions.

For example, a single platform can be selected and rolled out globally. While every region is leveraging the same provider, software, and user interface, the interface can include variability in the candidate questions in each region, and the interface language can vary as well based on region.

Another example is complying with General Data Protection Regulation (GDPR). GDPR is a regulation in European Union (EU) law covering data protection and privacy. While the US has sector-specific laws and state-level legislation around data protection, the GDPR was designed to harmonize data privacy across the whole of the European Union, allowing citizens to better control their data with a need for privacy by default and giving individuals the right to request the deletion of their data – with businesses facing significant fines if these obligations are not met.  However, regardless of the data collected, or the candidate questions asked, the experience remains consistent. The data (albeit different data) is presented in the same way, the same governance structures are defined around decision making, and the same terminology is used across teams.

The program, products, and technology need to be flexible and dynamic to account for the cultural and legal differences within the consistent framework and experience.

3. Regional Support

To successfully support our client’s global background check programs, Sterling mirrors client program models with client support. We look at the center of excellence which includes representation from the varying regions and develop a center of excellence in the same region while building ‘satellite’ support in each of the respective regions. The satellite support is critical, because by building out a team in every supported region we develop in-market expertise that we wouldn’t otherwise have access to. With this knowledge, not only is the team equipped to support the region in their language with an understanding of local laws and culture but can work to develop solutions and fulfillment that directly supports the regional market.

A Background Check Program Is Never ‘Set It and Forget It’

A global background check program is no different than a standard program in that it constantly requires tweaking. Legislation changes, technology advances, and new data becomes available. As a result, the Sterling Customer Success team partners closely with clients to provide regular guidance, best practices, and recommendations. We are continually learning and adapting, as well as adding new products to support our clients.

Are you ready to develop a global background check program, or review your existing program and see if it needs tweaking? Contact us for more information.

The information contained herein is for informational purposes only. Sterling is not a law firm, and none of the information contained in this notice is intended as legal advice. Clients are encouraged to consult with their legal counsel about the impacts of any requirements. This, and other important information can be found on the Sterling website at sterlingcheck.com.

Sterling is not a law firm. This publication is for informational purposes only and nothing contained in it should be construed as legal advice. We expressly disclaim any warranty or responsibility for damages arising out this information. We encourage you to consult with legal counsel regarding your specific needs. We do not undertake any duty to update previously posted materials.