Q. My company takes painstaking efforts to ensure that all of our employees are properly background screened and vetted to help ensure the safety and security of company personnel and assets. However, I can’t say with confidence that the same is true for the rest of our modern day workforce of temporary help, contract workers, on-site suppliers and vendor personnel. How do I ensure that the same level of diligence is put forth in vetting these “outside” workers who have similar access privileges to company facilities, personnel and information?
A. Good question! Many companies do not insist that their selected vendors, suppliers and contractors screen their workforce with the same diligence that the company screens their own employees; often times giving these “outside” workers the “keys to the store,” granting them open access to people, facilities, property and information. Not only is it a good business practice to vet your suppliers, vendors and contract workers but you may be contractually and/or legally obligated to do so. So what can you do to help ensure your contingent/outside workforce is vetted to your required level of clearance? Consider the following suggestions:
• Develop a company policy that requires contingent worker background checks to be conducted; a policy that addresses who, what, when, where and how.
• Develop and implement contractual agreements with suppliers of contingent personnel to vet their representatives to a specified level, conducting the required background checks to help ensure a mandated level of clearance. Be sure that your contractual requirements do not run afoul of local law, industry regulations or company culture.
• Determine what your company's contractual, regulatory or legal obligations are related to the background screening of your contingent workforce.
• Define your screening objectives by outlining both the overall and specific purposes and results.
• Determine what, if any, process differences are necessary to address different jobs, workers, suppliers, contractors or vendors.
• Determine what level of involvement you and/or your company needs to have in the actual background screening and clearance process.
• Determine who and how background checks and clearances will be communicated from the contingent workforce to your company.
• Develop and distribute subject related communications to all parties involved; outlining rules, roles, responsibilities and expectations.
• Determine who or how the costs associated with these background screenings will be addressed.
• Determine a conflict resolution process; identify how and who will address debatable screening results and issues.
Developing a process to accomplish your contingent workforce due diligence objectives should be specific to your industry, business structure and company culture; something that helps to ensure proper screening without impeding workflow, business operations or being detrimental to company culture. Be sure to include partners, e.g., Human Resources, Business Operations and Legal that are critical to implementing and maintaining an effective contingent workforce due diligence program. Help your vendors, suppliers and contractors understand how important due diligence is to your company and what the benefits are to them of having a vetted workforce.
While nothing is fool proof and even with the best of due diligence programs someone or something can slip through the cracks, a properly designed and executed contingent workforce screening program is one more component of a safe and secure workplace. It’s your business at risk, including your operations, brand, customers and employees. It does not matter that the person responsible for a data breach is a vendor with false credentials. It does not matter that the person who suddenly becomes violent in your workplace is an on-site supplier with a history of violence. It does not matter that the person who fails to comply with check and balance procedures enables a million dollar fraud to occur is a contractor with a criminal record. It is your reputation, your customers, your employees and your operations that are at risk. Know who has the “keys to your store.”
Answer provided by Kenneth Kasten, Security Executive Council Emeritus Faculty.
