6 Best Practices for Implementing a Continuous Monitoring Program

For Cisive’s most recent benchmark report, Cisive Insights: Talent Screening Trends 2021, Cisive surveyed more than 1,500 human resources, talent acquisition, compliance, and recruitment professionals worldwide to get a big picture view of the talent screening landscape during the COVID-19 pandemic.

The 2021 survey discovered that most of the background checks introduced in 2020 consisted of ongoing or continuous monitoring. Over 31% of respondents said they introduced an ongoing monitoring program and 30% said they introduced a rescreening program for employees. Looking ahead into the coming year, employers are focused on hiring and onboarding both remote and in-person employees, creating a need for policies around background screening and continuous monitoring for a hybrid workforce.

The most crucial component of background screening – and continuous monitoring – is to establish an employee experience that is as similar as possible for both remote and in-person roles (or a blend of both). Without an equitable screening process, employers may open themselves up to litigation for discriminatory hiring practices. For example, if an employer only implements continuous monitoring for onsite employees and doesn’t screen remote employees in the same way, a case could be made for disparate treatment.

 

What is Continuous Background Screening?

Continuous employee screening, sometimes known as continuous employee monitoring or “infinity screening,” is the practice of conducting criminal background checks and drug tests for existing employees on a regular or intermittent schedule.

We tend to think of background screening as a safeguard against physical threats at an employer’s workplace. However, internal threats to your company don’t always take place in a physical location. Consider cybersecurity, data protection, and what kind of damage criminals who are very good at hacking into a company’s infrastructure could do if they had access through your company’s intranet or VPN. If an employee is discovered to have a history of criminal activity that includes cyber theft or embezzlement, it’s imperative that screening uncover this information before a new employee has virtual access.

 

Continuous Screening Best Practices for a Hybrid Workforce

The following is an abbreviated list of areas to consider when creating a policy for continuous monitoring for employees in a hybrid workplace, from disclosure of your policy to employee education.

1. Job applications: Your job application forms should make it clear that any falsehood or omission from the applicant can result in termination no matter when it is discovered. Your company’s employee handbooks should also include language on what will happen if your company’s background screen (at any point) discovers falsehoods or omissions post-hire.
2. Employee consent: The Fair Credit Reporting Act (FCRA), which governs how and when companies conduct background checks, requires employee consent, and if a company plans to discipline or fire a worker based on the findings, it must give the employee an opportunity to review the data for errors or explain any mitigating circumstances. Your background screening vendor should understand this process from start to finish and can ensure that your company remains compliant throughout a continuous employee screening process.
3. Contractor screening: With a growing number of companies using contract and gig workers in order to expand and contract their workforce based on supply and demand, employee self-reporting policies don’t apply to these workers, making the business case even greater for continuous employee background screening and monitoring.
4. Employee education: For new remote or onsite employees coming onboard when a policy is already in place, continuous screening is less of an issue. However, when you implement it as a new policy your current employees may have more difficulty accepting it. Your HR team will need to conduct some employee education on the rationale of continuous screening, and show how the policy benefits everyone.
5. International screening: Hiring for remote roles means that your company can recruit employees globally. Conducting checks internationally means that employers must have a comprehensive understanding of the globally diverse safeguards for the protection of personal data privacy and data transfer security.
6. Accuracy of discovery: Avoiding liability means that your screening should provide the most up-to-date and accurate information on candidates and employees. Databases available to private employers are not always complete, accurate, or current. In large states like California, New York, and Texas, the statistical possibility of error is large enough to question the real value of search results. Background search firms that are able to access these databases are going to yield more reliable results.

 

Having a hybrid workforce gives employers flexibility and scalability, but the complications around avoiding disparate treatment between in-office and remote workers along with the regulations for screening contingent and international employees will be a challenge for internal HR teams to manage on an ongoing basis.

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