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Reliability Screening and Fingerprints: What You Need To Know About Public Services and Procurement Canada’s New Requirements
Fingerprints are becoming a mandatory requirement to work on Government of Canada contracts – is your organization ready?
As most companies doing work for the Government of Canada already know, security clearances are a mandatory step before any employee or contractor can get access to the Government’s classified documents or sensitive sites. Public Services and Procurement Canada has recently announced that a fingerprint-based criminal record verification will become a mandatory step for all government clearances, from reliability status to confidential, secret and top secret levels.
What is a Reliability Status?
A Reliability Status is granted to an individual who has successfully undergone a Security Screening with the Government of Canada’s Personnel Security Screening Division (PSSD). Its purpose is to ensure that individuals given access to protected government assets or data do not pose a reliability or trustworthiness risk.
The Reliability Screening is composed of the following elements:
- Surname (maiden name) and given name(s);
- Verification of date of birth;
- Verification of address for the last five years;
- Verification of educational and professional qualifications or trade certification or accreditation;
- Verification of employment history;
- Assessment of performance reliability and personal character by checking with previous employers and identified references;
- A written declaration concerning any conviction for a criminal offence for which a pardon has not been granted;
- A criminal record check;
- A personal credit check (if required);
- Other checks, as determined by the Manager, Personnel Security Screening Division (PSSD) depending on the particular requirements specified in the contract; and
- A Resolution of Doubt (RoD) interview (if required) for cause.
Government authorities must be able to conduct a background inquiry covering the last five years to grant someone a Reliability Status.
Who needs a Reliability Status?
The Government of Canada’s Policy on Government Security prescribes a Reliability Status for any individual who may have access to protected information or assets. In other words, almost anyone performing work for a contract for the Government of Canada is required to undergo a Reliability Screening prior to being given any access to the Government’s data or assets. If your company currently has a contract with the Government, you must not only screen anyone who performs work for this contract, but also any employee who may be able to access the contract’s protected information or assets.
What do I need to do to obtain a reliability status for my employees?
Prior to requesting a Reliability Status for someone, you are responsible for ensuring that the applicant can provide sufficient information to permit the government authorities to conduct a background inquiry covering the last five years. You are responsible for verifying:
- Applicant’s Identity
- Five-year Address History
- Education/Professional Qualifications
- Employment History
- Character/Employment References
You should only request a Reliability Screening for your applicant after a thorough preliminary verification of the above information. It is imperative that you keep records proving these verifications were made as this process can be audited by governmental authorities.
Can my background screener perform my employees’ Reliability Screening?
A Reliability Status can only by granted by PSSD; no third parties are authorized to issue it. However, the best practice is to have your background screener conduct a preliminary background check on any employee prior to sending a request to PSSD. It is the best way to ensure that you have duly carried out your responsibility to pre-screen your applicant, to keep auditable records of your pre-screening process, and most importantly to make sure your applicant will successfully undergo the Reliability Screening process. As the Reliability Screening can be a lengthy process, you do not want to hire someone to work on a government contract only to find out months later that they failed the Reliability Screening and that you’ve lost time and money training them for a role for which they will never receive the required clearance.
What is the new PSPC policy?
Public Services and Procurement Canada (PSPC) has announced that as of February 1st, 2017, electronic fingerprints will become a mandatory requirement with reliability screening requests. This means that, in addition to the current “Personnel Screening, Consent and Authorization Form”, candidates for a Reliability Screening will need to submit their electronic fingerprints with the application.
Why did PSPC’s policy change?
Reliability Screenings have always included a criminal record check. Up until now, these verifications were made by running the applicant’s name and date of birth in the Canadian Police Information Centre (CPIC) (referred to as a name-based search). This allows for a comprehensive, national criminal record search. However, in specific circumstances, a name-based search can create a risk for false positives due to someone having the same name and date of birth as a convicted criminal. Moving forward, PSPC will continue to perform the same level of criminal record search in the same database as before, but they will run the search using the applicant’s fingerprints instead of name and date of birth combination. This means that the new verification is neither more nor less exhaustive than the former name-based search, but it will yield more accurate results.
How does the fingerprint requirement impact my background check process?
The new fingerprint requirement should not have any impact on your preliminary background check process. To make sure your applicant can successful undergo the reliability screening, you probably already run a national name-based criminal record search when you hire someone new. At the pre-screening stage, this search remains the best value in terms of time and money since it is cheaper and much quicker than a fingerprint-based search, which takes anywhere from 5-10 business days (if clear) to several months to process (if your candidate has any former criminal convictions).
Where PSPC’s new requirement will impact your background check process is when you are ready to send the reliability screening request, once the applicant has passed your own pre-screening. In addition to having the applicant fill out PSPC’s authorization forms, you will need to have them get their fingerprints electronically taken with a police service or an accredited civil fingerprinting agency. Upon doing so, the applicant will receive a reference number called Document Control Number, which must be submitted with the candidate’s authorization form. Note that you do not need to wait for the results of the applicant’s fingerprint-based search before sending your Reliability Screening request; you only need to ensure that the fingerprints are taken and submitted with the Reliability Screening request since PSSD will run the fingerprint-based verification themselves.
How can I manage the new fingerprinting requirement of the Reliability Screening process?
You have several options to manage this new fingerprinting requirement. When you have identified a need for someone to obtain a Reliability Status, you can provide them the Fingerprints Applicant Request Form and direct them to the police service or civil fingerprinting agency closest to their place of residence to have their fingerprints taken. Fingerprints are valid for one year, so you can ask the applicant to do this as soon as they start preparing their Personnel Screening authorization form.
Make sure to check with local police services if they offer fingerprinting services to the general public before directing your applicant there because a lot of police services have stopped offering these services and refer the public to civil fingerprinting agencies instead.
If you prefer not to have to manage the fingerprinting process, you can check with your current background check services provider if they can handle the fingerprinting process for you. A company that will do so is usually an accredited fingerprinting agency and they will contact your applicant directly to arrange for them to have their fingerprints taken at one of their offices or at the applicant’s closest fingerprinting location. Your background screener will provide you the Document Control Number you need to send with your reliability screening request.
Feel free to contact one of our experts to find out more about Reliability Screening or our fingerprinting coordination solutions.