Frequently Asked Questions (FAQ)
What is ClearForce?
ClearForce is a workforce assurance and employee risk management solution. ClearForce protects organizations and employees from workplace crime through continuous, event-based real-time alerting of misconduct and unusual high-risk behavior of employees and contractors that may present a level of risk to an organization, its employees, or its customers.
What types of organizations use ClearForce?
Any organization that performs a pre-hire background check. Companies that have job roles with access to cash, financial transactions, credit card and customer PII, trade secrets, sensitive confidential information, healthcare records, prescription drugs, unsupervised employees with access to customers or secure infrastructure or children, employees with access to restricted facilities, employees that drive a vehicle for work, employees that deliver directly to consumer residences, and employees with a US government clearance.
What are the sources of alerts?
ClearForce typically generates real-time alerts that align to the organization’s pre-hire background check, which commonly includes criminal activity and leading indicators of material financial stress.
How often are alerts received in ClearForce?
The frequency of criminal arrest alerts varies by employee base. On average, for a typical workforce, approximately 2% of employees are arrested each year, 10% to 12% within a 5-year period, and 15-20% within a 7-year period. Organizations that perform pre-hire background checks would expect lower frequency. Financial alerts are often divided into single alerts and policy alerts. It is very uncommon for ClearForce customers to act on a single financial alert. Instead, most customers use the policy feature in ClearForce to define a specific pattern or combination of financial alerts, within a given time-period, for which they may initiate action based upon very unusual activity. ClearForce pre-defines policy and trains on the configuration of policy based on employee roles.
What other types of alerts can ClearForce receive?
ClearForce has an open API to receive and centrally adjudicate other external alerts based on your organizations specific requirements. In addition to criminal and financial, companies may also have alerting from an employee’s presence on a wanted or watch list (e.g., FBI, Sex Offender Registry, Interpol).
Do organization add staff to support ClearForce?
No. Often, policy is set to prioritize the workload based upon available HR and investigative resources.
What actions would qualify as adverse action on an employee?
A job change, transfer, demotion, termination, change in compensation or benefits may be considered adverse action.
Can ClearForce accept internal cyber and information security alerts?
Absolutely, ClearForce has an API to support the real-time input of internally generated alerts, which can then be centrally adjudicated with other alerts and incidents in the ClearForce system.
Does ClearForce scrape the internet?
Can ClearForce support Social Media?
Yes, ClearForce can support social media in one of three ways. First, ClearForce enables an investigator in ClearForce to paste known social media information directly into an existing employee case to support the adjudication process. Second, if desired, we partner and integrates with leading social media technology companies to create a formal and complete point-in-time social media report to support the adjudication of an employee case. Third, if desired, we partner and integrate with leading social media technology companies to create social media profiles, define key words and phrases and deliver alerts via monitoring of those profiles and words/phrases.
Can ClearForce support foreign travel and foreign contact requirements?
To satisfy US Government security clearance requirements, ClearForce enables the automated capture and centralized retention of self-reporting for foreign travel and foreign contact.
Privacy & Consent
How is employee privacy protected?
ClearForce operates with 100% employee consent, much like the consent obtained in a pre-hire background check. The organization transparently obtains consent to receive ongoing alerts for those specific events or actions it believes it needs to know about in order to manage safety and security. ClearForce helps organizations prevent misconceptions of the information that the employer obtains for security assessment.
How does an organization obtain consent?
Some companies have already captured consent as part of their new hire background screening, which also enables ongoing post hire rechecks or review. Some companies include modifications as part of a quarterly or annual HR handbook update. Some companies update their new hire consent to include on-going post hire checking. Some companies have direct outreach and communication to obtain new consent forms from existing hires. ClearForce provides sample consent forms in order to make this process easier and recommends legal counsel review prior to use.
Do organizations need consent from all employees?
In many companies, not every job role represents a material risk to the organization; therefore, not every job or employee is included in ongoing alerts. The organization identifies the appropriate job roles and defines the appropriate alerting sources and policy based upon the risk each job represents. Consent is only required for the specific job roles included for ongoing alerts. Companies define their individual policy when an existing employee does not consent and often align consent requirements to expanded responsibilities or roles and associated advancement and compensation, rather than take punitive action.
Can ClearForce be used to target specific individuals?
No, ClearForce does not search for data or negative information about an employee. ClearForce only receives alerts when organization-defined events occur. ClearForce also prevents bias and favoritism with alerts through initial anonymity. In ClearForce, alerts are first analyzed with the identity of the individual hidden. Only a description of the alert and role of the employee within the organization are viewable by a permission-based administrator during initial review. Alerts are then recommended for investigation based on the nature of the alert, the role of the individual within the organization, and the risk to the organization.
What protections are in place to ensure all employees are treated fairly?
ClearForce was designed to ensure fair and equitable treatment under EEOC law and FCRA regulations. Organizations must complete a standardized workflow process before considering any negative or adverse action. Furthermore, all data involving an alert and adjudication remains in the system, is centrally managed and archived, and all actions by permission-based administrators is comprehensively logged and retained.
Who has access to the information in ClearForce?
Permission-based roles are typically assigned to Human Resources and Internal Investigations. Large enterprises can have numerous roles; small businesses may simply have HR or financial managers and a business executive. ClearForce does not access or view the alerts or personnel information in the system.
Does ClearForce generate alerts on family members or associates?
No, only employees and contractors who have provided consent.
Are financial alerts generated for all employees?
Financial alerts are typically limited to those employees that have direct access to cash, financial transactions, customer PII and credit card data, trade secrets, sensitive confidential data, executives, or job roles where restricted access could be violated or sold for personal gain. Certain states have specific laws that govern an employer’s ability to use credit information for post-employment vetting. The legally compliant workflow in ClearForce helps companies standardize and ensure compliant use.
What specific financial data generates alerts?
Material indicators of severe financial stress or unusual financial activity can create alerts within ClearForce. These include significant account delinquency, significant loan balance changes beyond a pre-defined threshold, and excessive volume of new account openings.
Does ClearForce generate alerts for changes in credit bureau or FICO scores?
No, credit scores do not create alerts.
Does ClearForce generate alerts if an employee misses a credit card payment?
No, alerts are focused on combinations of very advanced delinquency within a short period of time and most employers will create policy only focused on the most severe indicators of financial stress.
Does ClearForce generate alerts for employees with imperfect credit who often miss credit card payments?
No, alerts are only focused on combinations of very advanced delinquency within a short period of time and most employers will create policy only focused on the most severe indicators of financial stress.
If employees had credit problems in the past, will that generate an alert in ClearForce?
No, ClearForce only generates alerts for financial alerts for current and future activity, not past activity.
Does ClearForce affect credit scores and show up as in inquiry on a credit report?
No, ClearForce does not affect credit scores or post as an inquiry on a credit report.
Will financial alerts result in negative action?
The most common action resulting from a financial alert is increased supervision and review. Depending on the job role, organizations will often ensure that financial stress and issues do not manifest in negative actions or behavior at work. For certain roles requiring stable credit behavior, credit counseling and training can be provided. Employee meetings or interview may be used for certain accounting or financial roles where the alert involved material, unusual transactions (e.g., an accountant’s mortgage and debts repaid rapidly in a month or two). Organizations may incorporate elements of financial wellness programs to assist employees under financial stress.
What if the financial data is inaccurate or incomplete?
Financial data is governed by the Fair Credit Reporting Act (FCRA). Prior to an organization taking adverse action, employees have the right to be notified of their rights under FCRA and to dispute the accuracy and completeness of the data directly with the consumer reporting agency. ClearForce provides full functionality to support auto redress, adverse action notification, and dispute resolution.
What is the Fair Credit Reporting Act (FCRA)?
FCRA is a law enacted in 1970 to promote accuracy and privacy of consumer information in the files of credit reporting agencies. FCRA regulates the collection, dissemination, and use of a range of consumer information, including consumer credit information. It is enforced by the US Federal Trade Commission and the Consumer Financial Protection Bureau.
How does FCRA apply to my use of ClearForce?
Anyone who uses credit information to take adverse action against an employee must comply with FCRA.
Where can I get more information on FCRA?
What is EEOC?
EEOC is the U.S. Equal Employment Opportunity Commission, which enforces federal laws that make it illegal to discriminate against a job applicant or employee due to race, color, religion, gender, national origin, age, disability or genetic information. EEOC also enforces rules that make it illegal to discriminate because a person complains about discrimination, files a charge of discrimination, or participates in an employment discrimination investigation or lawsuit.
Why does EEOC need to be considered when using ClearForce?
EEOC prohibits employers from terminating employment based on arrest data. As a result, it is more common for companies to consider conviction vs arrest data; however, conviction data has substantial delays in timing and often differs via plea bargains from the initial arrest. ClearForce makes arrest data actionable by providing a standardized “mini investigative” workflow that directs an organization to capture addition required information prior to any personnel actions.