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Background Checks and
Drug Screening

NAID Associate Member

"Background checks are one of the most commonly misunderstood NAID Certification requirements, and the most common cause for delays in the certification process." NAID Certification Advisory, June 2011

A Matter of Fact is an Associate Member of NAID familiar with the NAID Certification requirements. We are accredited by the National Association of Professional Background Screeners (NAPBS®) Background Screening Credentialing Council (BSCC).

Whether you want to be NAID Certified or simply conduct thorough Employee Background Checks, A Matter of Fact can help.

We Help You Meet NAID Certification Requirements
A Matter of Fact is an experienced Employee Background Screening vendor that understands the NAID background screening requirements. We provide employee screening services that meet the following NAID requirements:
  • I-9 or Proper Work Permit/Registration
  • Employment History Verification
  • Social Security Header Search
  • Criminal Record Search
  • Driver's License Verification
  • Drug Screening

Summary: NAID Certification Employee Screening Requirements & Our Products
New Hire Screening Requirements (Includes New Certification)
NAID Certification Requirement
[Certification Criteria Section #]
Our Product
Form I-9 and Employment Eligibility Verification [1.1] Form I-9 and E-Verify
Employment History Verification [1.2] Employment History Verification of all employers for the past 7 years
Social Security Header Search [1.2] Social Security Number Scan
Criminal Record Search [1.2] County Criminal Records Check for each county of residence and employment for the past 7 years
     AND
'Statewide' Criminal Records Check for each state of residence and employment for the past 7 years
     AND
Federal Criminal Records Check for all Federal Districts in each state of residence and employment for the past 7 years
Drug Screening [1.2] Employment Drug Screening
Drivers License Verification [1.5] Motor Vehicle Report
Note: International Searches are available for employees who have lived or worked outside of the United States. See International Background Checks.
Ongoing Screening Requirements
NAID Certification Requirement
[Certification Criteria Section #]
Our Product
Random Drug Screening [1.3]
     OR
Local Management trained in a qualified "Substance Abuse Recognition Awareness Program" [1.3]
Employment Drug Screening
     OR
AWARENESS Supervisor Training
Social Security Header Search every 3 years [1.4] Social Security Number Scan if the employee has moved or taken an extended leave of absence
Criminal Record Searches every 3 years [1.4] County Criminal Records Check for each county of residence and employment since the last screening
     AND
'Statewide' Criminal Records Check for each state of residence and employment since the last screening
     AND
Federal Criminal Records Check for all Federal Districts in each state of residence and employment since the last screening

NAID: New Employees Must Be Screened Prior To Granting Access
(This statement was originally published in the 'NAID Certification Advisory.')

New employees must be screened and confirmed to meet all screening requirements of Sections 1.1 and 1.2 of the NAID AAA Certification Application prior to having access to confidential material. They must also sign an acknowledgement of written policies and procedures (Section 2.1b). Allowing an employee access to confidential material without proper screening will result in the assessment of a Level 3 violation by the NAID Certification Review Board, with mandatory fines and possible removal of certification.

NAID (2012): Federal Criminal Record Checks Now Required
(This statement was originally published in the 'NAID Certification Advisory.')

Federal Background Checks (Sections 1.2 and 1.4) – In addition to Statewide and [County] criminal background checks in the United States, companies must now use checks for the Federal District Courts in all states appearing on the Social Security Header Search. For companies that are already Certified, this requirement is grandfathered. It will only be required for new employees hired after Jan. 1, 2012, and for any ongoing or random screenings of all employees, as required by Section 1.4.

NAID: Elements Of A NAID-Approved Background Check
(This statement was originally published in the 'NAID Certification Advisory.')

Background investigations are a critical aspect of a NAID Certified secure destruction operation. They assure the customer that their confidential information is not being handled by anyone who has committed a felony theft crime. Therefore, this requirement should not be taken lightly.

Background checks are also one of the most commonly misunderstood NAID Certification requirements, and the most common cause for delays in the certification process. Due to the nuances of the different jurisdictions and the varied ways in which records can be accessed, NAID requires the use of a third party vendor. However, the certified company – or the company seeking certification – should be partnering with their vendor to ensure that the checks are done correctly. Completely passing off this important requirement into the hands of a third party can produce problems that prevent a company from being certified, or may cost additional fees when an auditor requests that the checks be redone.

The fact is, anyone with an Internet connection and some level of knowledge can open up shop as a background investigation company. Therefore, it is important to vet potential vendors to ensure that the checks are being run in accordance with Certification criteria. No destruction organization would purchase a shredder unless they knew the expected output/particle size; in the same way, it is a mistake to hire a background check company without certainty that the product will meet NAID Certification standards.

First and foremost, the potential vendor should be queried to see if they are familiar with the NAID criteria. If not, provide them with a copy of Section 1.2 from the NAID AAA Certification Application, which lists the criteria in detail. Or, invite them to call the NAID office with any questions.

Next, ask for a sample report to make sure it includes the following:
  • A Social Security Header Search, which is comprised of a list of addresses and names derived from the person’s social security number (Note: this is NOT the same as a social security number verification).
  • A list of all State records that were checked, based on the results of the Header Search, the name(s) that were run in each state, and the actual results. If a certain state will not allow criminal record searches, ask the vendor for a letter attesting to the fact that the state is "closed," and then make sure criminal records are still pulled from all counties in that state that came up on the Header Search.
  • A list of all County records that were searched, based on the results of the Header Search, the name(s) that were run in each county, and the actual results.

The final step is to thoroughly review all employee background search reports to ensure that all required elements are included. If any employee or potential employee has been convicted of a felony theft-related crime within the last seven years, they cannot have access to confidential material under NAID Certification.

If anything is missing from the report, contact the vendor to request a correction or additional information, even if a scheduled NAID audit is not looming in the near future – an unannounced audit may be! If an auditor discovers a discrepancy during an unannounced audit, it will go before the Certification Review Board and may result in assessed fines, even after the missing information is corrected.

Note: Since this was published Federal Criminal Record Checks have been added to the requirements.

NAID: Don't Get Caught with Incomplete Background Checks: Know Your Obligations
(This statement was originally published in the 'NAID Certification Advisory.')

Employee screening is an essential part of the NAID Certification Program. Physical building and transportation security protects the confidential material from outside security breaches. Screening employees helps to protect against internal breaches.

The background check requirement should be viewed from the customer’s perspective, as it is intended to invoke customer confidence, and not for information destruction companies to use as a hiring tool, although it can certainly be used for that purpose, as well. Remember that the customer is entrusting people they do not know to handle their confidential material. Therefore, the customer expectation is that the checks are done as thoroughly as possible.

The Social Security Header Search (or Social Security Trace) is required to ensure that the correct records are checked for each employee. This is a non-financial run of a person's social security number. It returns all names and addresses that have been used in association with that SSN. The background check company is then able to derive a list all names, counties, and states that need to be run for that employee. The Social Security Header Search is NOT the same as a social security number verification! The verification only confirms that a SSN is valid.

Following are some tips for meeting the NAID Certification requirement for Background Checks:
  • Never assume that a background check company is running checks in accordance with NAID standards. Just because they are in the business and "know what they are doing," does not mean they are familiar with NAID's requirements. Background check companies should always be vetted, as with any vendor. NAID does not certify vendors, including those that are listed in the NAID Market section on the NAID web site. It is the destruction company's responsibility to make sure the service being provided meets the company's needs.
  • Provide the background check company with a copy of Section 1.1 of the NAID AAA Certification Application. Suggest that they contact the NAID office with any questions.
  • The auditor must be able to verify that the Social Security Header search was done. The report should clearly distinguish that a full search was conducted, followed by the results of that search. NOTE: A SSN followed by a list of addresses does NOT necessarily indicate that the addresses were derived from the SSN.
  • The report should also clearly distinguish which states and counties have been run. This must match the list from the Social Security Header Search.
  • The results of the county and state searches must be reported. A generic "no records found" indication after the employee's name does not allow the auditor to verify that the correct jurisdictions were checked. The auditor must also be able to see any specific records that are returned, in order to determine if the charge would preclude someone from being in an access position.
  • Federal/national searches cannot be used in lieu of state and/or county checks. This is a database that stores records from federal courts only. Criminal proceedings that were processed in local or state courts will not show up in a federal search. There is no reliable blanket search available for all criminal records in the United States.
  • County and state searches must be pulled directly from the county and state databases. Checks pulled from a secondary database compiled by a third party is often offered as an "instant" search option; however, the data may not be as accurate, and it is does not meet the NAID Certification standards.

Note: Since this was published Federal Criminal Record Checks have been added to the requirements.

NAID: Unannounced Audit Non-Compliance Issues
(These statements were originally published in the 'NAID Certification Advisory.')

Ongoing Criminal Background Screenings are not being done
Section 1.3: All Access Employees have criminal record searches conducted every three years by the following method (select one):
  • Option #1: One-third of Access Individuals have been randomly selected and criminal record searches conducted annually.
  • Option #2: One-third of all Access Individuals are screened the first year, a different 1/3 are screened the following year, and the remaining 1/3 are screened in the third year.
  • Option #3: All Access Individuals have Criminal Record searches conducted every three years.

Whichever option is chosen, it must be done consistently. This requirement for ongoing screenings is separate from the requirement for each employee to have an initial pre-hire screening.

Tips:
  • Keep the ongoing criminal background screenings together in a separate file, organized by date. You may also keep a copy in the employee’s file; however, having all the random screenings together will make it easier for an auditor to verify that this is being done. (NOTE: this tip may also apply to random drug screenings)
  • New hire/initial screenings do NOT count toward the ongoing screening requirement.
  • Ongoing screenings do not need to go back seven years. You need only go as far back as the employee’s last screening.
  • Make sure you are using a third party who runs criminal background searches in accordance with NAID Certification Standards, as set forth in Section 1.2 of the NAID AAA Certification Application.

Criminal Background Checks not done according to the NAID requirement
Section 1.2 (excerpt):Screening for Access Individuals must include:
  • 7 Year Criminal record Search:
    • Social Security Header Search
    • Statewide database search for all states on SS Header Search
    • County database search for all counties on SS Header Search

Not all background checks meet the NAID Certification requirements, which are very specific to ensure that an employee’s records are thoroughly checked before they are allowed to have contact with confidential material. The purpose is to assure the customer that only screened individuals are handling their sensitive data; therefore, proper documentation is required to verify that Access Employees have been properly screened. New hires must be cleared of any felony crime involving theft within the past 7 years. Please see Sections 1.1 and 1.2 of the NAID AAA Certification Application for a complete description of initial employee screening requirements, and Section 1.4 for a description of the requirement for ongoing/random screenings.

Tips:
  • Background searches must be conducted by a third party.
  • NAID does not endorse any background check company, including those that are listed at www.naidonline.org in the NAID Market Section. This section is provided as a member resource, but it is still the member’s responsibility to make sure that the checks are being done in accordance with NAID Certification standards.
  • Ask your background search company if they are a member of NAID, or if they are at least familiar with NAID. Again, while this does not guarantee that the results will be correct according to the NAID standards, it does indicate that they may be more familiar with our processes.
  • Provide your background search company with a copy of the NAID Requirements, as found in the NAID AAA Certification Application or refer them to our Headquarters if they have questions or concerns. We will be glad to explain these requirements to them.
  • An auditor can only verify that the searches were done properly if s/he can see all aspects of the search. The report should include the following:
    • Results of the Social Security Header Search, including all names and addresses associated with the employee’s social security number within the last 7 years.
    • Results of each county and each state that was run, followed by the results. This should match up with the results of the Social Security Header Search.
    • If a crime is reported, it must list the date and disposition (i.e. arrest, conviction, etc.), the crime that was committed or alleged, and the charge (i.e. misdemeanor or felony).
  • Searches must be done directly from the county and state databases. Secondary or "blanket" databases are not acceptable.
  • Federal searches are not required, nor are they to be used in lieu of county and/or state searches.
  • Some states are "closed" states, and thus do not allow checks of the statewide database. In this case, a letter from the background search company confirming that a particular state is closed, along with the applicable county searches will suffice. You are NOT required to search every county in that state.

Note: Since this was published Federal Criminal Record Checks have been added to the requirements.

NAID: Your Questions Answered
(These questions and answers were originally published in the 'NAID Certification Advisory.')

Q: My company is participating in a substance abuse recognition training program in lieu of random drug screening. Do I need resubmit the approval form every time I submit my application for recertification?
A: Once NAID has approved a substance abuse recognition training program, the approval is valid as long as certification has not lapsed. Maintain the signed approval form to show to a NAID auditor upon request, along with verification that supervisors have completed the testing on an annual basis.

Q: If I hire an employee who has worked for another NAID Certified company, do I still need to run background checks and drug screenings?
A: Employees who have worked for other NAID certified companies in the past are NOT exempt from the background and drug screening requirements of Section 1.2 of the NAID AAA Certification Application. You must still run the full screenings and keep a copy in the employee’s file for the auditor’s review.

Q: Why does NAID require federal background screening and how can I meet this requirement?
A: NAID requires federal background screening to check for felony theft convictions tried in federal district courts. County and statewide repositories only hold arrest data that correspond with crimes processed in county and state courts, respectively. A multilevel search of county, state and federal courts ensures a more comprehensive background investigation of employees with access to the confidential material in which your organization has been entrusted.

The federal background search requirement can be met in one of the following ways. A third party background search investigation company must always be used in all background screenings.
  • Direct search of federal district courts, according to the result of the employee’s social security header search (i.e., a list of all addresses and names used within the last seven years)
  • Public Access to Court Electronic Records (PACER): An electronic database used to access information from all federal district courts in the United States (Note: This is the only secondary database accepted for NAID Certification background checks. County and statewide checks must always be pulled directly from the courts.)
  • FBI fingerprint search, if available

As a reminder, all employees hired prior to Jan. 1, 2012, were not required to have a federal background screening. The screenings for new employees and employees hired after Jan. 1, 2012, (Section 1.2 in the NAID AAA Certification Application) AND employees chosen for random screening (Section 1.3) must include a federal search.

Note: federal criminal record checks are required for the ongoing screening of employees hired prior to Jan. 1, 2012. See the following Q & A.

Q: If an employee was exempt from the federal background screening requirement because they were hired prior to Jan. 1, 2012, are they still exempt when I run their ongoing screening?
A: No. Ongoing criminal background screenings (Section 1.4 of the NAID AAA Certification Application) must always be done in accordance with the current screening requirements. This includes a search of federal district courts, even for employees that are exempt from the initial screening requirement due to their date of hire. Initial/pre-hire screenings (Section 1.2) need to go back seven years; however, ongoing screenings need only go back to the date of the employee’s last screening.

For example, if an employee was hired on Dec. 1, 2011, they were exempt from the federal background screening requirement when it went into effect on Jan. 1, 2012. In other words, you were not required to go back and run a federal screening on that employee to fulfill the initial screening requirement. Suppose that same employee is due for an ongoing screening in 2013. You must run the full county, state and federal search on that employee, but you only need to search back to December of 2011, when the most recent background check was run on that employee.

Q: Do I need to do a social security header search for random criminal background screenings?
A: Social security header searches are not required for ongoing or random background screenings if the employee has not moved since his/her initial or pre-hire screening was conducted. Simply run the current county, state and federal district(s). If the place of employment is in a different county or state than the employee’s residence, that county or state (and the county within that state) must be run, as well. Likewise, if the employee or the company location moved to a different state or county since the employee’s last criminal background check was done, run both states and/or counties.

Social security header searches are always required for initial screenings, which must be conducted prior to granting the employee access to confidential material.

Q: Is a national criminal background search the same as a federal search?
A: No, they are two different things. Typically, a national criminal background search is pulled from a centralized database of records that have been compiled from various jurisdictions in a country. Due to the high possibility of errors or incomplete data, the NAID Certification Program does not allow this to fulfill the requirements for criminal background investigations. NAID requires all background checks to be completed by a third party that performs direct checks of the appropriate jurisdictions and courts.

On the other hand, federal background searches pull from the records of federal district courts in the United States. This is another level of search, in addition to state and county searches. As of Jan. 1, 2012, all three are required for NAID Certification. However, if a company is already certified, they will not need to adhere to this [for employees hired before Jan. 1, 2012] until their NAID Certification comes up for renewal.

For Canadian background searches, this federal background search requirement is already being met if the searches are pulled from the Canadian Police Information Centre (CPIC). For locations outside of the U.S. and Canada, searches should be conducted in a manner that checks all local, state and federal jurisdictions as they apply and according to their availability.

Q: Is it necessary to re-run the Social Security Header Search for ongoing random criminal background screenings?
A: Ongoing or random criminal background screenings are required per Section 1.4 of the NAID AAA Certification Application. These are searches that are done in addition to initial or pre-hire screenings on all access employees. Certified companies have several options for conducting ongoing screenings. They may 1) randomly select 1/3 of the access employees to be screened annually; 2) divide all access employees into three groups, and screen one group a year on a rotating basis; or 3) screen ALL access employees once every three years.

If an access employee has already been fully screened initially or pre-hire, it is NOT necessary to re-run the Social Security Header Search for the ongoing/random screening. The purpose of the Social Security Header Search is to determine the names and addresses that are associated with a particular social security number, so that the appropriate names and jurisdictions can be checked for the criminal background screening. This must always be done for initial or pre-hire screenings; however, for ongoing/random screenings it can be assumed that continuous employment implies that the county or state of residence has not changed. Therefore, only the current county and state of residence needs to be run.

Having said that, if the employee has changed their residential address since their last Social Security Header was run, and if the new address is in a different county or state, then the additional county/state must also be run.

Social Security Header Searches are always required for initial/new-hire screenings, or if the employee has taken an extended leave of absence.

Q: I just hired a summer intern. Do I still need to run a background check on them?
A: Background checks are required for every individual who has access to confidential material, even if they are hired as an intern or for any other temporary purpose.

Q: What is the Substance Abuse Recognition Training Approval Form?
A: The Substance Abuse Recognition Training Approval Form (SARP Form) is necessary only when a company has chosen to put management and supervisors through an annual program that trains them how to recognize the signs of substance abuse in the workplace. This program can be used in lieu of random drug screenings, but only if it is preapproved by NAID and the applicant marks Option #2 in Section 1.2 on the NAID AAA Certification Application. To apply for approval, simply fill out the SARP form and submit it along with an outline of the program you have chosen. During the audit, the auditor will ask to see this form, which has been signed by a NAID Official to indicate approval, as well as proof that the training has been completed within the last 12 months. Please remember that the SARP does NOT take the place of the initial drug screening requirement. Each access employee must still have a pre-hire screening in their file.

Q: Do I need to hire a third party to do past employment verifications?
A: There is no need to hire a third party to conduct past employment verifications, provided that whoever is doing the verifications documents as follows:
  • The date of the attempted verification
  • Who was reached at the company
  • Whether or not the stated dates of employment were verified

If a company is no longer in business or if no one can be reached, simply document the attempt in the employee’s record. If an employee was unemployed or self-employed, document that as well.

The purpose of employment verifications is to check for holes in an employee's past. For example, if they claim to be unemployed during a certain period of time, but the Social Security Header Search reveals an address in another county or state during that same time, it may warrant further investigation.

Q: One of my employees tested positive for drug use. Will this affect my Certification?
A: NAID Certification requires that employers routinely test their employees for illegal drug use. A positive result, however, will not prevent someone from being in an access position, nor will it hinder your Certification. The purpose for the screening is to ensure that Certified companies are aware of any illicit activities of their employees, so that appropriate measures can be taken to address the issue. Certain employee actions and behaviors can result in a breach of the security of customers' confidential materials, which could adversely affect a company's certified status, as well as cause other legal ramifications. Therefore, while NAID does not take the results of drug tests into consideration for Certification purposes, a positive result should always be taken seriously, and a procedure should be in place for handling this type of situation.

As a reminder, the results of Criminal Background screenings WILL be taken into consideration during scheduled and unannounced audits. Certification criteria require that no individual is placed in an access position if they have been convicted of a theft-related felony within the last seven years.

Q: What should be included in my ongoing Criminal Background Checks? Do I need to screen the same as I did for the initial/pre-employment screening?
A: In addition to an initial criminal background screening for each access individual, NAID Certification also requires that 1/3 of access individuals are screening annually. This can be done in one of three ways:
  1. Randomly choose 1/3 of access individuals each year.
  2. Screen 1/3 the first year, a different 1/3 the second year, and the remaining 1/3 third the third year, so that over a three year period all access employees have been screened.
  3. Screen all access employees once every three years.

These ongoing screenings must be done in the same manner as the initial screenings, including the social security trace, county and statewide searches. However, you only need to go as far back as the last screening that was done for a particular employee. For example, if someone was hired in October, 2008 and they come up in June, 2010 for a random screening, you only need to search between those two dates.

Note: Since this was published Federal Criminal Record Checks have been added to the requirements.

Note: Since this was published, later Q&As stated that social security header searches are required for ongoing or random background screenings if the employee has taken an extended leave of absence or if the employee has moved since his/her initial or pre-hire screening was conducted.

Q: What is a social security trace?
A: The Social Security Trace is a non-financial report of a person’s social security number, and it is required as part of the Certification background screening requirements. A trace will reveal all addresses and names associated with a particular social security number. That information is then to be used to determine the counties and states where background checks will need to be run, as well as the names under which to run them. The information returned from the trace should also be cross-referenced with the employee’s application and prior employment verification to check for any holes or discrepancies. The purpose of the trace is NOT to simply verify the SSN as valid; SSN validation is NOT the same as the Social Security Trace.

When an auditor reviews background checks during the audit, s/he will ask to see:
  • The full results of the SSN trace, with the complete listing of names and addresses
  • The full results of the individual county and statewide checks that were run from the SSN trace. The auditor will verify that the correct records were searched, and that there have been no felony theft convictions within the last 7 years.

Note: Since this was published Federal Criminal Record Checks have been added to the requirements.

Q: My drivers are part of a Department of Transportation consortium for random drug testing. Does this meet the NAID Certification requirement?
A: A DOT consortium usually consists of employees from many different companies, so there is no way to guarantee the number of employees that will be chosen from any given company. Therefore, the drug screenings of drivers selected in a consortium can be used toward the NAID random drug screening requirements (Criteria 1.3). However, a certified company is still required to make up the difference so that a total of 50% of that company’s employees have been screened within each 12 month period. Also, at least 50% of access employees who are NOT drivers, and therefore not included in the consortium, will also need to be screened to make up the difference, even if the number of drivers screened through the consortium represents 50% of the total number of access individuals.

Q: I have an employee who has received a security clearance from another entity. Do I still have to run a criminal background check on them?
A: NAID does NOT accept third party security clearances (military, security professional, government work, etc.) in lieu of background checks, unless the following is met:
  • The check was done at or near the employee’s date of hire and within the last 7 years.
  • The auditor is able to view a copy of the actual results, not just the clearance paperwork.
  • The check was done in accordance with NAID standards, as defined in Section 1.2 in the NAID AAA Certification Application.

Q: My company is a publicly traded, conglomerate and/or non profit corporation. Do board members and other executive personnel need to be screened as access employees?
A: In most cases, no. The general rule of thumb is that background screening, drug screening and employment verification needs to be done for anyone who has access to confidential material. This includes anyone who directly supervises those individuals or may grant access to the secure destruction area. For smaller, privately owned companies, this also means that the owner(s) or partners must be screened. For larger companies, conglomerates, or publicly traded organizations, the off-site Board of Director members or other corporate entities, including parent company executives, do not need to be screened; however, the on-site Operations Manager, or anyone in a similar position overseeing the entire operation, must be screened.

If a company provides services other than information destruction, and a different manager is appointed to each separate division, the company is required to screen the manager overseeing the information destruction operation, as well as any person on-site who oversees the entire facility.

As a reminder, anyone who has not been screened as an access individual must not be allowed access to confidential material without signing in as a visitor and being escorted by someone who has been screened.

Q: I employ or contract with individuals who have mental and physical disabilities. Do I still need to run background and drug screenings?
A: Yes, the NAID Certification requirements for criminal background screening and drug screening are the same for all employees that have access to confidential material before it is shredded.

For more Employment Screening FAQ's, see Background Check Frequently Asked Questions.

NAID: Auditor, CRB & NAID Staff Tips
(These statements were originally published in the 'NAID Certification Advisory.')

Separate random ongoing drug and criminal background screenings from initial/pre-hire screenings
Certification requires that each employee has an initial criminal background screening going back seven years and an initial drug screening. Each employee’s file must have these items for the NAID audit. Ongoing drug and criminal background screenings have separate requirements. To facilitate the audit process, please have proof of ongoing screenings in a separate file, rather than in the individual employee files, so that the auditor can confirm that you have met the required threshold for the year:
  • Drug Screening:
    • 50% of all access employees randomly chosen each year; or
    • Supervisors participate in an annual NAID-approved substance abuse recognition training program
  • Ongoing Criminal Background Screening:
    • 1/3 of all access employees chosen randomly each year; or
    • Each access employee is placed into one of three groups. One group per year is screened on a rotating basis; or
    • Screen all access employees once every three years
Please refer to Sections 1.2 and 1.3 of the NAID AAA Certification Application for a complete description of the requirements for ongoing screenings.

Substance Abuse Recognition Training Program Approval Submission Form:
If a company checks Option #2 for Section 1.2 in the NAID AAA Certification Application to have their supervisors go through a Substance Abuse Recognition Training Program in lieu of conducting random annual drug screenings on employees, a Substance Abuse Recognition Training Program Approval Submission Form must be submitted prior to or with the application, along with an outline of the program that has been selected.

The auditor will check for proof of completion during the audit. This program must be completed by all supervisors on an annual basis. As long as the same program is used in subsequent years, there is no need to resubmit this form with each annual renewal. Just be prepared to show the auditor proof that the training has been completed within the last 12 months.

Even if this option is selected, all Access Employees must still have an initial or pre-hire drug screening on file.

How to meet the requirement for employment verification:
NAID does not dictate specifically how employment verifications are to be done; however, the most important thing is that your auditor is able to verity that this has been done. For each access employee, you should notate the name of each previous employer, the date the employer was contacted, who you spoke with, and whether or not you were able to verify employment for the dates that the employee or candidate listed. If you are unable to contact someone at the company, such as the case might be if the company went out of business, you must still document the attempt.

It is not necessary to use a third party for employment verification.

Develop a system for updating drivers’ licenses in employee files
Section 1.5 of the NAID AAA Certification Application requires that all drivers meet licensing requirements. To confirm compliance, the auditor will check for a copy of a current drivers’ license in the personnel file for each driver. You should develop a system for updating each employee’s personnel file when their license has been renewed, since a copy of an expired license will result in a failed unannounced audit. Some examples for doing this include:
  • If you have a few employees, select one day each month to review all personnel files.
  • If you have more employees, or if checking all files each month is too tedious, set up a spreadsheet with the names of all drivers and the expiration dates of their drivers’ licenses. And then, once a month, refer to this spreadsheet to see if any of the drivers have expired licenses. Once you obtain a copy of their renewed license, remember to update the spreadsheet.
  • Use Microsoft Outlook, or a similar program, to pop up a reminder on the first day of the month when a driver’s license is due to expire during that month.

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