ALTA Best Practice #3 – Privacy and Information Security Written Policy requires that title companies conduct Background Checks on personnel who have access to non-public information (NPI). Specifically, in order to be compliant, the title company must provide evidence via an invoice or documentation in the employee’s personnel file, that a five-year Background Check has been conducted upon hiring and/or prior to promotion. Additionally, all five-year Background Checks initially conducted must be updated within the past three years, with aforementioned requisite evidence available for inspection.
We see most of our clients conducting appropriate background checks on hiring, and have encouraged redoing the checks prior to promotions as well as routinely so that the three year practice is followed.
Background Check Reports are available from a variety of companies with varying search criteria. We strongly recommend that the individual title company should determine the appropriate scoring for individual employee positions and not rely on a third party vendor to make pass or fail hiring decision on their behalf.
The standard to use should be directly related to the specific role the individual performs. For example, your firm may not want someone with a lot of bad debts to have signing authority on your escrow account. Similarly, if your employee is also a Notary who attends signings, you would want to know that they are not a Sex Offender before sending them off to a client’s home.
Being cautious about who you allow to work with you is not just a Best Practice, it’s good business.
ProsperitasForward is a consulting firm led by a team of title insurance veterans, formed to help title agencies improve top line revenue and bottom line results.