Now Accepting Comments for Proposed Revisions to the Accreditation Program Standard

BSAAP Standard Proposed Revisions

Before any proposed changes become final, the public (including and importantly the NAPBS membership) has an opportunity to review the proposed changes and submit comments back to the Background Screening Credentialing Council (BSCC) for their review and consideration. No fee changes are anticipated at this time.

The public comment period is open today, October 9, 2017 - November 8, 2017, at which time the BSCC will review the submitted comments. Comments should be sent to accreditation@napbs.com on or before November 8.

Please include all applicable Clause numbers with a comment. For more information regarding the timeline for agencies to come into compliance with the final Standard once it is approved and published, CLICK HERE.

Below is a high-level summary of the proposed BSAAP Standard changes. Note that many of the proposed changes are grammatical and/or add clarity; such changes are not noted in the below high level summary. The summary below contains both new Clauses and a high-level summary of clauses with more significant changes. A thorough review of the proposed BSAAP Standard in its entirety is highly encouraged and recommended by all firms. For comparison, a copy of the current available Standard can be found HERE .

Note: Each clause noted with an asterisk (*) includes updated content within the clause itself.

Throughout document. Clauses updated from "shall have a [condition]" to "must have and follow a [condition]" within the clause/audit criteria.
Throughout Sections 5 and 6. Updated so that CRA must provide evidence and adherence to procedures, including training records within the onsite audit criteria.

Clause 1.1: Information Security Certification (new clause)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 1.2: Information Security Policy (previously Clause 1.1)
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 1.3: Data Security (previously Clause 1.2)
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 1.4: Intrusion and Data Security (previously Clause 1.3)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 1.5: Storage and Backup of Data (previously Clause 1.4)
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 1.6: Access Protocol (previously Clause 1.5)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 1.7: Electronic Access Control (previously Clause 1.6)
*Clause 1.8: Physical Security (previously Clause 1.7)
*Clause 1.9: Consumer Information Privacy Policy (previously Clause 1.8)
*Clause 1.10: Unauthorized Browsing (previously Clause 1.9)
*Clause 1.11: Record Destruction (previously Clause 1.10)
*Clause 1.12: Sensitive Data Masking
Clause 2.1: Compliance with Law and Regulation (new clause)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 2.2: Federal Consumer Reporting Law (previously Clause 2.1)
- Updated title from "Designated Compliance Person(s)"
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
Clause 2.3: State Consumer Reporting Law (previously Clause 2.2)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
Clause 2.4: Driver Privacy Protection Act (DPPA) (previously Clause 2.3)
Clause 2.5: State Implemented DPPA Compliance (previously Clause 2.4)
Clause 2.6: Integrity (previously Clause 2.5)
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 2.7: Prescribed Notices (previously Clause 2.6)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 2.8: Agreement from Client (previously Clause 2.7)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 2.9: Client Legal Responsibilities (previously Clause 3.1)
Clause 2.10: Client Required Documents (previously Clause 3.2)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 2.11: Disclosure and Authorization (new clause)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 2.12: Adverse Action (previously Clause 3.4)
*Clause 2.13: Consumer Disputes (Previously Clause 1.11)
*Clause 2.14: Database Criminal Records (Previously Clause 1.13)
- Documentation subject to Desk Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 2.15: Identification Confirmation (previously Clause 4.7)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 2.16: Full File Disclosure (new clause)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 2.17: Jurisdictional Knowledge (previously Clause 4.8)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 2.18: Automated Searches (new clause)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 2.19: Quality Assurance (previously Clause 6.11)
Clause 2.20: Reappearance of Inaccurate Information (new clause)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 2.21: Quality Analysis (new clause)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 3.1: Truth in Advertising (previously Clause 3.3)
Clause 3.2: Legal Counsel (previously Clause 3.5)
Clause 3.3: Understanding Consumer Reports (previously Clause 3.6)
Clause 3.4: Information Protection (Previously Clause 3.7)
*Clause 4.1: Public Record Researcher Agreement
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 4.2: Vetting Requirement
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 4.3: Public Record Researcher Certification
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 4.4: Errors and Omissions Coverage (E&O)
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 4.5: Information Security
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 4.6: Auditing Procedures
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 5.1: Verification Accuracy
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 5.2: Current Employment
- Documentation subject to Desk Audit: Note new guidelines
*Clause 5.3: Accredited Academic Institutions
- Updated title from "Diploma Mills"
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 5.4: Procedural Disclosures
- Documentation subject to Desk Audit: Note new guidelines
Clause 5.5: Verification Databases
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 5.6: Use of Stored Data
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 5.7: Documentation of Verification Attempts
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 5.9: Conflicting Data
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 5.10: Authorized Recipient (previously Clause 5.11)
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 6.1: Background Checks for Personnel Charged with Enforcement Policy
- New content and updated title
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 6.2: Background Checks for CRA Workers (previously Clause 6.10)
- New content
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 6.3: Changing Law and Regulation (new clause)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 6.4: Insurance (previously Clause 6.2)
Clause 6.5: Client Authentication (previously Clause 6.3)
Clause 6.6: Vendor Authentication (previously Clause 6.4)
Clause 6.7: Consumer Authentication (previously Clause 6.5)
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 6.8: Document Management (previously Clause 6.6)
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 6.9: Employee Certification (previously Clause 6.7)
Clause 6.10: Professionalism and Proficiency Training (New clause)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
*Clause 6.11: Worker Confidentiality, Legal, and Compliance Training (previously Clause 6.8)
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 6.12: Visitor Security (previously Clause 6.9)
Clause 6.13: Responsible Party (previously Clause 6.12)
- Verification for Onsite Audit: Note new guidelines
Clause 6.14: Document Control (new clause)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Clause 6.15: Ethics Reporting (new clause)
- Documentation subject to Desk Audit: Note new guidelines
- Verification for Onsite Audit: Note new guidelines
- Attributes of and Suggestions for Onsite Audit: Note new guidelines
Glossary (new): For purposes of this BSAAP Standard, terms and acronyms have been added with definitions at the end of the document.

All documents can be found in the NAPBS Accreditation Download Center.