For the hundreds of customers who have come in to contact with WorkPro, either as a customer, a candidate or applicant, as one of our Federal Government partners, or Professional Association partners, you will know that we have built an enviable reputation as a compliance specialist – that’s what we do, and that’s all we do.
We don’t offer any other services, and we do what we do well. We work with specialists to understand risk, and build simple user interfaces, coupled with robust, complex back-end processes to provide you simplicity yet comfort that you are meeting governance obligations, to enable you to engage and manage your workforce efficiently.
I have had many many conversations with people who have worked with other ‘compliance specialists’ who come to us seeking assistance, but quite often, it is when they have been investigated, audited or unfortunately when they are facing legal case.
What I am referring to specifically in this blog is police checks.
WorkPro has worked over many years with the Australian Criminal Intelligence Commission (ACIC), the Federal Government Organisation that hosts the national police history database and their appointed auditors to deliver you a solution that is quick, but importantly, robust, and I am quite disturbed with company’s who are promoting police checking services as if you were buying fish and chips – it’s not simple and if it’s managed poorly, could put you, your employees, your candidates and if you are a recruiter, your clients, in jeopardy.
So, when you are considering a police check partner, here’s a quick rundown of questions that you need answered as part your investigation.
1. Are they an Australian Criminal Intelligence Commission (ACIC) Broker? This is critical. There are only two ways to gain a result for a police check. Either the person goes to a local police station and applies directly (results take about 6 weeks), or the company is an appointed Australian Criminal Intelligence Commission (ACIC) Broker. This broker application process is, for good reason, a lengthy one, and once appointed, Brokers are bound to a strict regime of auditing on a regular basis. The broker appointment can take as long as 12-months. Here is a list of accredited brokers: https://www.acic.gov.au/
The Australian Criminal Intelligence Commission (ACIC) updates this list regularly, so if the company you are talking to is not on this list, they are not authorised to conduct national police checks. Some companies do ‘sub-contract’ this work to an approved Broker, and you will naturally be expected to accept a ‘back-to-back’ and the relationship should be spelt out clearly in your contract. You should also expect to be audited by your partner, plus the Broker (most likely separately).
2. Application Form – the Australian Criminal Intelligence Commission (ACIC) provide an approved application form, so you should check that it clearly displays the Australian Criminal Intelligence Commission (ACIC) logo.
3. Experience – ask for a number of client references. The reference should include how many checks they have completed over a particular period, the response time, e.g. how long it takes from requesting the check, to the time it is returned to you. If they are an Australian Criminal Intelligence Commission (ACIC) Broker, this should be somewhere between what WorkPro offers – instant, to 24 hours. The response will definitely effect how you set expectations within your own company but also those of your clients if you are a recruiter. Due to our experience and the reputation of service we have become renowned for within the Australian Criminal Intelligence Commission (ACIC), if you have an initial return of ‘potential match’, we will be able to return your final result back to you a lot quicker than what other company’s may tell you.
5. Archiving – this is key in meeting privacy requirements. If the provider offers a manual process, e.g. the candidate completing a manual application, then that means you need to keep a copy of the application and ID and you will be expected to be audited by the Australian Criminal Intelligence Commission (ACIC)’s audit team, with about 3 weeks’ notice. This also means manual archiving and appointing an internal administrator to manage this process. It’s now getting more expensive for you to process a check. You will also need to send the original of the application and ID to the processing company, and they will need to archive the application. You will therefore be keen to understand how they collect and store the information as part of your privacy responsibility.
6. Turnaround Time – you may not think this is critical, but when other companies can present a candidate to a client with a police check clearance within a few minutes (if you are a recruiter) or you have just the right candidate, but have to wait weeks and weeks potentially for a police check clearance, turnaround time is going to become important. Ask your potential partner what their turnaround time is, and have this written in to your contract.
7. Process – what is the company’s process? Do you have your employees/candidates complete a manual form to be sent to the provider or is it on-line? A manual method will heighten manual errors, you will need to implement an archiving process and policy, there is no transparency with turnaround times, and you can expect to be subject to auditing by the Australian Criminal Intelligence Commission (ACIC). You will also need to send the company the original application form in the post, and in some cases, the company will expect you to send the original application and ID BEFORE they will process the check – I am sure you can see the possible issues with this, not least of all is whether the application will actually arrive.
8. Price – now this is an interesting one. Of course, you want to negotiate the best price, it affects your own profitability – but at the risk of being fined, taken to court, not to mention the cost of having to apply processes as mentioned in some of the points raised above may actually end up costing you. The market pricing is somewhere between $30.00 if the candidate goes to the police station to $80.00 – WorkPro transparently charges $55.00+GST for an instant police check for an employee and $25.00 for a volunteer. You need to conduct a cost-benefit analysis, possibly using the points raised above, as part of your decision-marking.
9. Support – some police check results returned can often be confusing and written from a legal point of view. You need to work with a partner who has access to the Australian Criminal Intelligence Commission (ACIC) to request feedback and explanations. If you get this wrong, and the employee or candidate is not employed because you have misunderstood the context or court charge, you could find yourself in a discrimination case.
10. Contract – naturally, police checking is a contracted service. Make sure that all of the above is included in your contract, so that you can be comfortable that you are protected.
So, bottom line, there is lots to know and to consider as part of your investigation. As a specialist company, who understands the importance of centralising services and employment related functions, so you can engage quickly and streamline your processes, you need to be comfortable that you have not compromised streamlining for risk.
Naturally, ask for a tour of their system – coupled with client references, this will give you a good understanding of the reality.
We know of the Australian Criminal Intelligence Commission (ACIC) Brokers whose services have been suspended based on their irresponsible business practices, so make sure you do your homework.
If you would like to discuss or clarify any of the above, or you want to work with a specialist police check provider, regardless of the number of checks you require, please call us on 1300 97776.