1. Who we screen
- All applicants offered a cleaner, lead-cleaner, or supervisor role.
- All office and dispatch staff.
- Owners, officers, and anyone with access to customer data or keys.
- Third-party contractors who enter customer properties.
2. FCRA compliance
Our background checks are "consumer reports" governed by the Fair Credit Reporting Act, 15 USC § 1681 et seq. Before we request a report, we:
- Provide the applicant a clear and conspicuous written disclosure in a standalone document that we may obtain a consumer report for employment purposes (§ 1681b(b)(2)(A)(i)).
- Obtain the applicant's written authorization — electronic signature accepted (§ 1681b(b)(2)(A)(ii)).
- Provide the FTC "Summary of Your Rights Under the Fair Credit Reporting Act" required by § 1681g(c).
- Where state law requires additional disclosures (e.g., California ICRAA, New York Article 23-A, Florida "Ban-the-Box" style county ordinances), we include them in parallel.
- Use a consumer reporting agency (CRA) that complies with § 603(y)(1) accuracy standards.
3. Databases we check
- County criminal records for all counties where the applicant has lived or worked in the last 7 years.
- Federal criminal records via PACER and/or CRA aggregation.
- Florida statewide criminal records (FDLE) and any equivalent state-repository searches for other states of residence.
- National Sex Offender Public Registry (NSOPW).
- Social Security Number trace to validate identity and develop address history.
- Driving record (MVR) for any applicant who will drive a company or personal vehicle on company business.
- OFAC / sanctions lists (SDN).
- Employment verification for the last two positions.
- E-Verify for Form I-9 work-authorization compliance.
4. Re-screening and annual review
For active cleaners we run a rolling re-screen annually (criminal + MVR) and the entire policy is reviewed and, if needed, updated each year. Customers who require more frequent screening on particular cleaners (e.g., for commercial or HOA contracts) can request that we re-run at a higher cadence.
5. Applicant rights
- Right to know whether a report was pulled and what it contained (§ 1681g).
- Right to dispute any inaccurate or incomplete information with the CRA (§ 1681i).
- Right to be informed before any adverse hiring decision based in whole or in part on the report (§ 1681b(b)(3)).
- Right to privacy — reports are accessible only to the hiring manager and HR.
- Right to free copies of the report from the CRA in certain cases (§ 1681j).
6. Adverse action process
We follow the FCRA two-step adverse-action process:
- Pre-adverse action letter. If we are considering not hiring because of a consumer report, we send the applicant the pre-adverse letter, a copy of the report, and the FTC "Summary of Rights." We wait a reasonable period (minimum 5 business days) for the applicant to respond or dispute.
- Final adverse action letter. If, after considering any response, the decision is final, we send the final adverse action notice including the CRA's contact information and a statement of the applicant's right to obtain a free additional copy within 60 days.
7. Dispute process
If you believe your consumer report contains inaccurate information:
- Contact the CRA listed on your report. Disputes must be investigated within 30 days (§ 1681i).
- Email us a copy of the dispute at hr@gogreenorganicclean.com so we can pause the adverse-action clock while the investigation is ongoing.
8. Applicant review of own report
Any applicant or employee may request a copy of their most recent consumer report from the CRA that prepared it. We provide the CRA's name, address, and phone number in every disclosure and in any adverse action letter. See also the Consumer Financial Protection Bureau's guide at consumerfinance.gov.
