Zafar I. Anjum, CFE is an International Investigator and chief executive officer of CRI Group, a global supplier of investigative, forensic accounting, business due diligence and employee background screening services for some of the world's leading business organizations. A member of the Dubai International Financial Centre, CRI safeguards businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. CRI Group maintains offices in Dubai, Islamabad, Lahore, Karachi, Manila, Riyadh and the United Kingdom.
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In the complex world of employee background screening, no two countries are alike. In the United States International investigators have a web of databases at their disposal and a vast network of local resources that provide a wealth of information at the mere click of a mouse.
It’s a different world in the Middle East. Technology is limited in many parts of the region. Privacy legislation varies from country to country and from jurisdiction to jurisdiction. Cultural differences can impact the flow of information. Language barriers can contribute to inaccurate reporting.
Instead of database-driven investigations that are generally conducted in the United States, professionals in the Middle East must conduct large parts of their investigations literally on foot, traveling to remote regions to scour records and interview sources.
Simply put, if you’re looking for accurate, reliable information in the Middle East you need to turn to qualified, professional sources that are familiar with the countries, cultures, terrain, languages, resources and – most of all – the laws that govern personal privacy.. In this part of the world your contacts and resources are your greatest asset.
Discovering Hard-to-Find Facts in Hard-to-Reach Locations
The biggest challenge to conducting background investigations in the Middle East is collecting reliable information in the most efficient manner. This requires a well-trained and diverse group of professional investigators who are multilingual and multi-cultural, are familiar with those geographic regions and can easily traverse the obstacles that often impede international investigations. Those obstacles include:
• Working with local customs offices;
• Complying with data protection laws and mandates;
• Knowledge level of local investigative researchers;
• Lack of centralized information resources and databases; and
• The proliferation of multicultural environments that are particularly influenced by locals who vastly differ in their approaches to investigative screening and public record searches, particularly with information collected via database sources.
To address these obstacles, successful background investigators in this part of the world are often required to work deep in the field, travelling to remote destinations to conduct interviews, develop resources and enlist local assistance to verify information.
Progressive screening firms will conduct investigations that regularly involve a thorough review of local press records, using online and proprietary databases augmented by manual field research to locate the appropriate public records. This in-depth investigative approach is necessary to bring to light any instances of malfeasance or notable, publicly aired criticism.
These professionals will also research all public records that are available within the respective government institutions such as a region’s trial courts, police and SEC sources, and global sanctions lists.
The goal of providing this level of investigative legwork is to collect timely, well-documented and substantiated information which will measure up to the high standards often required by our U.S. partners.
Examples of Privacy Laws in the Middle East
While reputable screening firms in the United States comply closely with the Fair Credit Reporting Act to conduct domestic background investigations, foreign investigations are much more complex.
Middle East countries have no prohibitive legislation that governs the employment screening process. At the same time there is no cooperative legislation and regulation to support background screening services for employee due diligence. However we, as industry professionals, must adhere to strict data protection requirements (such as the European Union data protection directive) to process consensually based personal information.
In our region local police departments provide “Good Conduct Certificates” for employees for immigration purposes, while the Dubai International Financial Centre (DIFC) awards a “Police Clearance” certificate for employee due diligence work.
In the United Arab Emirates, data protection laws permit investigators to process sensitive personal information such as criminal history data. As a DIFC licensed entity, the CRI Group (as well as other reputable background screening firms) must maintain strict adherence to the region’s Data Protection Law of 2007 in order to fulfil our ongoing DIFC licensed status. As in the United States, the procurement of personal data in this region – and any subsequent transfer of data outside of the DIFC – may only be attained with the written consent of the individual being investigated.
Reputable screening firms in the Middle East will also comply with regional privacy laws (such as the EU data protection directive) by appointing an internal Data Protection Officer (DPO) whose primary responsibility is to conduct independent audits of the firm’s various information processing operations which handle customer and employee data. The DPO ensures that personal data is handled in accordance with all relevant data protection provisions covering online and offline data procurement while complying with local and regional regulations pertaining to individual privacy standards.
How to Locate and Partner with
Reputable Screening Firms in the Middle East
So how does one go about securing a reputable background screening source abroad? The following checklist may be helpful.
1. To begin, it is highly recommended that you research the listing of expatriate background screening firms provided by the National Association of Professional Background Screeners (NAPBS) or PreemploymentDirectory.com in the International Section. The list can be found at www.napbs.com/content.php?id=250 or at www.PreemploymentDirectory.com.
2. Ask your provider how they comply with local and regional laws governing individual privacy protection and the methods they utilize in protecting information.
3. Make sure your service provider’s physical address is in the region they’re conducting investigations. If not, they could be simply outsourcing their cases to a third party.
4. Ask about the manner in which your service provider conducts investigations. Stay away from firms that investigate exclusively through media searches.
5. Inquire about the internal policies and procedures the service provider uses to monitor the protection of data, and if it conducts regular audits to ensure compliance with regional privacy mandates.
6. Don’t settle for firms that say they specialize in providing checks of the International Terrorist Watch List and the OFAC watch list. Those lists are available online to anyone at no cost.
7. Stay away from firms that won’t supply you with the source of the records they obtain. Also, be sure to ask how old the information collected is.
8. The truly reputable firms will combine in-depth field investigations with routine public records searches. Make sure your provider is doing both.
9. Service delivery is critical in foreign investigations. Ask about average turnaround times and get commitments for delivery in advance of the investigation.
10. Find out what other U.S. companies use the service provider. Ask for references.
As the world economy shrinks and the pool of foreign job applicants expands, a partnership with a reputable international background screening service provider to conduct investigations abroad is essential for maintaining a safe hiring program for your clients. To ensure you’re using the best providers available, a little investigating of your own will result in big benefits down the road.
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