Third Party Background Check Assessment Training.
[Audio] Before we jump in let's look at our agenda. In this session we will discuss a few house keeping items, master agreements and county attachments, exporting from storm, and we will close by going over non us third parties..
[Audio] Before we dive in, a couple things are worth noting at the top. One, the steps demonstrated in this training do not need to be followed to a tee. Each person completing the assessment may have a different approach that works for them. Different approaches are just fine, as long as the end-result aligns to the requirements of the assessment. Two, this training will cover alternative verification process, the very first question of the assessment, towards the end of the training. The training will skip the first question by answering it NO, and then it'll circle back to address it at the end..
Step 1. 4. Gather and understand governing document(s) and background check requirements Gather master agreement along with all country attachments Capture contract IDs and sections that contain background screening requirements Capture the provision language in the comments..
[Audio] The first step is to gather your governing documents, including all country attachments that govern the agreement between Wells Fargo and the third party. Once you have these identified, capture the contract IDs as well as the sections within each contract that contain background check provisions. These requirements will drive what needs to be evidenced by the third party related to their background screening program..
[Audio] Once you have the questionnaire open, document the contract IDs and the sections of those contracts in the supporting comments for each question of the assessment. This is regardless of whether that requirement is applicable or not, Ie whether that requirement is present in the contract or not. The purpose of this action is to set the location of where the applicable requirement resides for each and every question..
[Audio] Capture the provision language in the comments. This will ensure mutual understanding of the background check requirements..
[Audio] If the requirement within the assessment is not present in the contract, select yes and provide rationale for why this requirement is not applicable..
Step 2. 9.
[Audio] Again, there is no "one right approach", this is just one way to complete the assessment, process-wise. Using the Export function, save the questionnaire locally. With the questionnaire worksheet open, hide any assessment questions that are either answered Yes or are otherwise not for the third party to directly answer, like the "duly licensed" question..
[Audio] The export can be copied and pasted to an email. Ensure the questions that are not applicable or are not for the third party to address (ie the "duly licensed" question). This will set the standard for what the third party must respond to. Help Text guidance within each question should be used to facilitate with the third party what is acceptable evidence. However, it should not be provided to them without curating the message to be appropriate for a third party as the audience..
[Audio] Finally, let's take a deeper dive into a few scenarios. We will briefly talk through Non-US third party scenarios, alternative verification scenarios, and lastly, what does sufficient validation evidence from a third party look like..
[Audio] Country attachments will contain language that prescribes country specific requirements for some provisions, which may or may not include background screening requirements. The language in the country attachment will dictate which provisions should replace the master language; background check requirements may be one of those provisions included. In the event of contract provisions in conflict, refer to the master's Order of Precedence provision to help navigate which document(s) take precedent. If questions remain on how to interpret or prioritize the background check requirements, please reach out by creating a Supply Chain Management Support ticket.
[Audio] The first question of the assessment is a carve-out for instances where existing verification processes can be used by the Third Party to satisfy this background check requirement for certain professions or roles. For example; attorneys, domestic correspondent bank employees, and certain other licensed professionals may not need to have an additional background check performed due to prerequisite background checks being performed as a condition of their employment in such professions or roles. Note, this alternative applies to the individuals that hold the license and it does not extend to individuals who work for, or with, the licensed individuals. If it is believed the third party already performs background checks on personnel performing WF services due to a specific licensure or certification, the following information must be provided by the third party in order to answer Yes and bypass the remainder of the assessment: 1 Name of the licensing or certifying agency (Example: State Bar of Arizona membership). 2 Confirmation the licensing or certifying agency may suspend or revoke such license or certification if the individual is convicted of screened crimes 3 Confirmation the third party can demonstrate that a criminal background check is a prerequisite to obtaining such professional license or certification and that the scope of the criminal background check is appropriate for the services being provided. And 4-Description of third party's validation process (for example, how long is the certification good for and how does the third party ensure personnels' good standing).
[Audio] The question in the assessment titled, Is the third party able to provide eligible /non eligible status of sample of individuals, as certified by background screening provider?" is Wells Fargo ensuring the third party is performing the screens they are required to perform. It does not require , nor does Wells Fargo want, any actual results of personnel screenings be provided. Standard background check contract language requires the following: Upon Wells Fargo's request, Vendor will provide written evidence (but not the actual results) that all of Vendor's Personnel providing the Products or Services have undergone the Screen required by Section V D (Background Screening) of the General Terms and individualized assessment. To satisfy this requirement, evidence can be provided in one of two ways: -An Inventory of third-party personnel providing services for Wells Fargo with corresponding date of screening performed on individual; along with redacted invoice that demonstrates the details of the screenings. Note, the screening provider's description of the criteria included (suite of services offered) can also help to demonstrate what's included in the screenings used by the third party. Alternatively: -An attestation from a senior employee within third party's Human Resources department, or equivalent, that screenings are occurring against all third-party personnel performing Wells Fargo services prior to when the personnel will begin performing the services for Wells Fargo and incorporate all requirements present in the contract..
[Audio] This concludes our training presentation. Thank you for joining the session; we hope it was helpful. A couple quick reminders Ensure you have read and understood each questions' sub-text and help text Reach out to the S-C-M Support Tool with questions Thank you!.