New Criminal Records Check Fingerprinting

New Criminal Records Check Fingerprinting

August 19, 2019 2 By Kailee Schamberger


Welcome to a Public Services and Procurement Canada (PSPC) video on the recent changes to the criminal record check process. During this video we will explain why electronic fingerprints are now part of the criminal record check process. We will also explain why and when organizations registered with the PSPC Contract Security Program need to send employees to get electronic fingerprints when they apply for a personnel security screening. First, let’s look at who this process applies to. This process applies to organizations who work or intend to work on a Government of Canada contract with security requirements that are managed by the Contract Security Program (CSP). Specifically, this process applies to organizations who have employees that require a new, a renewal or an upgrade of their personnel security screening, also commonly referred to as “clearances,” that have been issued by the CSP. It is important to note that this process does not affect the validity of an existing personnel security clearance granted by the CSP. The CSP works in partnership with the Royal Canadian Mounted Police when it assesses whether to grant a personnel security screening [or] clearance to employees of private sector organizations. This process involves having to conduct a criminal check. From these checks, RCMP results are generated. The CSP uses these “criminal record check results” as part of their overall assessment along with other considerations. In this video we will explain: • why the new criminal record check process has been implemented • who is involved • some of its benefits, and • what steps an organization registered with the PSPC Contract Security Program needs to follow when submitting a personnel security screening request that includes electronic fingerprints Let’s get started. The Royal Canadian Mounted Police (RCMP) is the lead agency responsible for law enforcement inquiries. Last year [2016], they announced that they were replacing the criminal record name check process with a new criminal record check process using electronic fingerprints. On February 1, 2017, Public Services and Procurement Canada launched the new mandatory electronic fingerprint requirements for its suppliers. As such, changes to the Contract Security Program processes were made to meet the new RCMP criminal record check requirements. You may ask why the RCMP is replacing the name-based checks with fingerprint checks. The answer is simple: the name-based criminal record checks are not always reliable. They often result in errors in spelling or in common surnames or nicknames and often do not take name changes into account. Essentially, name-based searches are not as accurate as fingerprint-based searches. Fingerprint screening has been used for many years to confirm identities and is an international best practice. It is the only definite way to determine whether an individual has a criminal record and reduces false associations with criminality. Make no mistake: fingerprint-based verification is not a higher level of screening, but rather an improvement over the existing criminal check process. There are also other benefits to using electronic fingerprints as part of the criminal record check process. As mentioned earlier, fingerprints allow for immediate results. This means that employers and applicants, especially individuals whose application would have otherwise been delayed due to their names being incorrectly associated with those of convicted offenders, will no longer have long wait times due to having a common name. The automation of internal processes along with immediate electronic responses from the RCMP will contribute to reducing processing and response times. This means that organizations’ employees that apply for personnel security screening can obtain a clearance from the PSPC much quicker. The RCMP has invested significantly in a solution that meets mandatory fingerprint processing requirements. Since 2013, most police services have made arrangements to either buy the equipment or associate themselves with other police services that have the required capability or equipment. Given that all police services have not yet been fitted with the RCMP electronic fingerprinting capability, the RCMP accredits private service fingerprinting providers. There are currently 135 RCMP-accredited private service providers across Canada. This list is constantly updated as more service providers are accredited by the RCMP. Private sector service providers are companies who charge a fee to take fingerprints. There are also currently 515 RCMP detachments across Canada that are capable of taking fingerprints, including remote locations such as Iqaluit and Cold Lake, just to name a few. To accommodate suppliers’ needs in remote locations where electronic fingerprints cannot take place, the use of scanning technology is offered. This allows for fingerprints to be taken on paper (ink and roll), then mailed to central sites to be scanned and submitted to the RCMP electronically. This model is already in place for some agencies. If you are listening to this video and you are a private sector service provider offering fingerprinting services and you are not familiar with the new February 1, 2017 PSPC Contract Security Program arrangement with the RCMP, please contact the RCMP Canadian Criminal Real Time Identification Services. As mentioned earlier, RCMP-accredited private service providers charge a fee when they take fingerprints. Current cost estimates range between $40 and $65; however, fees can vary from province to province. These fees can either be charged by the private service providers, the RCMP or police detachments. It is important to note that the PSPC Contract Security Program does not receive funds from providers and does not profit from their service. To ensure applicants do not overpay, they should bring with them the PSPC Contract Security Program applicant request form and use that form as a legitimate indication that their fingerprints are required as part of a Government of Canada contract with security requirements. Applicants can also remind service providers of [a] recent RCMP-generated correspondence sent to all accredited service providers indicating that PSPC criminal record checks and electronic fingerprints considered government requests and that
these fees should be adjusted accordingly. If the service provider does not recognize the PSPC applicant request form as an official Government of Canada form and intends on charging extra fees, we suggest that the applicant consult with their organization company security officer before fingerprints are taken. The company security officer is encouraged to contact our program to find out more about fingerprinting service locations and/or other options offered to them. When visiting a fingerprint service provider, applicants should ensure the provider has been accredited by the RCMP. In cases where a fingerprinting service provider is not accredited by the RCMP, or, in cases where fingerprinting machines are not set up to request that an applicant criminal record check result be sent directly from the RCMP to PSPC, that applicant should again first consult with their organization company security officer before the prints are taken. We will be showing the PSPC fingerprint applicant request form and explaining how to use it a little later in this video. Let’s take a quick look at some key information when it comes to privacy concerns. It is important to understand that PSPC does not receive your fingerprints or the fingerprints of applicants. With the new process we only receive the result of the fingerprint check conducted by the RCMP. This means that the police agency or third-party service provider submits applicants’ fingerprints electronically to the RCMP, and the RCMP uses the fingerprints to search their criminal record database. The RCMP only provides PSPC with the results of that particular search, and the Contract Security Program uses them as part of the process to determine whether or not an applicant can be granted a personnel security screening. Once the RCMP completes their search, they delete the fingerprints from their system. At no time are civil fingerprints kept in a database. Furthermore, criminal record check results are only accessed by PSPC’s analysts who are responsible to process an applicant’s personnel security screening request. They are not released to or shared with contracting authorities or with the applicant’s company security officer. In addition, police agencies and accredited companies are not authorized to retain and archive civil fingerprinting forms or electronic copies of fingerprints. Once an application is processed in the system, the fingerprinting forms and electronic fingerprints are to be destroyed as per Treasury Board [of Canada Secretariat] guidelines for protected information. If an individual refuses to provide fingerprints for a criminal record check on the basis that it is an invasion of privacy, PSPC will not be able to proceed with the personnel security screening request. In the next 3 slides we will review the circumstances when fingerprints are required, when they are not needed and when they may be required. Let’s talk about when mandatory electronic fingerprints are required. The first circumstance is a new request. Any new personnel security screening (reliability status) or security clearance (Secret or Top Secret clearances) submitted to the Contract Security Program are subject to the new criminal record check process, which means fingerprints are required. Next is the upgrade request. If an applicant requires an upgrade to their personnel security screening or clearance, a criminal record check will be required. In this case, the applicant must get electronic fingerprints. However, if an applicant submitted a request for a screening or a clearance to the program, within the last year, the program will be able to use the criminal record check results generated by the RCMP as part of its reviewing process and no further fingerprints will be required. Upgrade requests include any individuals holding a Reliability status requiring a Secret clearance or any individual holding a Secret clearance requiring Top Secret. Please note: if a CSO [company security officer or] ACSO [alternate company security officer] is using the personnel security screening services (PSSS) through the online industrial security services (OLISS) portal to submit an applicant’s personnel security screening request, they must select the upgrade option when employees cleared at the Reliability status level are in need of a Secret or Top Secret clearance. Another occasion when fingerprints are required is when an applicant requires an update (renewal) to a personnel screening [or] clearance Generally, electronic fingerprints will always be required. However, in cases where an applicant has already undergone a criminal record check through the Contract Security Program within the 1 year of the date the update (renewal) request was submitted, no further fingerprints will be required. Again, this is because the CSP can use the RCMP-generated results to process the clearance request. Lastly is the signals intelligence [SIGINT] request. This request is rare but electronic fingerprints are still mandatory. Electronic fingerprints are not required in cases of transfer requests, unless, of course, an applicant’s personnel security clearance is due for an update (renewal). A transfer is completed when an organization’s employee needs to have their existing security screening transferred from one government department or agency to another government department or agency. A company security officer can find out if a transfer is possible by looking at the TBS 330-23 form, in section B, where an applicant is asked to indicate if they have previously completed a Government of Canada security screening form. Note: It is not possible for an organization to transfer an employee’s security screening from its company to a government department or agency. Only a government department can make that request on behalf of that organization. Also, it is very important to note that an organization can only transfer its [own] employee’s clearance. This means a company cannot request to transfer the clearance of a resource that is subcontracted. In such cases, the subcontractor’s company security officer would need to submit that request. Also please note that you cannot transfer an employee’s fingerprints or the results of a criminal record check stemming from a fingerprint. To transfer a security clearance, 3 things must happen: • First, the employee’s security screening must still be valid • Second, their screening must not be due for updating • And third, your organization must be registered and in good standing with the Contract Security Program For duplications, electronic fingerprints are not required unless there is a change of circumstance. An employee’s clearance may be duplicated if that employee needs to work for more than one organization whose Government of Canada contract has a security requirement and if the following 3 criteria are met: • The employee’s security screening is still valid. The individual must also confirm that there have been no changes in their personal history regarding criminal convictions • The employee screening is not due for updating • And, the organization duplicating the employee’s clearance is registered and in good standing with the Contract Security Program If any of these criteria are not met, a new clearance request for that employee must be submitted and fingerprints will be required. NATO and COSMIC special access requests: Fingerprints are not required if an applicant requesting North Atlantic Treaty Organization (NATO) and Control of Secret Material in an International Command (COSMIC) special access because they already hold a valid Secret or Top Secret clearance, and these requests do not constitute an upgrade. COSMIC is a NATO Top Secret clearance. Additional steps may apply depending on the requirement. You can visit our website [Personnel security clearances—What type do you need?] or contact our program to learn more about COSMIC [and] NATO clearances. Lastly, fingerprints may be requested in the following circumstances: Reactivation requests Electronic fingerprints are only required to reactivate a personnel security clearance that has been inactive for more than 1 year and, in this case, the applicant’s security clearance would be processed as a new request and would require fingerprints. A reactivation request pertains to the employees who previously held a personnel security clearance with a private sector organization registered in the Contract Security Program. A personnel security screening request is considered inactive when a personnel security clearance termination has been submitted for that employee to the Contract Security Program by the company security officer. For out of country verifications, electronic fingerprints may also be required when applicants have lived or worked outside of Canada for at least six months consecutively. In such cases, the Contract Security Program would inform the company security officer of this requirement. To help organization security officials and their applicants better understand how to submit a personnel security screening request that needs mandatory fingerprints, the Contract Security Program developed an easy 7-step process. Before we start reviewing these steps, we would like to remind you that you can also conveniently find a copy of these steps listed on our website [Mandatory electronic fingerprints]. At the end of this video, you will also see all relevant website pages listed to help guide you through this process. The first step involves the organization security official (CSO or ACSO). The CSO [or] ACSO needs to determine if an employee needs a personnel security clearance and at what level. [Second step] If the answer is yes, the CSO [or] ACSO needs to provide their employee (also referred to here as the applicant) with a copy of the Public Services and Procurement Canada (PSPC) fingerprint applicant request form. This form can also be found on our website. Next [third step], the employee brings the form to a police agency or accredited fingerprint company, certified and accredited by the RCMP, and requests that the service provider fill in the form. Then [fourth step], the service provider takes the applicant’s electronic fingerprints. As part of this process, a 20-digit document control number (also referred to as the DCN) is generated and identified on the electronic fingerprint transaction record. The DCN must be recorded on the applicant request form. It is very important that the applicant receives a copy of the electronic fingerprint transaction record with the DCN and a copy of the applicant request form with the DCN recorded. We also ask that applicants request a copy of the RCMP SRE submission results electronic (SRE) transaction record [search results] response data sheet, which identifies the applicant’s DCN and confirms the destination to where the criminal record check results will be sent. These documents can later help validate the correct DCN associated with the applicant’s criminal record check results and help the program identify any potential un-matching issues. We also remind organization security officials to first verify with the service provider, before sending an applicant for fingerprinting, that their fingerprinting system is set up to enter the PSPC reference number. This number is on the applicant request form. It is PQ80800). This number needs to be entered in the service provider fingerprinting system. It allows the applicant’s results of the RCMP criminal record check, to be sent directly from the RCMP database to Public Services and Procurement Canada (PSPC) for processing. We have now reached step 5. At this step, the applicant’s electronic fingerprints are forwarded electronically to the RCMP by the service provider. As mentioned earlier, if the applicant lives in a remote location in Canada, their fingerprints may need to be taken on paper and sent to a central site to be scanned and submitted electronically to the RCMP. If an applicant is only given that option, the document control number from the submission must be included on the applicant’s personnel security screening application sent to the Contract Security Program. Please note: applicants must follow up with the central site to obtain the document control number (DCN) from the submission. For step 6, the applicant gives the form and a copy of the service provider receipt to their company security officer. It is the security official’s responsibility to proceed with the applicant personnel security screening request, either electronically via the online industrial security services (OLISS) portal or by submitting the request manually. Remember, starting February 1, 2017, all new, update or upgrade requests must include a DCN. For electronic requests, the company security officer must enter the document control number into OLISS. For manual requests, the company security officer must submit a copy of the service provider electronic fingerprint receipt. If a copy of the applicant request form is submitted with the relevant applicant’s TBS [330-23 and/or 330-60] personnel security screening forms, please also ensure a copy of the service provider receipt is included in the envelope. The program uses the document control number as proof that electronic fingerprints were taken and it allows the program to match the RCMP criminal record check results with the applicant’s request. It is very important to remember that PSPC cannot match the applicant’s criminal record check results if, at the time the fingerprints were taken and the DCN was generated, the service provider system did not include the PSPC PQ80800 reference number. This is because a service provider generated document control number cannot be transferred to or used by other departments or agencies. In the last step, step 7, the program receives the applicant personnel security screening application, including proof that fingerprints have been taken by matching the RCMP criminal record check results, with the applicant’s date of birth and associated DCN. The program reviews the application and proceeds with the remaining checks before determining if the request can be granted. If the request is granted, the organization company security officer is notified. The CSO or ACSO is then expected to ask their employee to read and sign the security briefing certificate and explain the responsibility associated with a granted Government of Canada clearance. And that is it: easy and fast. Now let’s take a look at the PSPC fingerprint applicant request form. Again, a copy of this form can be found on our website. As we mentioned earlier, it is very important that the applicant takes this form with them when they visit a service provider. You will notice at the top of the form, the PSPC reference number, PQ80800 [indicated as the ORI number on the form]. The following information should be added to the form: • The name of the applicant • The name of the applicant’s organization. Here the legal name should be used • The name of the fingerprint service provider. If the service provider is a police station or an RCMP detachment, the name of that station should be entered • The name of the person who conducted the electronic fingerprints • The date the fingerprints were taken • The 20-digit document control number. It is very important that the applicant confirms this number using the receipt produced by the service provider. The receipt would also list the applicant’s DCN The information contained on this applicant request form will help the organization security official to accurately fill in the applicant’s personnel security screening request, whether using the online portal or hand filling the TBS [330-23 and/or 330-60] forms. As we mentioned earlier, a document control number is generated when an applicant has their fingerprints taken and a criminal record check result is generated by the RCMP. This DCN allows the Contract Security Program to match the RCMP results to the applicant. Here is a chart to help you understand how the DCN works when requesting an applicant personnel security screening request by using the online Personnel Security Screening Service (PSSS) in OLISS. If a company security officer enters a new request and chooses “new individual,” the system will automatically prompt you to enter the fingerprint submission DCN. If the name of this applicant already exists in OLISS and you choose the option “Search Existing Individual,” the online system will automatically pre-populate the DCN that was submitted previously, if this was the case. If the pre-populated applicant’s DCN is no longer valid, the company security officer has to enter a new DCN. If the system cannot find a previous DCN for that applicant’s name, the new DCN field will automatically be pre-populated with zeroes. Also, if you intend on submitting a new request, and the system populates the applicant’s personal information from a previous request, the company security officer will see a new DCN field appear, along with a confirmed DCN field. In such cases, the company security officer must enter a valid DCN. A valid DCN is one that has been issued by a fingerprint service provider and where the criminal record check results have been sent from the RCMP directly to the Contract Security Program. If criminal record check results were sent by the RCMP to the applicant and these results were then mailed to the program, the DCN generated from the fingerprints would also be valid. A valid DCN would also have to be issued within the last year. It is safe to say that if the applicant was sent for fingerprints after February 1, 2017, and an applicant request form was used, the DCN obtained from that transaction would be valid and could be entered in the online DCN field. Please remember: for all new requests, the online system will automatically prompt you to provide a DCN. However, although you may not be automatically prompted, as mentioned earlier, any update or upgrade type requests also require a DCN. As such, the company security officer would need to enter the applicant’s document control number in the DCN field. Company security officers can create applicants’ personnel security screening requests requests and not submit them to the
contract security program immediately in fact the PSSS system in OLISS allows
the user up to 120 days to submit the created application now that mandatory
fingerprints are required for new update renewal or upgrade requests a company
security officer should understand what happens when an applicant’s fingerprints
are taken and criminal record check results are sent to our program by the
RCMP. The RCMP generated results will generally be sent to the program
immediately after the applicants fingerprints are taken. When our CMP
results are sent to the program and there are no personnel security
screening requests to match with that applicants DCN, and criminal record check
results, the program cannot start processing the applicants clearance
requests. We would like to remind company security officers that when an
applicants request is created in PSSS within OLISS and the personal
information has been verified, the company security officer needs to click
the submit button. If the submit button is not selected, the applicant’s
information will not be sent to the contract security program for processing.
For example all new update or upgrade applications created in PSSS within
OLISS before february 1st 2017, that have not yet been submitted to the Contract
Security Program and do not include a DCN will be rejected by the program when
received. If you are using PSSS within OLISS to
fill out an applicant security screening request, the contract security program
does not need a copy of the applicant request form or a copy of the
fingerprinting receipt the DCN associated to the fingerprint submission
for the application must be entered in OLISS and that is all. It is highly
recommended that a copy of the applicant request form, the electronic fingerprint
transaction record and the service provider generated RCMP SRE response
data sheet be kept in case an online applicant request, the RCMP criminal
record check results and the DCN are unmatched. In cases where the program
cannot match the application with a criminal check result, the program will
contact the company security officer, highlighting the next steps or the
proposed options. This may mean the applicant has to return to the service
provider and ensure that the results are submitted to the appropriate destination
as per the PSPC reference number on the fingerprints applicant request form
which is also the ORI number PQ80800. If a company security officer is manually filling out a personal security
screening request for one of their employees that security official must
send: – the respective TBS screening forms – a TBS 330-23 for reliability
status or both the TBS 330-23 and 330-60 secret or top secret
clearance – a copy of the PSPC filled out fingerprint applicant request form a
copy of the service provider receipt. Copies of service provider fingerprint
receipts are used as a means to validate the 20 digit document control number. It
helps the program confirm the number entered on the fingerprint applicant
request form a copy of the service provider RCMP SRE response data sheet.
This sheet when printed will help the applicant validate where the criminal
record check results will be sent to. It is very important that the destination
refer to the PSPC ORI code PQ80800. If the results are
not sent to that destination, our program will not be able to match the personnel
security screening request with the criminal record check results. Please
note that the RCMP SRE response data sheet contains private information and
by sending a copy of this form to the program you consent to releasing the
information contained within for contract security programs use only. All
four documents must be sent to our program with the applicants request in
order for the request to be complete. Tools have been developed and are
available on our website to help security officials verify that the
application is complete and there is no missing information. You can visit our
website at the link shown on your screen. Please remember the program cannot
accept fingerprint applicant request forms or copies of service provider
receipts without the applicant’s TBS screening forms. Conversely the program
will not accept personal security requests from individuals. Private sector
applicants personnel security screening requests submitted to the PS PC can only
be submitted by security officials from organizations registered in the contract
security program. If you have any inquiries concerning
Government of Canada contract security requirements, the Contract Security
Program’s client service center is your first point of contact. Our team of
devoted client service representatives will respond to your inquiry or transfer
it to a subject matter expert for further action. This is the best way to
ensure that your call is dealt with effectively. Our contact information is
shown on this slide. You can contact us by phone, email or visit our website to
read helpful information that may help you answer your own inquiry.
We hope you enjoyed this video and now feel more confident in implementing the
new criminal record check process and in submitting new update or upgrade
screening requests to the Contract Security Program. We leave you with some
useful links that you can refer to as needed for more information on the
various topics related to fingerprinting.