Reminder: Review Your Fingerprinting Program
Tags : Fingerprinting
BIG wants to remind our fingerprinting service clients that it is crucial for legal counsel and/or other experts to continually review your fingerprinting program to ensure compliance with updated FBI requirements.
The FBI has recently updated their requirements for Channelers who repurpose fingerprints. In light of these recent changes, please consider the following compliance points, as referenced in our prior News to Note:
- It is standard industry practice and FBI requirement to receive consent from the subject for the use of their fingerprints.
- There is a clear expectation from the FBI that you obtain consent for the specific use of a fingerprint.
- You must obtain consent prior to the collection and use of a fingerprint.
- Consent should not be generic or global to cover all fingerprinting purposes but rather targeted for that specific fingerprint's purpose, known at the time of the print's collection.
For reference and provided as general guidance, please see our provided sample specific consent, for consideration by competent counsel and/or other experts for use under the FBI requirements to have explicit consent prior to fingerprint collection. Please review this process with your legal representation to make an informed decision regarding your onboarding program and its use of fingerprinting.
If you have any additional questions or concerns, please contact your BIG sales executive, account manager, or customer service team.
Posted: June 3, 2021
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This document and/or presentation is provided as a service to our customers. Its contents are designed solely for informational purposes, and should not be inferred or understood as legal advice or binding case law, nor shared with any third parties. Persons in need of legal assistance should seek the advice of competent legal counsel. Although care has been taken in preparation of these materials, we cannot guarantee the accuracy, currency or completeness of the information contained within it. Anyone using this information does so at his or her own risk.
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