Scope
- All US-based candidates for employment (full-time, part-time, intern) and contractors who will receive Neuroscale-issued credentials, devices, or access to Confidential data.
- Re-screens of existing employees triggered by role changes into security-sensitive positions or by periodic re-screen requirements for high-trust roles.
- Out of scope: customer or vendor-side due diligence (covered by Vendor Risk Assessment).
Roles
| Role | Responsibility |
|---|---|
| CHRO | Procedure owner; final approval of adverse-action decisions affecting hiring outcomes. |
| General Counsel | Reviews adverse-action letters, state-specific notices, and any candidate disputes. |
| People Operations (today: CHRO; see Roles & Personnel alias map) | Day-to-day operation: orders the report, sends notices, tracks waiting periods. |
| CISO | Defines which roles are “security-sensitive” and require enhanced or periodic re-screening. |
| Hiring Manager | Receives the disposition (clear / review / no-hire) but never the underlying report content. |
CRA — Checkr
Neuroscale uses Checkr as its Consumer Reporting Agency. The Master Services Agreement and Data Processing Addendum on file include:- A written certification of permissible purpose under 15 U.S.C. § 1681b(b)(1) — Neuroscale certifies, before each report is ordered, that the report will be used for employment purposes only, that all required disclosures have been made, that consent has been obtained, and that the report will not be used in violation of any federal or state equal-employment-opportunity law.
- Compliance attestations covering FCRA, the California Investigative Consumer Reporting Agencies Act (ICRAA), the New York City Fair Chance Act, Illinois HB 3994, and the Massachusetts CORI law.
- Data-handling commitments aligned with the Data Management Policy.
Pre-hire process
1. Job ad & application — ban-the-box compliance
- Job ads must not state or imply that applicants with criminal histories will not be considered, except where a specific role is barred by law (e.g., positions with regulated access).
- The employment application must not contain any question about criminal history.
- New York City roles: the job ad includes the NYC Fair Chance Act notice that Neuroscale will not consider criminal history until after a conditional offer of employment.
- Interviewers are trained not to ask about criminal history during the interview process.
2. Conditional offer
A background check is initiated only after a conditional offer of employment has been extended in writing.3. Disclosure & authorization
CHRO, via Checkr, sends the candidate two distinct documents:- A stand-alone disclosure stating that a consumer report (and, where applicable, an investigative consumer report) may be obtained for employment purposes. Per 15 U.S.C. § 1681b(b)(2)(A)(i) and binding case law (Syed v. M-I, LLC), the disclosure is a clear and conspicuous, stand-alone document — not embedded in the employment application or combined with liability waivers.
- A separate written authorization form signed by the candidate. See the Background-Check Consent template.
- A Summary of Your Rights Under the FCRA (CFPB-prescribed form).
- State-specific notices required by the candidate’s state of residence and intended work location, including (non-exhaustive):
- California (ICRAA): Notice that the candidate may request a copy of any investigative consumer report; the seven-year cap on reportable convictions per Cal. Civ. Code § 1786.18; investigative-consumer-reports notice.
- New York City (Fair Chance Act): Notice that criminal history will be reviewed only after a conditional offer.
- Massachusetts (CORI): Acknowledgement form for any CORI request and the standard CORI notice.
- Illinois (HB 3994 / Job Opportunities for Qualified Applicants Act, as amended): Notice that conviction records will be considered only after a conditional offer.
- Washington, Minnesota, New Jersey, Connecticut, Colorado, and other ban-the-box jurisdictions: Equivalent notices as required.
4. Order
CHRO files the Background Check intake form — which captures the role tier, the candidate’s residence and work-location, and the package selection — and, once authorization is captured in Checkr, orders the appropriate package for the role’s tier (defined by the CISO; security-sensitive roles receive enhanced packages including credit checks where job-related and legally permitted).Adjudication
Checkr returns the report to the CHRO review queue. Reports are matrix-adjudicated against role-specific criteria approved by the CHRO and General Counsel:- Clear — no records or only records that do not meet review criteria; hiring proceeds.
- Review — record matches a review criterion; triggers an individualized assessment as described below.
- Engaged — candidate self-disclosure or dispute in progress.
Individualized assessment
Where a record meets a review criterion, CHRO and the General Counsel conduct an individualized assessment considering the nature and gravity of the offense, the time elapsed, the nature of the position, and any evidence of rehabilitation, consistent with EEOC guidance and applicable state/city fair-chance laws.Pre-adverse action
If the individualized assessment indicates Neuroscale is likely to make an adverse decision in whole or in part based on the report, CHRO sends the candidate a pre-adverse-action notice containing:- A copy of the consumer report.
- A current copy of the Summary of Your Rights Under the FCRA.
- Any state- or city-specific notices required (e.g., the NYC Fair Chance Act Notice, including the position-specific Article 23-A analysis form).
- A clear statement of which item(s) in the report are at issue.
- Instructions on how to dispute the accuracy or completeness of the report directly with Checkr.
Final adverse action
If, after the waiting period, the decision remains adverse, CHRO sends a final adverse-action notice that includes, per 15 U.S.C. § 1681m(a):- The name, address, and toll-free telephone number of the CRA (Checkr) that furnished the report.
- A statement that the CRA did not make the adverse decision and is unable to provide the specific reasons why the decision was made.
- A statement of the candidate’s right to obtain a free copy of the report from the CRA within 60 days.
- A statement of the candidate’s right to dispute the accuracy or completeness of any information in the report directly with the CRA.
- All applicable state- and city-specific adverse-action notices (e.g., the NYC Fair Chance Act final determination, California ICRAA notice).
Records retention
Records of every step of this procedure — disclosure and authorization forms, the report itself, the individualized assessment, the pre-adverse and final adverse notices, and any candidate correspondence — are retained per the Records Retention Schedule.- Adverse-action records: retained for 5 years from the date of the adverse action.
- Consent and disclosure forms (cleared candidates): retained for the duration of employment plus 5 years (or as required by state law).
- All records are stored in the CHRO folder of SharePoint with access restricted to the CHRO, People Operations support staff, and the General Counsel.
Re-screening
A re-screen is triggered when:- An existing employee or contractor moves into a role classified by the CISO as security-sensitive (e.g., production-data access, financial systems).
- A high-trust role reaches its periodic re-screen window — every 3 years for roles handling production data or financial-control responsibilities.
- A specific event (e.g., reported misconduct triggering a fitness-for-duty review) is approved by the CHRO and General Counsel.
Cross-references
- Human Resources Security Policy
- Background-Check Consent template
- Adverse-Action Letter template
- Records Retention Schedule
- Onboarding
Version history
| Version | Date | Description | Author | Approved by |
|---|---|---|---|---|
| 1.0 | May 8, 2026 | Initial version | Cameron Wolfe | Ishan Jadhwani |