RE: Proposed Change to Criminal Record Check Process to Fingerprint Submissions
From: National Association of Professional Background Screeners (NAPBS) - Canada Chapter
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As a like-minded stakeholder who represents a specific industry, NAPBS Canada wanted to share that
the Royal Canadian Mounted Police (RCMP) has proposed a change to the background screening process
used by employers, volunteer organizations and landlords every day to ensure the safety of their
employees, members, residents and customers.
This proposal will eliminate an organization’s ability to conduct criminal record checks utilizing an
individual’s full name and date of birth and require employers who wish to complete background checks
to utilize a mandated fingerprint-based system with extensive delays.
On behalf of our member companies, we would greatly appreciate your support on this critical piece
of legislation.
NAPBS is a non-profit professional association that represents over 750 companies engaged in
employment, volunteer and tenant background screening across the globe who are dedicated to
providing the public with safe places to live, work and volunteer. We are the voice of the background
screening industry, and our member companies range from Fortune 100 companies to small local
businesses, conducting millions of employment, volunteer and tenant background checks each year.
In Canada our goals are:
• To foster professionalism and high business standards in the field of background screening;
• To provide a forum for discussing, developing and advancing mutually agreed upon purposes of
members;
• To discuss, develop and advance learning opportunities and professional education in background
screening.
The proposed change to the criminal record check process will result in costs of routine checks
skyrocketing to upwards of $75 and more; increased turnaround time; extensive workflow coordination
and inconvenience to complete the fingerprint capture; and cultural changes for your members. This
process has been seen as an invasion of privacy for the millions of Canadians applying for work and
volunteer opportunities. We encourage you to speak with your members and correspond with the
Minister of Public Safety, as you deem appropriate. Through our Association’s efforts, many of your
members may already be aware of this discussed change and we encourage you to seek their input on
the impact to their organizations to fully understand the financial, operational and risk impacts such a
decision will have on their organization.
The added costs and processes have been seen by many as an additional and unwanted tax on
employers and workers, one which could have the downstream negative impact of limiting employment
growth, volunteerism rates or job replacement across Canada. The implications of this policy change
will be broadly experienced and are expected to be counterproductive to community and workplace
safety. By increasing the cost, time and overall burden to complete checks employers may opt out of or
reduce their screening program, a program that was designed and implemented for safety reasons.
NAPBS is committed to upholding the security and privacy of Canadians. Our concerns centre around the
manner in which the change is being carried out, the impact it will have on millions of Canadians, and
the elimination of any options for organizations to decide how they want to best mitigate their own risk.
Please find below a proposed draft of a letter to customize and forward to the Minister of Public Safety,
Steven Blaney.
To maximize the value of this correspondence, we strongly suggest that you compose your own letter.
The draft supplied is only for your information but contains speaking points you may wish to include.
Minister Blaney’s contacts are:
https://www.publicsafety.gc.ca/cnt/bt/cntct-frm-eng.aspx,
The Honourable Steven Blaney
Minister of Public Safety and Emergency Preparedness
Government of Canada,
269 Laurier Avenue, West,
Ottawa, Ontario K1A 0P8
If you need additional information, require an electronic version of the template below, would like to
speak with us directly or have any questions, please do not hesitate to contact us. If helpful, we can also
provide a more detailed white paper on the impact these changes will have to all organizations.
Via mail:
Via email:
NAPBS - Canada Chapter
Garda 305 Milner Avenue, Suite 900
Toronto, ON M1B 3V4
[email protected]
Respectfully submitted,
Government Relations Committee
NAPBS Canada
(Your Association Letterhead)
Date
Dear Minister Blaney,
It has come to our organization’s attention that the process for obtaining criminal record checks in
Canada may be changing. I am writing to express our concerns about the Royal Canadian Mounted
Police (RCMP) taking steps to mandate that the only way a search for criminal record convictions can be
conducted is via the submission of the applicant’s fingerprints. Mr. Minister, this is both unnecessary
and untenable for our members’ business operations. On behalf of our organization, we find such a
change to be an unacceptable and economically discriminatory action taken with respect to our
members, our industry and our well-honed recruitment practices.
We do not understand the impetus for this change and steadfastly remain to be convinced that there
are any significant benefits to be gained by substituting the current name-based process with a more
costly, inconvenient and time-consuming fingerprint process. In the absence of compelling evidence
that such a change is of any concrete benefit, such a mandate appears to be an excessive response to an
undefined problem that has not been experienced. It has the definite appearance of an undesirable tax
on employers, and a needless financial imposition placed upon the backs of Canadians seeking
employment or volunteer opportunities. These are difficult times for new employment growth within
our sector and for Canadians in general, and the annual downstream cost impact to almost one third of
working Canadians cannot be underestimated. This is simply cost prohibitive to all.
The current process of conducting criminal record checks via name and date of birth has been working in
a fully satisfactory manner for our members for decades. It provides cost effective, outstandingly
reliable and timely decision support which ensures the safety of staff, workplaces, customers, and
assets. The current process allows organizations to demonstrate due diligence and mitigate risk. A
change as described may decidedly limit, or be counterproductive, to these worthwhile objectives.
The procedures that are in place today balance process, cost and convenience with healthy risk
mitigation. Our industry suppliers have access to many forms of data and onboarding practices that
enable a person’s identity to be fully verified. We hold the view that fingerprints need only be
introduced on rare occasions when results are inconclusive. It is our view that Canadian organizations,
based on their own risk mitigation reviews and analysis, should be allowed to choose when a
fingerprint-based process is needed, rather than this proposed Canadian mandate.
If this change is put into practice, Canada, a country that takes great pride in its human rights record,
will be the only country in the world that requires the submission of fingerprints when applying for a job
or to volunteer. The invasion of privacy and cultural implications of fingerprints pose additional
challenges to such a proposal.
Our organization strongly opposes these changes and we ask you to speak against this proposal.
Respectfully Submitted,
(Your Association Information)