Sterling periodically reviews our sample forms based on industry best practices and trends in litigation. Recently, we have seen claims brought against employers arguing that the FCRA disclosure for consumer reports and the disclosure for investigative consumer reports cannot be combined. As a precaution and to avoid any confusion, Sterling is making a change to separate the two disclosures into two distinct forms.
Starting Wednesday, July 8, 2020, Sterling is removing the investigative language from the stand-alone FCRA disclosure form and creating a separate investigative disclosure on its own page.
Action Required
Going forward, our sample forms – both paper versions and sample forms – will include an FCRA disclosure followed by an investigative disclosure. We recommend that you, as an employer, review the forms with your legal counsel prior to use. Note: If you use custom forms in Sterling’s system, no updates will be made automatically to your forms. Please review the new forms with your legal counsel and contact your Sterling Client Success representative to update your existing forms.
Thank you for your continued trust in Sterling. If you have any questions or concerns, please contact your Sterling Client Success representative.