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Archive for April, 2009

Conducting Background Investigations in the Middle East

Thursday, April 16th, 2009

By Zafar I. Anjum, CFE
CEO, CRI Group
Dubai, UAE

In the complex world of employee background screening, no two countries are alike.  In the United States investigators have a web of databases at their disposal and a vast network of local esources that provide a wealth of information at the mere click of a mouse.

It’s a different world in the Middle East.  Technology is limited in many parts of the region.  Privacy legislation varies from country to country and from jurisdiction to jurisdiction.  Cultural differences can impact the flow of information.  Language barriers can contribute to inaccurate reporting.

Instead of database-driven investigations that are generally conducted in the United States, professionals in the Middle East must conduct large parts of their investigations literally on foot, traveling to remote regions to scour records and interview sources.

Simply put, if you’re looking for accurate, reliable information in the Middle East you need to turn to qualified, professional sources that are familiar with the countries, cultures, terrain, languages, resources and – most of all – the laws that govern personal privacy..  In this part of the world your contacts and resources are your greatest asset.

Discovering Hard-to-Find Facts in Hard-to-Reach Locations

The biggest challenge to conducting background investigations in the Middle East is collecting reliable information in the most efficient manner.  This requires a well-trained and diverse group of professional investigators who are multilingual and multi-cultural, are familiar with those geographic regions and can easily traverse the obstacles that often impede international investigations.  Those obstacles include:

  • Working with local customs offices
  • Complying with data protection laws and mandates;
  • Knowledge level of local investigative researchers;
  • Lack of centralized information resources and databases; and
  • The proliferation of multicultural environments that are particularly influenced by locals who vastly differ in their approaches to investigative screening and public record searches, particularly with information collected via database sources.

To address these obstacles, successful background investigators in this part of the world are often requires working deep in the field, traveling to remote destinations to conduct interviews, develop resources and enlist local assistance to verify information.

As one of the largest screening firms in the Middle East, CRI Group’s investigations regularly involve conducting a thorough review of local press records, using online and proprietary databases augmented by manual field research to locate the appropriate public records. This in-depth investigative approach is necessary to bring to light any instances of malfeasance or notable publicly aired criticism. Our professionals also research all public records that are available within the respective government institutions such as a region’s trial courts, police and SEC sources, and global sanctions lists.

The results of this level of investigative legwork is the collection of timely, well-documented and substantiated information that measures up to the high standards often required by our U.S. counterparts.

Examples of Privacy Laws in the Middle East

While reputable screening firms in the United States comply closely with the Fair Credit Reporting Act to conduct domestic background investigations, foreign investigations are much more complex.

Middle East countries have no prohibitive legislation that governs the employment screening process.  At the same time there is no cooperative legislation and regulation to support background screening services for employee due diligence.  However we, as industry professionals, must adhere to strict data protection requirements to process consensually based personal information.

In our region local police departments provide “Good Conduct Certificates” for employees for immigration purposes, while the Dubai International Financial Centre (DIFC) awards a “Police Clearance” certificate for employee due diligence work.

In the United Arab Emirates, data protection laws permit investigators to process sensitive personal information such as criminal history data.  As a DIFC licensed entity, the CRI Group (as well as other reputable background screening firms) must maintain strict adherence to the region’s Data Protection Law of 2007 in order to fulfill our ongoing DIFC licensed status.  As in the United States, the procurement of personal data in this region – and any subsequent transfer of data outside of the DIFC – may only be attained with the written consent of the individual being investigated.

In compliance with the European Union data protection directive, the CRI Group has also adopted a strict stance on corporate self-monitoring by appointing a Data Protection Officer (DPO) whose primary responsibility is to conduct independent audits of our various information processing operations that handle customer and employee data.  The DPO ensures that personal data is handled in accordance with all relevant data protection provisions covering online and offline data procurement while complying with local and regional regulations pertaining to individual privacy standards.

How to Locate and Partner with Reputable Screening Firms in the Middle East

So how does one go about securing a reputable background screening source abroad?  The following checklist may be helpful.

  1. To begin, it is highly recommended that you research the listing of expatriate security firms provided by the National Association of Professional Background Screeners (NAPBS). The list can be found at NAPBS Website.
  2. Ask your provider how they comply with local and regional laws governing individual privacy protection and the methods they utilize in protecting information.
  3. Make sure your service provider’s physical address is in the region they’re conducting investigations. If not, they could be simply outsourcing their cases to a third party.
  4. Ask about the manner in which your service provider conducts investigations. Stay away from firms that investigate exclusively through media searches.
  5. Don’t settle for firms that say they specialize in providing checks of the International Terrorist Watch List and the OFAC watch list. Those lists are available online to anyone at no cost.
  6. Stay away from firms that won’t supply you with the source of the records they obtain. Also, be sure to ask how old the information collected is.
  7. The truly reputable firms will combine in-depth field investigations with routine public records searches. Make sure your provider is doing both.
  8. Service delivery is critical in foreign investigations. Ask about average turnaround times and get commitments for delivery in advance of the investigation.
  9. Find out what other U.S. companies use the service provider. Ask for references.

As the world economy shrinks and the pool of foreign job applicants expands, a partnership with a reputable international background screening service provider to conduct investigations abroad is essential for maintaining a safe hiring program for your clients.  To ensure you’re using the best providers available, a little investigating of your own will result in big benefits down the road.

Zafar I. Anjum, CFE is chief executive officer of CRI Group, a global supplier of investigative, forensic accounting, business due diligence and employee background screening services for some of the world’s leading business organizations.  A member of the Dubai International Financial Centre, CRI safeguards businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business.  CRI Group maintains offices in Dubai, Islamabad, Lahore, Karachi, Manila, Riyadh and the United Kingdom.