Security Screening
Credit Check – Questions and Answers

A1. The new Treasury Board Secretariat (TBS) Standard on Security Screening that came into effect on October 20, 2014, for all Government of Canada departments and agencies established a risk- based approach to security screening. As part of this new Standard, a credit check, which is only one of a number of factors considered during the security screening process, is a mandatory requirement.

The new Standard on Security Screening will be implemented over a 36 month period. Effective October 20, 2014, credit checks are mandatory for all new requests for security screening. Credit checks for current employees and contractors will be implemented as security screening is required for update or upgrade or reviews for cause.

A2. This new requirement applies to all individuals employed by, or working in departments as defined in section 2 and any other agency included in Schedules IV and V of the Financial Administration Act (FAA), unless excluded by specific acts, regulations or orders-in-council. This includes employees, volunteers, students or persons on loan, assignment or secondment, private sector contractors, and foreign and domestic visitors.

A3. No, the practice of conducting mandatory financial inquiries (credit checks) for security screening dates back to 1986 when the first Treasury Board Government Security Policy was introduced. At that time, although optional for Reliability screening, some departments conducted credit checks on a mandatory basis for all levels of screening. A credit check has continued to be a mandatory check for security clearance screening.

A4. An assessment of the trustworthiness and reliability of all individuals accessing sensitive information and/or assets must be undertaken to protect the interests and security of the Government of Canada. A credit report will be reviewed, in addition to other information collected (e.g. criminal record check, employment history, personal character references), to assist in assessing an individuals’ reliability and trustworthiness, as an employee of or individual working with the Government of Canada (as per Q2).

A5. A credit history is a record of an individual's past borrowing and repaying, including information about late payments and bankruptcy. It is used as a measure of reliability. The information in a credit history includes date of birth, addresses, employment information as well as a comprehensive history of the current credit or credit which has been used at any time in the past 6 years—or longer if bankruptcy was declared. This history is kept up-to-date by the banks, credit card companies, retailers, auto lease financing companies and other establishments that provide an individual with credit.

A6. The overall assessment of reliability considers an individual’s trustworthiness in protecting government assets, information and facilities. An individual's financial situation is relevant to this assessment, particularly as it relates to their ability to meet their financial obligations. Information that may be of concern would be an inability to make payments on time, accounts placed for collections or written off by financial institutions as unrecoverable or a very high ratio of debt when compared to income. Information contained in a credit report can also be used to validate other information provided by an individual such as previous address, date of birth etc.

A7. No, credit checks conducted for the purpose of security screening are masked so that a negative effect does not occur on the individual’s credit bureau file. Only credit checks performed by Canadian financial institutions (e.g. banks, credit agencies, etc.), which are interpreted by credit reporting agencies as attempts by the individuals to obtain credit, have an impact on an individual's credit score.

A8. Yes, credit checks are legal. The Policy on Government Security, Standard on Security Screening provides the legal basis for verifying the credit history for security screening purposes for those individuals employed, contracted or hired at Government of Canada departments and agencies.

A9. The protection of personal information is governed by the Privacy Act which establishes personal information-handling practices of federal government departments and agencies to respect the privacy of all Canadian citizens and permanent residents. The Office of the Privacy Commissioner of Canada (OPC) oversees compliance with the Privacy Act.

With respect to the security of your information, the credit report is made available through the credit reporting agency’s web site using secure connectivity methods (e.g. point to point connections, SSL encryption), and client identification information on each transaction is validated by the credit reporting agency prior to being processed. The encryption process transforms sensitive information into a string of unrecognizable characters before they are sent over the Internet and helps keep the information private between the computer system and the Internet browser. In addition to encryption, a unique Username and Password would be required to authenticate the department or agency security official processing the credit check each time they access / use the service.

Both Equifax and TransUnion detail their privacy and security practices in their respective privacy policies published on their web sites.

A10. As part of the security screening assessment, credit bureau verification will be conducted for all individuals as part of security screening. It is mandatory that section “C” #3 of the Personnel Screening, Consent and Authorization form (TBS 330-23) be initialed by the individual providing the Personnel Security Screening office with consent to conduct a credit check. The collection of information for personnel security screening purposes will not be undertaken without an individual’s written consent.

A11. A credit check is a component of the new Standard on Security Screening and is required for employment. For initial requests where the individual refuses to provide consent or the required information, screening activities will cease and an administrative cancellation will follow. When a security screening is being updated or upgraded, the individual’s existing security screening must be suspended and reviewed for cause, and the human resources unit should be consulted.

This administrative cancellation will result in the individual no longer meeting the condition of employment and could result in an administrative termination of employment or cancellation/termination of a contract.

A12. The Departmental Security office will process these checks as one of the verifications undertaken in the personnel security screening process and will protect personal information in accordance with the provisions of the Privacy Act.

A13. It is the responsibility of the individual to contact the credit bureau to discuss further. The Departmental Security office is not permitted to discuss an individuals’ information with the credit bureau due to privacy reasons.

A14. The results will remain within the Departmental Security office’s personnel security screening files. They are protected and properly safeguarded in accordance with the Policy on Government Security, the Standard on Security Screening and the Privacy Act. The only information an individual will automatically receive is a confirmation that a Reliability Status or Security Clearance has been granted, denied or revoked. If the results of the credit check provide adverse information, such as a history of collection or missed payments, a more in-depth assessment is required which may require an interview with the individual by Departmental Security. The results of which will assist with the assessment and determination to grant, deny or revoke the Reliability Status or Security Clearance.

A15. It would be very unlikely that a credit check would form the basis for a denial or revocation of a Reliability Status or a Security Clearance. It is one part of a comprehensive assessment of information collected to determine reliability and trustworthiness. If it is deemed that the results of the credit check, along with other information found, could pose a risk to the functions being performed in an individual’s position, there is a possibility that these results will affect the specific assessment. Prior to any decision being made however, individuals will be informed and given an opportunity to respond to the information.

A16. This additional check should not cause any further delays as the report is available through the credit bureau’s supplier’s web interface. Should a report contain adverse information, delays may be incurred if it requires a more in-depth assessment is required (e.g. an interview with the individual to better understand the circumstances).

A17. The decision about an individual’s eligibility for a security status or clearance that follows the initial security screening process reflects the person’s eligibility at a specific point in time. That eligibility may change over time.

Aftercare practices provide confidence in an individual’s continued reliability and loyalty. Aftercare comprises formal, planned security briefings; security awareness; updates and upgrades; and the reporting of changes in circumstances or incidents.