GHRR Standard Reporting Procedures
Basic Reporting Information
GHRR will report pending criminal cases and felony and misdemeanor convictions for the seven years preceding the date of the request for a report, even though the consumer may have convictions which are older than seven years, unless a different reporting scope is expressly agreed to by GHRR and the Customer in writing, such alternate reporting scope being contingent upon, and limited by, the parameters of state law. Certain low-level convictions, such as ordinance violations, infractions, and traffic violations, may not be reported, even though they may be technically classified as misdemeanor-level offenses under a given state’s law.
Reporting Scope of Convictions
GHRR generally calculates the time period for the reportability of convictions is from the date of disposition, end of sentencing term, or end of the probation term, whichever event occurs last and irrespective of whether the consumer was released from prison, jail, or probation early. In certain states which prohibit reporting convictions that antedate the report by more than seven years, GHRR will disregard sentencing and probation and calculate reportability based upon the disposition date.
State Police Records, aka “RAP Sheets”
When reporting criminal history information obtained from a “RAP Sheet” procured from a statewide law enforcement (executive) agency, GHRR in its role as a consumer reporting agency cannot report all information contained therein, even though state law may require a customer to obtain a complete and unredacted copy of the RAP Sheet. If a customer is required to obtain and maintain in its files a complete copy of a RAP Sheet, GHRR recommends Customer purchase separate third-party administrative record retrieval services.
Reporting of Non-Conviction Adverse Information
The term “Non-Conviction Adverse Event” means any adverse item about a consumer other than a criminal conviction as that term is defined under applicable state or federal law. The following is an illustrative, non-exhaustive, list of examples of Non-Conviction Adverse Events:
- Records of arrest not leading to conviction
- Dismissed criminal charges,
- Juvenile adjudications
- Completed deferred adjudications
- Dismissed or vacated convictions
- Dispositions which may qualify as convictions under federal law but which do not constitute convictions under state law
- Moving violation reports
- Driver’s license suspensions
- Adverse professional licensing actions
- Sanctions or exclusion history information
- Civil suit information.
As a general principle, unless an adverse event is a conviction, it should be considered a Non-Conviction Adverse Event; however, pending charges are not considered Non-Conviction Adverse Events unless the file date of the case is older than seven years.
GHRR does not ordinarily report Non-Conviction Adverse Events, even if they occurred in the last seven years, unless one of the following applies: (a) Customer orders a specific search that pertains to Non-Conviction Adverse Events, such as driver’s license reports, sanctions and exclusion searches, professional licensure verifications, and civil searches; or (b) the parties agree in writing that GHRR will furnish Non-Conviction Adverse Events, subject to any limitations on reporting imposed by federal and state consumer reporting laws as well as any other limitations as to the scope and extent of reporting agreed upon by the parties. GHRR may in its sole discretion cease reporting Non-Conviction Adverse Events.
For professional licensing-related sanctions, exclusions, and similar adverse information, GHRR will only report the status of the Primary Name for the last seven years with regard to that adverse information. For motor vehicle or driving record reports, GHRR will report the information returned by the state department of motor vehicle for the driver’s license number supplied but said information will not exceed seven years of age.
Identity Matching Requirements
Federal and state consumer reporting laws require GHRR to establish a match of identity between the record containing adverse information and the Consumer; if GHRR cannot establish this identity match to its commercially reasonable satisfaction, GHRR will not report the adverse information