Whether you like it or not, live scan fingerprinting is the formality that needs to be done before employment, immigration, or basically anything, in which a fingerprint-based criminal history check is required. The easy and widespread availability of live scan fingerprinting has made it a common activity that people need to go through whenever any application requires a criminal history background check.
This easy availability and casual attitude toward live scan fingerprinting, however, does not diminish its significance in any way. It is an important process, in which a casual approach may lead to errors and which can turn out to be costly in some cases. A trivial mistake in live scan fingerprinting can lead to lost opportunity for applicants and sometimes lost revenue for the live scan service provider.
1. Not properly explaining the details to the customer
Sometimes, possible mistakes with fingerprint submission may originate from the customer side, such as providing inaccurate ORI numbers or other demographic details. Once you submit your live scan application (electronically), you are going to be charged by the govt. agency for the background check.
This issue can be prevented in case of customers go through the live scan fingerprinting for the first time. This live scan fingerprinting mistake can be easily avoided while taking an appointment for a customer by properly explaining what to expect and what information/documents to carry while arriving for the fingerprinting.
2. Not checking proper identification documents
If you are a live scan fingerprinting service provider, it is very important to make sure that the applicant is carrying the proper IDs. In most cases, two forms of identification will be required. As a live scan service provider, it should be your first and foremost responsibility to check and verify a proper ID.
Some individuals who are coming for the live scan fingerprinting may have preconceptions about what form of identification they need to carry. For example, a folk may come carrying a student ID or a passport, in some cases that may be alright but the acceptance of the form of identification should conform to the local/state live scan background check requirements.
For a service provider, it is wise to stick to local/state guidelines for live scan fingerprinting. In the United States, these guidelines may vary from state to state. For example, the fingerprinting guideline may allow one form of identification such as a passport in one state, but the same ID may not be enough to prove your identity in another state.
It should be the live scan fingerprinting service providers’ responsibility to inform the customers about the ID verification requirement when they call up to make an appointment for a live scan or provide information on their web pages if online booking is available.
3. Incorrect ORI Number on Live Scan Request form
This is a trivial mistake that can ruin your chances of getting through live scan fingerprint successfully even if you have the cleanest criminal record in the world. ORI (Originating Agency Identification) is a unique number provided by the agency requesting fingerprinting. If you are submitting fingerprints using an FD-258 fingerprint card, it may have pre-printed ORI if you received it from the requesting agency.
Different departments have different ORI numbers and they will also be different for inter-departmental categories. For example, the medical department will have its own ORI number, the same as the other departments such as education, public services, etc. Further, within one department, there may be several categories that will have different ORI numbers.
For example, for nursing license fingerprinting requests, different categories or nursing licenses will have different ORI numbers. Similarly, a physician will have a different ORI number than a physiotherapist, even if they come under the same department.
Sometimes, your fingerprinting service provider (such as IDEMIA IdentoGo fingerprinting centers, which is authorized to accept fingerprints for certain departments in many states) offers an online tool to look for an ORI number.
Not mentioning an accurate ORI number can be a costly mistake on the FBI background check fingerprints form, which can lead to delays or even rejection of your fingerprint background check request.
4. Ignoring applicable laws/regulations
There is no one-size-fits-all set of guidelines or regulations for fingerprinting service providers across the country and these guidelines, recommendations, laws or regulations may vary from one state to another. It will be wise and in your best interest if you go through the guidelines and live scan fingerprinting recommendations applicable to your case. Ignoring these guidelines can sometimes be a costly live scan fingerprinting mistake.
5. Not paying attention while interpreting demographic data
Demographic information furnished by a customer can be confusing and may lead to errors if you don’t pay attention to the details. For example, there can be certain characters such as 1 (one), I – (small case L), that can be interchanged while entering data. Zero (0) may sometimes be interpreted as O, etc.
Sometimes data interpretation can be more prone to errors if there is a high volume and people queued up to get their live scan done. Such errors will cause delays and turn out to be costly for your business as well as the customer. It is wise to double-check when you are entering data that can be confusing.
6. Furnishing incorrect personal information
Live scan fingerprinting service providers can verify some of the information against ID and fingerprinting request forms. However, for some information, they have to rely completely on the applicant assuming the information provided on the live scan fingerprinting form (or paper fingerprint form) is accurate. Intentionally or unintentionally, providing inaccurate information can be one of the costly mistakes in fingerprinting.
7. Not maintaining the privacy of applicants
Live scan fingerprinting service providers often do not realize that they deal with highly sensitive personal information of individuals. An incident of mishandling this personal information may not only compromise this sensitive information but can also have legal implications putting them in trouble.
While applying for a fingerprint-based criminal history background check, applicants have to provide a lot of personal information such as their name, date of birth, place of birth, signature, and more. This information counts as Personally Identifiable Information (PII). There are specific laws for personal information and how it should be handled and stored. Being small-scale businesses, live scan fingerprinting service providers may be unaware of all the specifics of such laws and may be ignorant about these laws and the legal consequences that may follow.
On top of demographic information, live scan fingerprinting applications also include biometric information (fingerprint images) of the applicants. So far there are no country-wide biometric-specific laws and it is mostly considered PII, but sooner or later, these laws will be enacted considering the sensitive nature of the information.
8. Ignoring primary/secondary ID requirements
Live scan fingerprinting has identification document requirements, in which the fingerprinting service provider needs to document the photo ID presented by the customer (applicant). Most states require acceptance only of current, valid, and unexpired picture identification documents as primary valid identification.
For example, the California Department of Justice requires a primary form of photo identification (listed below) or a secondary form of photo identification (also listed below) with two supplemental documents.
The acceptable primary form of photo IDs in California
- California Driver’s License
- Department of Motor Vehicles Identification Card
- Out-of-state driver’s license
Acceptable secondary form of photo IDs in California
In the absence of a primary form of identification, one or more of the following may be accepted as secondary forms of identification, but only with two supplemental documents.
- The state government issued a Certificate of Birth
- U.S. Active Duty/Retiree/Reservist Military Identification Card (000 10-2)
- U.S. Passport
- Federal government Personal Identity Verification Card (PIV)
- Department of Defense Common Access Card
- U.S. Tribal or Bureau of Indian Affairs Identification Card
- Social Security Card
- Court Order for Name Change/Gender Change/Adoption/Divorce
- Marriage Certificate (Government issued certificate)
- U.S. Government issued Consular Report of Birth Abroad 3
- Foreign Passport with appropriate immigration document(s)
- Certificate of Citizenship (N560)
- Certificate of Naturalization (N550)
- INS I-551 Resident Alien Card issued since 1997
- INS I-688 Temporary Resident Identification Card
- INS I-688B, I-766 Employment Authorization Card
- Utility bill (address)
- Jurisdictional voter registration card
- Vehicle registration card/title
- Paycheck stub with name/address
- Spouse/parent affidavit
- A canceled check or bank statement
- Mortgage documents
When supplemental documentation does not support the validation of the original identification documents, staff will not accept the form of original identification as valid and the applicant will not be fingerprinted.
9. Not printing fingerprint card with a recommended printer
As a live scan fingerprinting service provider, you don’t depend only on “live scanning”.There will always be instances when a customer would want to submit his/her fingerprints by mail and not with electronic submission. Some would want them to be captured with a live scan and printed on the fingerprint card (FD-258 card). In some cases, there would be no option for electronic submissions(from the law enforcement side) an applicant would have to send in an FD-258 card. In such cases, not printing fingerprints with an FBI-approved/recommended printer can be a costly mistake.
Printing fingerprint images on the FD-258 card results in better accuracy and common flaws can be avoided that are present in ink-based fingerprint capture.
Printing with an ordinary printer may result in blurred, and overlapped details of customer fingerprints, which will most probably return or reject your request, causing unnecessary back-and-forth delays. To address this issue, the FBI recommends printers that can be used to live scan captured fingerprint images to a standard FD-258 card.
Fingerprints have minute details that need to be printed as precisely as possible as these fine details are what are used to match fingerprints by the FBI’s automated fingerprint recognition system (NGI). Printed fingerprint cards are scanned by the FBI and fed to the NGI, in order to search for potential records associated with that fingerprint. If fingerprints are not printed precisely on the card, you cannot expect acceptance of such fingerprints by the law enforcement agency.
10. Data integrity
What do we mean by data integrity? As a live scan service provider, you will be holding a lot of data about your customers including their personal and biometric information.
Last but not the least, as an owner of a live scan fingerprinting business, data integrity should be one of your ethics to follow. Here, you do not need to put your business values in black and white like big corporations, but keeping the concept of the idea of data integrity in your mind would be enough.
“Data integrity is the maintenance of, and the assurance of, data accuracy and consistency over its entire life-cycle and is a critical aspect to the design, implementation, and usage of any system that stores, processes, or retrieves data.”
Don’t let your friendly guy next door access your computer to surf the internet, just because you know him. Intentionally or unintentionally, there can be serious data integrity issues if you do not take care. Use passwords that are complex enough and are known by you or biometric login to your computer with your customer data. Keep your antivirus software and operating system updated.
Looking at all the conversations we had above, you might ask – what can be at stake? It’s just a mistake and the worse that can happen if the fingerprint application will be rejected. But think about this, rejected live scan fingerprinting applications would cause undesired delays for applicants, which means that an employer may consider hiring someone else. For another customer, this delay may mean a delayed or lost immigration opportunity or a business license.
For live scan service providers too, mistakes that you consider small can be costly. It can cost you your rolling fee; the fee paid to the law enforcement agency and above all, the trust of the customers in your business and service quality. Despite its easy availability, live scan fingerprinting is an important process and will always be.