WHITE PAPER

Information You Need to Know

HIRING EMPLOYEES AND VENDORS IN INDIA

India Quick Facts

• 1.2 billion population
• Second largest population behind China
• Hotspot for outsourcing

Overview
As employers around the world progress towards a standard practice in global background screening, they are discovering a
range of unique regional- and country specific issues that must be addressed and resolved to optimize their hiring success.
India, the focus of this document, is a prime example. For starters, India is a hotspot that has become synonymous with
the offshoring or outsourcing of key business processes such as information technology (IT), product development, shared
services for back office functions, and customer support. Likewise, considering its massive population, roughly 1.2 billion
people compared to 313 million people in the United States (U.S.), it’s also a hiring mecca for organizations looking to
recruit the best talent to work both inside and outside the country.
With India’s vast array of vendor options and employment candidates comes the responsibility of performing appropriate
levels of due diligence, and this is where country-specific background screening issues begin to emerge. With no
standardized government-issued identification (ID) such as a Social Security Number and no centralized databases for
criminal records or employment and educational data, the process of vetting vendors and candidates within India is largely
a manual, resource-intensive process that can be rife with subjectivity, inconsistency, inaccuracy and—if not carefully
managed—questionable, dubious and even corrupt practices. This is a potentially huge compliance risk for many global
organizations.
What’s more, restrictions and permissible searches vary based on governmental departments and jurisdictions, making
compliance a particularly complex burden for most organizations. Compliance can also be severely compromised by
localized vendors who may have little-to-no understanding of global compliance, multinational IT or data security
requirements, and lack the appropriate data security infrastructure, processes and business practices that large, global
businesses often require. These risks are real, and something every employer should consider when determining how to
screen candidates from India.

INFORMATION YOU NEED. PEOPLE YOU CAN TRUST.

What You Will Learn:
To help organizations build a model hiring program within India that minimizes risk associated with vendors, employees and
employment compliance, this white paper seeks to:

• Educate employers around the world about localized screening issues within India

• Explore how a trusted, quality background screening provider can help employers optimize their global hiring program

• Offer proactive best practices for screening success in India

India Quick Facts

• Workforce population is nearly 2x the entire U.S. population
• By 2020, India will provide 12% of advanced degrees attained by 25-34 year-old graduates globally

The Dichotomy in India: Talent and Fraud

Home to the second largest population in the world, just behind China, India is a vast country that encompasses 28 states and
seven union territories, which are further subdivided into smaller jurisdictions. While English is a common business language,
roughly six primary languages are spoken—Hindi, Bengali, Telugu, Marathi, Tamil and Urdu—with hundreds more spoken
throughout the country.
Considering the sheer size of India’s population, along with its political, logistical and linguistic diversity, employers must
work with trustworthy background screening vendors that have the in-country expertise, on-site employees, solution scope
and processing capacity to accurately perform high volumes of verifications and related employment checks.

A deep pool of talent

India’s workforce population is massive at more than 484 million people in 2012, nearly twice the size of the entire U.S.
population. With nearly 10 million students currently enrolled in higher education, the country produces millions of college
graduates each year. According to estimates by the Organization for Economic Cooperation and Development (OECD), in
the year 2020, India will provide 12 percent of advanced degrees attained by 25-34 year-old graduates globally - putting
India ahead of the U.S. and second only to China.

Fraud is alive and well

Despite its immense talent pool, there are issues to be aware of when hiring in India. For starters, resume and application fraud
is a big concern. The University Grant Commission (UGC) , a statutory organization within India charged with maintaining
higher education standards, recently issued a list of non-legitimate universities across the country that included 21 universities
and a few hundred distance learning centers, or so-called affiliated institutes or degree factories. “Non-legitimate” or “fake”
universities are unaccredited by a reliable source, which can mean several things. A school could be awaiting accreditation, or
it could have lost accreditation. However, the category most notably includes diploma mills, which sell counterfeit academic
degrees for a fee. Unless they are confirmed by a reliable education verification process, these counterfeit degrees easily pass as
legitimate academic credentials making them a viable option in a competitive hiring environment such as India.
Other forms of resume fraud also exist. For example, there are a few thousand companies that provide candidates with counterfeit
employment and experience letters for a small fee. These issues could cause employers to hire less qualified or even unqualified

HIRING EMPLOYEES AND VENDORS IN INDIA 2

candidates over those with legitimate education and experience, which can drive down workforce productivity, while increasing
employee turnover rates and hiring costs.
According to our recently published report, First Advantage India Screening Trends Report (a quarterly analysis of
background screening conducted within India), overall discrepancy rates—the number of times screening results did not
match the information provided by a candidate on the employment application—hovered around 10 percent throughout
2013. This indicates that 10 out of every 100 candidates hired had a discrepancy in one or more background screen
components. Minor discrepancies including the inability to verify data could be as high as 20 percent, and up to 35
to 40 percent in many verticals that have little or no awareness of professional background screening, such as retail,
manufacturing, pharmaceuticals, healthcare and others.

Quick Facts
10 out of every 100 candidates
hired had a discrepancy in one or more background screen components

The report also revealed that discrepancies in employment history are by far the biggest offender across key verification
components including address and education. It’s important to note that while some employment discrepancies—as with all
discrepancies—can include embellishments and even honest mistakes such as slightly off dates or addresses, the discrepancies
can also include completely falsified employment history.

Overall Discrepancy Trends: 2013 Quarterly Comparison

80%

70% Employment
71.5%
69.8%

Address
60% Education
Others
50%

40%

30%

20%
20.6%
20.1%

5.1%

5.0%

4.3%

3.6%

10%

0%
Q1-13 Q2-13

80%

70%

60%
60.2%
56.9%

50%

40%

30%

20%
19.7%

5.5%

19.0%
18.9%

4.5%

15.3%

10%

0%
Q3-13 Q4-13

HIRING EMPLOYEES AND VENDORS IN INDIA 3

FOCUS: Criminal Police Verification Checks

In India, criminal Police Verification Reports are often the main, if not the only, component of a criminal
background check. Ideally, they should help verify if an individual has been involved in any criminal activity
and has pending criminal cases in jurisdictional police offices records. These reports involve checking records at
the Commissioner of Police Office/Superintendent of Police office and the local police station, as applicable,
based on a candidate’s address and local or state regulations. However, there are specific challenges with these
reports that render them less effective, often inaccurate, and potentially non-compliant with a variety of local,
regional, and international regulations and guidelines.

• No central criminal database

Police verification in India is not centralized or driven by a national database. Without digital records, crime
logs are local and not accessible at city, state or national levels. This makes police verification from a local
police station based on the candidate’s address, incomplete, inaccurate and redundant. Understaffed,
overburdened and without a technology-based infrastructure, police stations tend to be disorganized with
manual records and paper piles lacking data security or safety measures.

• Tedious, time-consuming and chaotic process

The formal process of police verification yields a result turnaround ranging from 60 days to a year based
on the location. All police verification requests are filed personally by the candidate through the police
commissioner’s office, and may require the candidate to make multiple visits to complete the check. The
process may differ from one locale to other.

• Global compliance risk

Police verification through a local police station is inconsistent and often acquired through unethical or
corrupt practices. Unfortunately, many local vendors continue to offer and deliver this verification, ignoring
the compliance issues and not alerting employers, who could subsequently be exposed to serious non-
compliance issues. For example, fraudulent information and verification obtained by deceptive means and
corrupt practices are unethical and could lead to lawsuits and legal action falling under the United Kingdom
(U.K.) Bribery Act and the Foreign Corrupt Practices Act.

An individual with a criminal background in one part of city,

state or country could relocate to within India and appear
to have no criminal record on a local police verification.
Pair this stark coverage gap with all of the issues above
and this verification method is highly ineffective and
potentially futile if not performed through a formal
process.

HIRING EMPLOYEES AND VENDORS IN INDIA 4

 Corruption is a problem too
In addition to resume fraud, there are incidents of unscrupulous India Background
background checking practices at the local agency levels. Many Check Market
searches such as criminal police verification are manual and in absence of a
centralized database of nationwide criminal records, the procedures for performing The current background
screening market in India
these localized searches can vary by state, by city or by a local jurisdiction, and
is highly fragmented
they’re often not standardized and compliant with formal processes.
with approximately 18
Bribery and other forms of fraud and corruption thrive under these conditions Empanelled Background
at both public agencies and private firms, as does non-compliance with the U.S. Checker (see sidebar on
Foreign Corrupt Practices Act (FCPA) and other anti-bribery acts. For example, a fake next page) vendors and
50 smaller, inexperienced
police verification racket was recently uncovered in India, in which a local domestic
vendors. Given recent news
screening provider, listed by many customers and official bodies as a reputable and about fraud in the process,
credentialed vendor, was forging the seal and signatures of Indian police officers and the empanelment process
issuing false criminal police verification documents. is under review and being
expanded to better qualify
and rate the screening
Risk to Hiring Organizations providers.
Employers must take care to work with trusted, reliable screening
providers when vetting potential employees and vendors, no matter
where they’re from or where they work—and India is no exception.
Not doing so can damage an organization’s global integrity, credibility and brand
quality, and cause it to hire unqualified or otherwise unfit employees or vendors,
increasing the potential for:

• Physical harm associated with employees that have a history of criminal activity,
violence or harassment

• Financial and proprietary data theft risk from individuals with access to privileged
information

• Reduced productivity due to employees with a lack of skills, expertise, education

and/or training

• Higher Human Resources costs to replace unfit employees

• Legal risk posed by non-compliant hiring and screening processes

• Corporate and personal risk for executives and directors of the organization

HIRING EMPLOYEES AND VENDORS IN INDIA 5

 For Screening Success in India, Work with a
Quality Provider Empanelled
Just as there are specific issues to be aware of when performing employee Background Checkers
screening in India, there are also simple tips and helpful best practices are unique to India
to boost your success. You can acquire this type of valuable in-country expertise by
working with an experienced screening provider. Empanelled Background
Checkers (EBCs) are the
entities empanelled, or listed,
Thoroughly vet potential background screening vendors prior to
by India’s leading IT services
using their services trade group, National
To confidently hire the best talent from this dynamic country while also protecting Association of Software
against serious local, regional and global compliance issues, perform due diligence and Services Companies
(NASSCOM), and National
on all background screening providers you consider using. Here are some initial
Database Management
items to evaluate a potential vendor. Limited (NDML) to render
1. Ensure the vendor understands your local areas. the services of checking the
veracity of the information
• Ask how many offices or locations they have within India. Based on the response, ask registered by Knowledge
how many offices are located within jurisdictions that are most important to you. Professional (KP) with
• Consider choosing vendors based on location to ensure optimal coverage, controls National Skills Registry
and office infrastructure. (NSR). These entities record
the results of the background
• Ask questions about global and local regulations around data privacy, information check on the NSR system.
security and other critical areas of operations.
Source: https://nationalskillsregistry.
• Work with your own selection checklist. com/background-verification.htm

2. Validate business registrations such as certificate of incorporation and service tax

registration.

3. Visit and audit the provider’s facility, processes and technology infrastructure. Check
their financial strength and payment records for their vendors and employees.

4. Test the experience.

• Ask the vendor to offer a trial or pilot period to experience their process, turnaround
time and results. Include a relevant and thorough selection of searches such as address
verification, employment/education verification and criminal background check.

5. Ask for customer references. Follow up with those references and ask specific
questions.

HIRING EMPLOYEES AND VENDORS IN INDIA 6

Global compliance is critical to your success—be sure your screening
vendor is an expert
Yes or No?
Best-in-class employment screening providers understand the complexity of
global screening and work hard to provide employers with a one-world view that A quality background
takes into consideration country specific issues, while providing consistent, reliable screening vendor in India will
program results and support. say “yes” to these questions.
How would your background
Since global background checks—including those from India—involve the collection screening vendor answer?
and transmission of personal information and sensitive data across international
borders, they are subject to data protection laws of many various countries. Quality Work globally?
providers understand these varying requirements and restrictions and can help you yes no
comply with them.
Specialize in the India
market?
You should also ensure that a screening vendor manages this aspect of
yes no
compliance within their vendor network. Ultimately, your organization could be
culpable should any misuse or mishandling of personal information occur within the Show endorsement by the
employment screening supply chain. National Skills Registry as
an Empanelled Background
It is strongly recommended that you consult with in-house or outside legal support
checker?
when developing and managing a global screening program to determine what is legally yes no
allowable and sufficient within India and other jurisdictions in which you operate.
Offer court verification
Technology is also important in India’s competitive hiring market combined with database
searches?
One way to compete for and win the best talent within India is by working with
yes no
a screening provider that leverages new technologies to automate the time-
consuming processes of manually completing applications and other paperwork. Understand global and local
Through applicant tracking systems and online applications, candidates with laws and regulations (FCPA,
Internet access can easily search and apply for jobs online from the convenience of FCRA, etc)
their homes. These technology platforms can include resume upload functionality, yes no
as well as pre-population of employment and background screening applications.
The right provider can scale your program to meet your precise needs, while offering
proactive guidance and automated, centralized solutions that help you quickly, cost-
effectively and accurately screen and hire the best candidates.
Likewise, a quality screening provider should provide you with access to analytics
about your global screening activity, which you can then compare to broader market
trends. You should question areas where performance has dropped compared to
the market, and work with your screening provider to resolve any issues through
updated technology, products or other strategies.

HIRING EMPLOYEES AND VENDORS IN INDIA 7

4 Top Tips for Multinational Companies Hiring in India
Once you find a trusted, experienced background screening vendor, here a few 4 Top Tips
strategies to consider that can further enhance your screening success within India.
1. Screen candidates.
1. Screen all candidates prior to making a job offer. 2. Perform a court
Once you decide on a screening provider, consider authenticating verification and database
search.
these four basic areas of personal information for candidates across all
positions: employment, education, address and criminal history. For executive-level 3. Verify employment
and education.
positions, or positions with access to sensitive information or populations, consult
with your employment screening provider on additional checks that are available 4. Require drug screening.
and recommended. Ask your local human resources contact, and your IT or business
process outsourcing (BPO) business partner—companies such as Infosys, Accenture,
IBM, Comcentrix, Cognizant, HCL, WNS and others—about the nature and process
of criminal checks conducted and their employment screening partners.

2. Consider performing a court verification criminal

check combined with a database search as an
alternative to a Police Investigation Report.
Since all serious offenses and crimes are filed in respective courts, a court verification
check uses law firms and independent lawyers to check the court records, online
or physically, for any judgments and pending cases related to a candidate.
Complementing the court verification check is a database search, which combines
multiple sources including:

•A
 Web/Meta crawler that identifies data on a candidate’s name in the leading
search engines including Google, Bing, Yahoo, AltaVista and Ask;

•A
 world check that covers media searches related to terrorism and financial
fraud; and

•A
 private database search of Manupatra, India’s largest and most
comprehensive online legal and business policy database, which provides an
online court check covering the high courts, supreme court and tribunal courts.
Conducting a court verification check combined with a database search offers
big benefits compared to standard Police Verification Reports, including:
- F ewer requirements, since you only need candidate information, no
documentation
- Faster turnaround time, around 12 days versus 60 days
- Lower cost
- L ess complicated, since it doesn’t require or involve the candidate to visit
the police station
- Improved compliance, since court checks are auditable through the
lawyers and law firms performing the search

HIRING EMPLOYEES AND VENDORS IN INDIA 8

 - E xpanded coverage since cases filed in a court may provide additional details, history and geographic coverage on
a criminal verification as compared with information in police records.
Only approved global screening providers will have access to this combination of resources, so it is important to inquire
about this alternative when considering potential screening providers. It will save time in the background check process and
provide faster, more consistent and reliable results.

3. Always verify employment and education.

Considering the high rate of counterfeit universities in India, 21 operating across the country, and a few
hundred not listed by the UGC, coupled with the fact that discrepancies in employment history are by far the
biggest offender across key verification components in India, you should always validate the employment and education
information stated by an applicant. Although the availability and accessibility of databases for the purposes of employment-
related background checks is extremely limited in the Indian market, resources do exist and employers should use them.

• W
 hen performing education verifications in India, first ensure the University or Education Board is accredited. Start by
visiting the websites of the UCG and the Council of Boards of School Education in India (COBSE), which publish lists of
counterfeit universities and of recognized member boards periodically.

Likewise, inquire about your current or prospective screening provider’s process. Be sure they verify a school’s
accreditation before procuring the education verification. For example, First Advantage verifies school
accreditation, researches and documents any negative articles about the institution and also maintains a list of
non-legitimate, suspect and ceased educational institutions.

• When performing employment verifications in India, be sure the candidate has provided all genuine documents, and
beware of fake or forged documents. Also, instead of calling the numbers provided by candidates, conduct your own
research on the company and find the appropriate verification source and contact that individual instead. In cases
where the employer is a small company, consider performing a site visit to validate the existence of the company.

Below is a list of available resources and strategies to help determine if a company where a candidate has claimed
to work is legitimate.

- C
 heck the Registrar of Companies (RoC) India, an official government agency that falls under Ministry of
Corporate Affairs
- S earch for Indian stock exchange listings under the Bombay Stock Exchange (BSE)/National Stock Exchange
(NSE)
- Search phone directories for company phone numbers
- C
 heck for a company’s Tax Account Number (TAN), a number similar to a U.S. organization’s federal or state
Employment Identification Number (EIN)
- Perform a Web domain and other online media searches
A final note on education and employment verifications within India—consider outsourcing them to a well-vetted, qualified
screening provider. Select providers typically have a system of checks and balances in place to ensure you get the most
reliable, comprehensive and consistent results possible. In addition, quality providers also possess a deep knowledge of
international compliance and can help ensure that you can actually use your verification results in your hiring decisions. A
word of caution, in case you or your services partner chooses to work with local vendors who may offer background services
at a deep discount: be sure to thoroughly check the authenticity of their screening and verification processes.

HIRING EMPLOYEES AND VENDORS IN INDIA 9

 4. Require drug testing to protect your workplace.
Screening all employees for substance abuse helps you better understand the potentially threatening drug habits
of candidates and employees. This drives more informed hiring decisions that can help reduce workplace risk,
minimize tardiness and absenteeism, and improve productivity and performance. Typically you should perform drug tests
using urine or hair samples, and determine which drug-panel works best for your organization, with testing options ranging
from a 5-drug panel, up to a 10-drug panel test.
As for the workflow, drug testing can add time—generally about 10 days—to the onboarding process as international drug
testing can be a highly manual process. However, the costs related to hiring a risky candidate with substance abuse issues
can add up fast and ripple across your organization when you consider the lost productivity, potential workplace harm and
the added cost of re-hiring a new employee to eventually replace the candidate.
Be sure to ask your current or prospective screening provider details about their process, as drug testing is highly regulated
and requires official paperwork and forms, as well as professional, accredited validation of positive tests. Likewise, ask if they
offer any technology tools such as an online ordering platform where you can order tests and access your results to help
simplify, streamline and accelerate the hiring process for your organization, as well as your candidates and employees.

At First Advantage, we’re here to help.

From India to Illinois to Ireland, we offer proven solutions, deep insight and trusted recommendations to help you create a
winning strategy for finding, screening and hiring the best talent around the globe.
With 26 worldwide First Advantage offices, we have roughly 4,500 employees across 12 countries, all of whom speak the
local language and understand the local cultures, norms and sensitivities. We invite you to tap our deep understanding of
local screening requirements, service and fulfillment options, regulations and policies, in addition to our global compliance
expertise around current and emerging data privacy and sovereignty regulations.
Whether you’re looking for a screening provider in India, or you simply have a few questions about how to begin or modify your
global screening strategy, we can help. Contact us at +91 22 4069 7000, +91804252 9400 or email info.india@fadv.com to
schedule a free consultation today.

As the trusted partner of over 45,000 organizations worldwide, we at First Advantage provide
easy-to-understand background screening results so you can confidently make decisions about
prospective employees, vendors and renters. Not only does this safeguard your brand, but you
also arrive at dramatically better background insights – insights you can rely on.

It’s time to partner with First Advantage. Now in 25 locations, 12 countries and conducting over
23 million international background screens annually. Trusted Knowledge. Exceptional People. FADV.com
© First Advantage 2014 FA091914_WP_HiringEmployersandVendors