Registration of Russian citizens at their place of residence and work will be simplified

According to Russian media since 01^st of January 2011 registration of Russian citizens at their temporary place of residence and work will be simplified. This initiative of the government is intended to limit illegal labor migration (according to public sources about 3 million Russian citizens) and is said to be the first step towards updating of Russian private persons’ registration system.  We will definitely face some serious changes in background screening procedures and raw data mining when this law will be implemented. I’ll keep you informed about recent changes in private persons’ registration system but yet I don’t have enough data to say something for sure.

Database of unreliable former employees of the biggest Russian bank

It took me a month to prepare new article for my blog. Initially I planned to send a long research about management of commercial and trade secrets in Russia, but actually I’ m a little overloaded by due diligence projects and it is hard to find spare time and revise the problem. That’s why I’d like to share new important link that will be helpful for you during background screening of bank and finance management professionals in Russia.

Since August 2010 Russian biggest governmental bank Sberbank started to publish the list of former employees dismissed because internal fraud or theft. Initially the list included also those employees who were caught by internal control department but several legal claims forced Sberbank to exclude fraudsters who weren’t brought to the Court. 

http://www.sbrf.ru/moscow/ru/about/dismiss

The list is in Russian language only and is intended to be regularly updated.

The question of the hour: Can we check educational background of the subject and how this can be done in accordance with Russian legislation?

For several years since mid-90th the problem of educational background check of Russian employees is a terrible headache for professional investigators and background screeners. “What’s up, man, what’s the problem with it?” – that’s what we often hear form our international partners and even local HRs and security managers.

The problem has several sides:
1. Fake Higher education Diplomas are available on the black market and even on the Internet. Average price of the fake Diploma is 500 USD; add another 1200 USD and you can even register it in the list of Diplomas of several private or even State Institutes or Universities.
2. There are a lot of small private Institutes in every region of Russia. Sometimes it is a problem to identify the Institute where the Subject got his Diploma.
3. There is no Federal or even local database of Higher education Diplomas.

How we can manage this situation and get reliable data about Subjects’ educational background?
Step 1 Check University or Institute Diplomas database.
Ask your potential employee to make a copy of his Diploma. This copy will be in need when you apply to the University for Validation. Please pay attention that it is not allowed by most State institutes to validate the number of the document without written permission of the Subject and at least a fax copy of his Diploma. It is strange but some institutes can’t trace back their students Diplomas issued in 70-90th years of XX century.
If the reply will be positive there is 80% probability that the Subject was in fact graduated from this institute.
Step 2 Check social networks accounts of the Subject to identify if there are classmates from the same institute in his friends list.
If results of steps 1 and 2 are positive, the probability that the Subject was in fact graduated from this institute is 90%
Step 3 Get in touch with potential classmates of the Subject (it is better to choose some not from his friends list) and ask them if they had studied with the Subject and did he really graduated from the institute.
If results of steps 1, 2 and 3 are positive, the probability that the Subject was in fact graduated from this institute is 99%.

I often see public offers from Russian PIs that they are ready to check educational background of the Subject in two or three days. I can assure you that results of these investigations can’t be accurate or reliable – there are no legal (and even partially legal) databases of Diplomas of governmental or private higher education institutes of Russian Federation.

How to use SNA during background screening in Russia?

Method of data mining in social networks was widely discussed in LinkedIn Group “ProP.I.” in March 2010. Most questions were about pretexting in social networks and ability to use the data collected in the court. I paid attention, that there are many approaches to problem solving, depending on regional traditions and regulations where PI operates.

That’s why I think it is reasonable to say a few words about the way data collected in social networks can be used in background screening in Russia.
First of all lets’ divide the law and the ethics. According to the law one can use any data collected in public accounts unless he is trying to use this data against the owner of the account. Most PIs I know is working on the edge of the law and it is reasonable to take for granted that reliable expert will find the way to get information he needs in compliance with local regulations.

Taking into consideration the above statement, pretexting in social networks is the matter of ethic, not the law.

There are 2 different situations:
1. PI uses unknown for the subject name and personality asking him “add me as a friend”. Pretty girl in bikini or sales person with “unique opportunity” are good examples of these fake pages. If the subject accepts this offer I see no reason to speak about unethical behavior or offense against the law. The subject made his own decision and thinks that the data on his page can be given to the stranger.
2. PI uses fake page of the subject‘s classmate or relative. Even if this way gives PI the data he needs I think that it is unethical. This practice must be stopped and may be even prosecuted by professional community.
In my practice I met several “subject’s fake accounts” where competitors or detractors of the subject publish compromising materials.

How can we use social networks’ pages as a valid data if we are not even sure that this page actually belongs to the subject of the investigation? – There’s no other way except validating this data through other informational sources or during investigation.

Social networks can give us only preliminary information, nothing else.

What kind of data can be collected during basic pre-employment screening?

First of all you have to take into consideration that in Russia you won’t ever get standard criminal background or credit history report of the employee.

Criminal records: There are no “open for public” databases of criminal records in Russia. Moreover, except for serious (or organized) crime, police has no federal database of crime participators. That’s why if we try to get criminal background records of the employee, the task should be split into 2 different steps:

1. Check if the employee was named in the Federal database as an offender or terrorist (pay attention that this source is also “for authorized use only”)
2. Check local database of criminal records to find if the employee was prosecuted or detained by the police (no chance to get this data unless you have a strong relations with local authorities).

There’s also another way of collecting criminal background information – check illegal databases of organized crime participants and offenders which is available on the black market. This database is not up to date (newest records dated 2002) and doesn’t pretend to be full. I can’t recommend you to rely on this source of information, but if you try to save your time & money, this is the only source you have. Elsewhere you will have to “investigate” and get information directly from police databases.

Credit history: It is a long story which started in 2004, when the Federal Law 213-F3 “About credit history” dated 12.30.2004 was published. According to this Law, several Credit bureaus are to be organized. Banks are welcomed but not obliged to sign agreement with Credit bureaus and disclose information about their debtors. As the result there are databases of Russian citizens credit history, but they are not reliable (if the Subject get financial credit from the bank which is not in the disclosure program, this data will be hardy available). With the permission of the Subject you can get information about his criminal background, but the only legal way to get credit history of the Subject is to take his Power of Attorney.

So, what will we find in the basic background screening report of Russian employee?

National registration data of the Subject (First name, Second name, Fathers name, date of birth, passport number, registered address). Registered address (so called “propiska”) is a kind of legal address. Very often registered address doesn’t mean place of residence.

Tax ID (Individual tax number, INN) – identification of the private person in tax police

Driving license (including expiry date)

Relatives of the Subject – only if they are registered at the same address.

Ownership of vehicles (VIN, registered number, date of registration)

Ownership of premises

Involvement in legal bodies

Criminal background – only Federal database data (see above)

I’ve seen different reports produced by local and international companies but the truth is that this data is the only valid information about the employee that can be collected without investigation.

Pre-employment screening of Russian citizens (1)

I think it is a good idea to start from pre-employment screening of Russian citizens. This task is common and widely used by international companies during start-ups or development of their Russian brunches. I had several dozens projects of top-managers and regular workers background screening for EU companies in Russia and wish to share my experience of cooperation.

LAW: Personal data of Russian citizens is protected by the Federal Law “On the Personal data” #152-FZ dated 07.26.2007. Unless it was published on the Internet or printed media, personal data can’t be collected or analyzed without written permission of the Subject. Debates follow application of this Law since the date of its publication, but main rules are simple:

• “If you wish to make pre-employment screening of your applicant – take a written permission to check his personal data”
• “If you wish to have your employees under control, add the disclaimer to the Labor agreement that personal data of employee can be regular screened by internal audit department or sub-contractor of the company”

That’s all for today. Next post will be about the data and informational sources for pre-employmant screening in Russia.