Pre-employment background checks are generally wellaccepted as part of the hiring process in highly-regulated sectors such as the pharmaceutical industry. But what happens post-hire once a new employee is onboard and welcomed into the company? While many aspects of a pre-employment background check are static, that certainly does not mean that the same employee cannot present a future risk, as the organisation, the staff member and his/her role and, personal circumstances most certainly will evolve and change over time. This is especially imperative, in an industry where patents and other valuable intellectual property-often worth millions-are in jeopardy.
Pre-employment background checks are generally well-accepted as part of the hiring process in highly-regulated sectors such as the pharmaceutical industry. With patents and other valuable intellectual propertyoften worth millions-at risk, the potential of sabotage from activist groups, theft from industry rivals, potential insider threats, and, not to forget, employee access to prescription drugs once onboard, pharmaceutical companies must perform their due diligence before hiring new staff members.
But what happens post-hire once a new employee is onboard and welcomed into the company? While many aspects of a pre-employment background check are static (for example, establishing that the individual’s credentials are indeed valid), that certainly does not mean that the same employee cannot present a future risk, as the organisation, the staff member and his/her role and personal circumstances most certainly will evolve and change over time.
For example, in November, an arrest in Queensland, Australia, involved a pharmacist stealing more than US$20,000 worth of prescription drugs for personal use1. Earlier this year, a doctor in Singapore was jailed for selling 2,300 litres of cough mixture on the black market to drug abusers2. Within Asia, where lesser developed healthcare systems and low-paid doctors have rendered the sector vulnerable to corporate malpractice and bribery, corruption involving healthcare workers and pharmaceutical executives can become rife-as in the case involving a pharmaceutical giant in China3,4.
The APAC Employment Screening Benchmark Report from HireRight in 20175 found that less than three in ten (28 per cent) APAC companies re-screen employees periodically. This remains a major area of exposure to organisations, as an employee’s personal history or external circumstances may have changed in a way that could impact their abilities, certifications, or behaviour in the workplace.
To minimise the risk of criminal activity, substance abuse, or other misconduct-potentially making the company liable for negligent retention or exposing it to other claims-pharmaceutical companies should consider new procedures such as periodic re-screening that take these realities into account. Besides identifying new risks, such post-hire screening programs act as a deterrent and create an audit trail should issues emerge.
Setting the groundwork for continuous screening protocols Background checks encompass a wide variety of areas, and need to be tailored to an organisation’s unique needs as well as the broader regulatory environment. HR departments should carefully consider the areas that require rescreening to make the process simple, yet effective. A biennial criminal background check, for example, helps mitigate risk to an organisation without being too arduous. Randomised drug tests every six months, law permitting, minimise the temptation to divert controlled substances. Ensuring that checks are supported by easy to use, mobile-enabled technology will drive a positive user experience and reduces the impression of imposing onerous requirements on staff.
Pharmaceutical companies may also want to consider what drugs employees have access to, and tailor screenings accordingly with expanded drug panels, or additional saliva, hair strand and blood tests.
Furthermore, organisations should consider re-screening employees who have been promoted or moved into a new role that is more senior or carries with it new responsibilities, expectations and access – a gap identified by the same Employment Screening report.
In the US, a high-profile case involving the illegal sharing of trade secrets and business information (source)6 between two romanticallyinvolved top executives from rival companies, resulted in the leak of around 900 confidential company files from one firm to the other. In the case of the executive who leaked the documents, it was found that she had been hired in 2012, and rose up the ranks to become the company’s senior director of regulatory affairs between 2014 and 2016, when she allegedly committed the illegal disclosure.7
New roles naturally equate to new responsibilities, possibly different access, and with that, a change in risk profile. The initial screening performed pre-hire might not have been tailored to the new role or to the changed circumstances. It is therefore essential that companies, as a matter of course, tailor and apply different checks to different roles, and seek to mitigate risk by performing the relevant checks as employees move within and across the organisation.
Indeed, a significant challenge in implementing continuous screening practices lies in maintaining employee morale and company culture, and to avoid giving the wrong impression to loyal staff. It needs to be made clear from the outset that this is not a monitoring program developed to dismiss people without a word of warning. Instead, the company is looking to protect the safety of its patients and employees, preserve its reputation, and build upon already high standards of professionalism.
With that in mind, it is important to make any changes in company policy-and the consequences of such -transparent and well understood. In most APAC markets, conducting drug and alcohol tests for example requires prior informed consent from the employee-what happens then if the employee refuses to comply? Equally, if something were to be uncovered during a screening - such as a positive drugs test -what action would be taken? Would that employee be immediately dismissed Strateg y or would they be given a second chance? Would they be offered any support or counselling? There can be little room for ambiguity, particularly when it comes to existing staff who may be reluctant to embrace new protocols.
Finally, companies should keep in mind how continuous screening fits into the bigger picture of promoting a culture of safety and integrity-it is a part of the solution, and needs to be complemented by other initiatives. These could include health assessments, training to enable coworkers to identify warning signs, and enhanced processes to share information and data. Regardless, all these elements must come together to form one united strategy, aimed at equally protecting the organisation and its employees.
References:
1 https://ajp.com.au/news/legal/pharmacist-steals-20000-worth-drugs/
2 http://www.straitstimes.com/singapore/courts-crime/doctor-gets-jail-and-fine-for-selling-2300-litres-ofcough-mixture-to-drug
3 https://www.reuters.com/article/us-gsk-china/gsk-case-a-warning-to-all-foreign-firms-in-china-xinhuaidUSBREA4F01P20140516
4 https://www.economist.com/blogs/analects/2014/07/corporate-corruption-china
5 https://www.hireright.com/apac/resources/view/2017-apac-employment-screening-benchmark-report/
6 http://www.philly.com/philly/business/sex-drugs-andsharing-trade-secrets-20170712.html
7 http://www.philly.com/philly/business/sex-drugs-andsharing-trade-secrets-20170712.html
Mary O’Loughlin is the Vice President and Managing Director of Healthcare and Life Sciences of HireRight, responsible for the strategic growth of the healthcare industry within the organisation, while managing the cross-functional team responsible for the overall service of HireRight's healthcare customers.
