Due Diligence and Ongoing Monitoring

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  • 1.  Cleaner contracts

    This message was posted by a user wishing to remain anonymous
    Posted 02-27-2024 12:19 PM
    This message was posted by a user wishing to remain anonymous

    What insurance requirements are generally required from bank facility cleaners?  Is a bond needed?  Any specific requirements on policies for cleaning employees - background check, etc.? 



  • 2.  RE: Cleaner contracts

    Posted 02-27-2024 12:48 PM

    I have never required a Bond form janitorial staff. However Cert of Insurance with verbiage in the contract that the vendor assumes liability for their employees (pretty standard) and background checks. I also suggest looking for venders known for working in data sensitive areas they do seem to have additional controls and more stringent hiring processes but a clean desk enforcement also minimize exposure. 


    Original Message


  • 3.  RE: Cleaner contracts

    Posted 03-05-2024 07:51 AM

    We have several branches that are cleaned by outside companies.  NPI may be accessible so we require 1mm liability and 25k crime bond.  We have no contracts and no background checks being performed. 

    I am trying to put in a process.  Do you do background checks on the owners at inception and once a year or just during the initial process.  Do you require them to do background checks on their employees once or every year?  Do you specify the criteria for the background checks for their employees?  What is included in the contract?  Would you have a template that you could share?  Thank You. 

     

     

    Peter Wald, Third Party Risk Manager

     

     




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  • 4.  RE: Cleaner contracts

    Posted 03-05-2024 08:23 AM

    Hi,

     

    We had this come up in an FDIC audit back in 2012 or 2013.  Due to potential access to NPI we have moved them to a high vendor in the instance someone does not follow the clean desk policy.  We do require the vendor to perform background checks where they supply us with the results upon hire.  We asked for annually as well, but there was push back.  We do have it in place that if anything changes that we are made aware.  For example, we had an instance where one of the cleaning people was arrested for theft over a weekend.  We were notified by the vendor and when he showed up we turned him away.  I still think that the vendor should have told their employee that, but at any rate we did not allow him back in the building.

     

    I do not have a template to share.  They adjusted their version specifically for us.

    Thanks,

     
    Kelli Shoup | Technology Support Lead/Information Security Specialist

    The Farmers Bank




    Original Message


  • 5.  RE: Cleaner contracts

    Posted 03-06-2024 07:48 AM

    Hi Peter- 

    We do require the cleaning staff to only permit staff that has successfully passed a background check to be used. They are required to provide evidence of the check to us as part of our periodic due diligence.  We also have insurance requirements for theft etc. in our contracts but we also enforce a clean desk policy and have our guards periodically walk the floor to ensure that the printers are clear and there aren't laptops or other items of concern out in the open.  I hope that helps! 



    ------------------------------
    Jenn Wilkinson
    Vice President
    Third Party Risk Management
    Cenlar FSB
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    Original Message


  • 6.  RE: Cleaner contracts

    Posted 03-05-2024 08:21 AM

    How do you verify that janitorial companies perform background checks on their employees?

     

    Thanks

     




    Original Message


  • 7.  RE: Cleaner contracts

    Posted 03-05-2024 08:53 AM

    We request a print out from the vendor for each one performed and add it to their file.

     
    Kelli Shoup | Technology Support Lead/Information Security Specialist

    The Farmers Bank




    Original Message