www.cooley.com Social Network Checks  Establish policies on when social media checks will be conducted, by whom, at which sites, for what information, and how will that information be evaluated  Include social checks by third-party vendors in your FCRA compliance program  Social checks by the employer's own staff are not subject to FCRA  Careful about: asking/coercing an employee or applicant to provide social media password(s), or fraudulently/coercively gaining access to network  Be careful of taking adverse action against en employee for comments on social media (could be protected by state law or NLRB rules) 20
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