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What procedures does the FCRA require with respect to sexual harassment investigations performed by outside investigators?

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What procedures does the FCRA require with respect to sexual harassment investigations performed by outside investigators?

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According to the FTC’s opinion letter (Vail, 4/5/99), the FCRA requires in this context that an employer do the following: a) At any time “before the report is procured or caused to be procured,” the employer must provide a separate, written disclosure to the investigated employee that a “consumer report” may be requested for employment purposes and obtain written authorization from the investigated employee to obtain the report; b) Within three days after first requesting the investigation, the employer must mail or otherwise deliver to the investigated employee a special disclosure that an “investigative consumer report,” which must be clearly defined as set forth in the Act, may be made; that the employee may request additional information about the nature and scope of the investigation; and that the employee may request a summary of rights under the FCRA; c) If the employee requests additional information about the nature and scope of the investigation and/or a summary of rights th

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