Your Organization Needs Employee Fingerprinting—But Do You Have an ORI?

This article is based on conversations we regularly have with HR managers, operations teams, compliance personnel, and organizational leaders who call to arrange onsite fingerprinting for employees before realizing that the requesting pathway must be established first.

A company calls and says, “We need you to come to our office and fingerprint a group of employees.”

One of the first questions we ask is, “Do you have the Request for Live Scan Service form and the ORI?”

We frequently hear a pause, followed by: “What is an ORI? How do we get one?”

At that moment, the conversation changes. The organization originally thought it was choosing an appointment date. In reality, it first needs to identify who is authorized to request the background checks, where the results are supposed to go, and whether that pathway can be established before its compliance deadline.

Mobile fingerprinting can solve the physical and logistical problem of getting employees fingerprinted. It cannot create the organization’s authority to receive California Department of Justice criminal-history information.

What an ORI Tells the Live Scan System

An ORI is an identifying number associated with an authorized agency or program. On a California Request for Live Scan Service form, it helps identify the agency connected to the background-check request.

For the organization, the ORI is not merely a number to place in a blank box. It is part of a larger authorized pathway that may also include:

• the agency name;
• the type of applicant;
• the working title or position;
• a mail code or billing information, when applicable;
• the level of service authorized for that request; and
• the agency or program permitted to receive the response.

One thing many organizations do not realize is that the mobile fingerprint technician does not decide what background check the organization is legally entitled to request. The technician captures the fingerprints and submits the information provided through the authorized request for live scan form and workflow.

If the requesting information is missing or incorrect, bringing a scanner to the workplace does not solve the underlying problem.

Why Organizations Suddenly Discover They Need Fingerprinting

These calls are usually connected to a larger requirement. An organization may be onboarding employees, renewing an insurance policy, beginning a new contract, responding to an audit, working with a regulated population, or trying to comply with a statute, regulation, licensing rule, client requirement, or internal policy.

For example, an organization may be working with schools that require the organization’s employees to get background checks.

The operational pressure often sounds like this:

• “Our insurer says these employees need background checks.”
• “Our contract begins next month.”
• “We have to show that everyone is cleared before they can enter the facility.”
• “We are hiring a large group and do not want to send everyone to different offices.”
• “We thought we could schedule Live Scan this week, but we do not have a form.”

The requirement may be legitimate and urgent, but the source of the requirement does not automatically determine the correct fingerprint-based background-check route. An insurer or customer may require appropriate screening, for example, while the organization still must determine which legally available screening process satisfies that requirement.

That determination should happen before employees are scheduled.

Begin with the Requirement, Not the Fingerprinting Appointment

From our experience, the most useful first step is to work backward from the reason the organization believes fingerprinting is required.

The organization should identify:

• who imposed the requirement;
• the statute, regulation, license, contract, policy, or program involved;
• which positions must be screened;
• what type of background check is actually required;
• who is supposed to receive or review the results;
• whether an authorized agency already exists in the process; and
• the date by which the requirement must be satisfied.

This prevents a common mistake: planning an efficient fingerprinting event before confirming that the transactions have a valid destination.

Obtaining background checks, or becoming an agency of record, for a company’s employees is no easy task. It’s advised to confirm the precise requirement before taking action.

Another Authorized Agency May Already Own the Request

Not every employer needs its own ORI.

In some situations, a licensing board, government department, contracting agency, school system, care program, or other authorized entity supplies the Request for Live Scan Service form. The organization’s responsibility may simply be to ensure that its employees complete the fingerprinting required by that outside agency or program. TrustLine is one example of this exception when the employees and their positions fall within TrustLine’s eligible childcare, caregiving, supervised-visitation, ancillary-childcare, or child-transportation categories.

If that is the case, the correct form should come from the agency or program requiring the check. Employees should not guess at the ORI, copy information from another person’s form, or use an old form created for a different position.

Before a group event, we want to know whether all applicants are following the same route or whether several forms and applicant types will be present. That affects scheduling, data entry, payment, and the amount of review required onsite.

The Organization May Need Applicant-Agency Authorization

If the organization itself needs to request and receive California DOJ background-check information, it may need to become an authorized applicant agency.

Eligibility is not based simply on how many employees need fingerprinting. California DOJ determines whether applicable law authorizes the organization to receive the criminal-history information requested for its employment, licensing, certification, or other approved purpose.

The authorization process generally requires the organization to explain the basis for its request and provide information through the DOJ’s applicant-agency authorization system. An organization seeking authorization also needs to address who will serve as its Custodian of Records and how sensitive information will be protected.

This is not something the mobile fingerprint technician can approve at the appointment. DOJ makes the authorization decision.

The Timeline Question Should Come Up Immediately

After learning that the organization does not have an ORI or established program, our next question is often: “What does your timeline look like?”

That question matters because the organization may be combining two very different timelines:

1. the time required to establish the correct authorization, program, or requesting pathway; and
2. the time required to fingerprint the employees once the pathway is ready.

A mobile team may be able to organize an onsite appointment relatively quickly. The agency-authorization stage is outside the mobile provider’s control and should not be treated as an appointment-scheduling task.

If a contract, insurance renewal, opening date, hiring class, or audit is approaching, the organization should communicate early with the party imposing the requirement. It may need to confirm exactly what evidence is required and whether the compliance date assumes that the organization already has an authorized background-check program.

The safest planning approach is not to promise that every employee will be cleared by a certain date before confirming the pathway, the form, and the agency responsible for the results.

Where TrustLine May Fit

TrustLine sometimes enters the conversation when the work involves children, caregiving, supervised visitation, ancillary childcare, or certain child transportation services.

TrustLine is a California registry and background-screening program for specified categories of providers who are not always covered by a traditional licensed childcare pathway. Depending on the role, it may include certain:

• nannies and babysitters;
• in-home or license-exempt childcare providers;
• professional supervised-visitation monitors;
• employees working in qualifying ancillary childcare settings;
• subsidized childcare providers; and
• child transportation or transport/escort personnel covered by the applicable program requirements.

TrustLine should not be treated as a general alternative for every company that does not have an ORI. The position and organization must fit the program, and applicants must use the application and fingerprinting instructions associated with that pathway.

For a qualifying organization, however, TrustLine can answer an important question: which authorized program is receiving and managing the background-check process?

An ORI Does Not Mean the Organization Must Own a Live Scan System

Another misconception appears once an organization begins considering its own applicant-agency authorization: “If we receive an ORI, do we have to buy equipment and fingerprint everyone ourselves?”

Those are separate operational decisions.

The organization’s applicant-agency responsibilities concern the authorized purpose, forms, receipt of results, confidentiality, record handling, and related compliance. A professional Live Scan provider performs the fingerprint-capture and submission operation.

An organization can have recurring fingerprinting needs and continue using an outside mobile provider. For many organizations, that avoids the separate responsibility of purchasing equipment, maintaining connectivity, staffing certified fingerprint rollers, training backup personnel, managing equipment problems, and supporting an operation that may be busy during hiring periods but unused at other times.

The ORI determines the authorized agency pathway. It does not require employees to travel to a particular fingerprinting office, and it does not prevent the fingerprinting operation from coming onsite.

Once the Pathway Is Ready, Mobile Planning Can Begin

When the forms and authorized requesting pathway are established, the conversation returns to the practical reason the organization called us: how to fingerprint a group without unnecessarily disrupting operations.

A well-planned large mobile fingerprinting event requires more than selecting a date. We typically discuss:

• the total number of applicants;
• whether everyone uses the same form and applicant type;
• employee shifts and availability;
• one location or multiple worksites;
• building access, loading, parking, power, and connectivity;
• a private and practical location for fingerprint capture;
• who pays the rolling and government fees;
• how applicants will be scheduled;
• how identification and forms will be checked;
• who will serve as the onsite point of contact; and
• how late arrivals, missing forms, and other exceptions will be handled.

One lesson we have learned is that form preparation determines event speed. A technician can move efficiently between applicants when every employee arrives with the correct agency form and acceptable identification. If each person arrives with a different question about why they are being fingerprinted, the event turns into an intake investigation that should have happened earlier.

What the Mobile Technician Can Verify—and What the Organization Must Decide

The mobile technician can review the physical form presented, check identification, enter the supplied information, capture the fingerprints, evaluate fingerprint quality, and submit the transaction through the approved system.

The organization or requesting agency must determine:

• why the background check is required;
• which employees or positions are covered;
• which agency is authorized to receive the results;
• which ORI, applicant type, and working title apply;
• which form should be issued; and
• how the resulting information will be handled.

Keeping those responsibilities separate protects the organization and prevents employees from being fingerprinted under an incorrect or incomplete request.

A Checklist Before Calling to Schedule the Group

Before selecting the date for onsite employee fingerprinting, the organization should be able to answer:

• What requirement is driving the background checks?
• Who imposed that requirement?
• Does another agency or program provide the form?
• Does the organization already have an ORI?
• If not, has it confirmed that it is eligible to seek applicant-agency authorization?
• Could a specialized program such as TrustLine apply to the positions?
• Who will receive and manage the results?
• What is the compliance deadline?
• How many applicants need fingerprinting?
• Will the need continue after the first event?

If the organization can answer the pathway questions, an experienced mobile provider can help turn the remaining work into a practical onsite plan. Anshin Mobile Notary & Livescan coordinates mobile fingerprinting for organizations and groups throughout Los Angeles, including event scheduling, onsite setup, applicant flow, fingerprint capture, and transaction submission.

Frequently Asked Questions

Can a company schedule mobile Live Scan without having its own ORI?

Possibly. Another authorized agency, licensing body, contracting entity, or specialized program such as Trustline may supply the ORI and Request for Live Scan Service form. Before scheduling, determine who is requesting the background check and who is authorized to receive the results.

Can the mobile fingerprint provider give our company an ORI?

No. California DOJ determines whether an organization qualifies to become an authorized applicant agency and assigns the associated agency information. A mobile provider can perform fingerprint capture and submission after the correct pathway and forms are established.

Does needing background checks for many employees automatically qualify us for an ORI?

No. Transaction volume can make an organized program operationally important, but DOJ authorization depends on the legal basis permitting the organization to receive the requested criminal-history information.

Does an insurance or statutory requirement automatically authorize California DOJ background checks?

Not necessarily. An insurer or statute may require appropriate employee screening, but the organization still must determine which legally available screening method satisfies the policy or law, and whether a California DOJ applicant-agency pathway applies.

How long does it take to obtain an ORI?

Timing depends on the organization’s eligibility, the completeness of its authorization materials, the Custodian of Records process, and DOJ review. Organizations should contact DOJ for current instructions and should not schedule a compliance-sensitive fingerprinting event on the assumption that authorization will be immediate.

Can TrustLine be used if our organization does not have an ORI?

TrustLine may provide the applicable pathway for certain childcare, caregiver, supervised-visitation, ancillary-childcare, and child-transportation roles. It is not a general background-check program for every employer, so the organization should confirm that the position qualifies.

If our organization gets an ORI, do we have to buy Live Scan equipment?

No. Applicant-agency authorization and operating a Live Scan fingerprint-capture system are separate functions. An authorized organization can continue using an outside mobile provider to fingerprint employees onsite.

What should employees bring to an onsite mobile Live Scan event?

Employees generally need the correct Request for Live Scan Service form and acceptable, unexpired government-issued photo identification. The organization should distribute the correct form and event instructions in advance so the technician can focus on identification, data entry, fingerprint quality, and submission.

Establish the Pathway Before Choosing the Appointment Date

When an organization needs a group fingerprinted, mobile Live Scan may be the most practical way to reduce travel, coordinate employee schedules, and keep the fingerprinting process from interrupting an entire workday.

But the equipment should not be the starting point.

First identify the requirement. Then identify the authorized agency, ORI, form, and deadline. Once those pieces are in place, the mobile fingerprinting operation can be designed around the organization’s people, location, and schedule.

The first question may be, “How soon can you come to our workplace?” The more important question is, “Where are these fingerprint transactions authorized to go?” Answering that question early is what turns an urgent request into a workable plan.

This article is part of Group and Corporate Fingerprinting, where we cover the logistics that get settled before the first applicant sits down.

Also in this section: What Organizations Are Actually Paying For, How Large Fingerprinting Events Actually Work and How to Prepare for a Successful Event.