Consumer Dispute Process – Agent SOP & Checklist

Department: Operations / Compliance
System: Freshdesk (FD)
Purpose: Ensure every consumer dispute is properly documented, investigated, and resolved within the required timeframe.

1. What is a dispute?

A dispute occurs when an applicant challenges the accuracy or completeness of information reported on their background check.

Examples:

• Criminal record does not belong to the applicant.

• Incorrect criminal charges or case disposition.

• Incorrect crime type

• Incorrect MVR information.

• Incorrect personal information.

• A record that should not appear on the report.

• Incorrect or incomplete information provided by a third-party vendor.

IMPORTANT: A request to explain a record, provide mitigating circumstances, or reconsider an employment decision is not automatically a dispute.

2. Agent Checklist

STEP 1 – Receive and Identify

• Review the applicant's request.
• Confirm whether the applicant is disputing the accuracy or completeness of the report.

• Locate the applicant in Turn Admin (TA).

• Identify the Turn ID, partner, and disputed check.

• Verify the applicant's identity before disclosing personal information.

• Immediately acknowledge receipt of the dispute.

• Record the date the dispute was received.

Do not wait for supporting documents to acknowledge or register a dispute.

Do not wait for the applicant to identify the specific information being disputed. If the applicant does not respond, all adverse information in the report must be reinvestigated.

STEP 2 – Document the Dispute

• Create or update the Freshdesk ticket.

• Record the dispute in the Compliance Dispute tracking sheet.

• Document exactly what the applicant is disputing.

• Download a copy of the applicant's background check report before initiating the dispute and attach it to the Freshdesk ticket.

• Download a copy of the background check report from the Partner Dashboard before initiating the dispute and attach it to the Freshdesk ticket.

• Attach any supporting documentation received.

• Identify the source/vendor responsible for the disputed information.

• Immediately send a dispute notification email to the original vendor that provided the report, requesting a reinvestigation.

• Immediately request the disputed information from an alternative vendor (Sunshine) for independent verification.

• Document both vendor requests and attach the communications to the Freshdesk ticket.

Do not wait for the applicant to identify the specific information being disputed. If the applicant does not respond, all adverse information in the report must be reinvestigated.

IMPORTANT: Both versions of the original report must be saved and attached to the Freshdesk ticket before any changes are made. Vendor requests must be initiated immediately, without waiting for additional information or supporting documentation from the applicant.

STEP 3 – Start the Investigation

1. Confirm that the original vendor has received the dispute notification and initiated the reinvestigation.

2. Confirm that the independent verification request has been submitted to Sunshine.

3. Review the original background check report and identify all information requiring reinvestigation.

4. Review any supporting documentation provided by the applicant.

5. Ensure that all disputed information is included in the reinvestigation.

6. Document all investigation actions and vendor communications in the Freshdesk ticket including dates.

7. Monitor the investigation deadline and escalate any delays to Compliance leadership.

8. Conduct an independent court records search using the official court website. Verify the case details, charges, disposition, and any other relevant information against the original report.

9. Document the findings and attach any available court records or screenshots to the Freshdesk ticket.

IMPORTANT:
• The reinvestigation must begin immediately, without waiting for additional documentation from the applicant.

• The investigation must generally be completed within 30 calendar days, with an extension to 45 days only when legally permitted.

STEP 4 – Review the Results

1. Review the reinvestigation findings provided by the original vendor.

2. Review the independent verification results provided by Sunshine.

3. Compare both vendors' findings against the original background check report and the official court website findings.

4. Identify any discrepancies, inaccuracies, or incomplete information.

5. Determine whether the disputed information is accurate, inaccurate, incomplete, or unverifiable.

6. Escalate any conflicting findings or unresolved discrepancies to Compliance leadership.

7. Correct or remove inaccurate, incomplete, or unverifiable information as required.

8. Update the applicant's background check report and the Partner Dashboard, when applicable.

9. Attach all reinvestigation results, court records, and supporting documentation to the Freshdesk ticket.

IMPORTANT: 
- Do not rely solely on the original vendor's response. The original vendor's findings, Sunshine's independent verification, and the official court website findings must be reviewed before making the final determination.

- If either vendor has not responded and the legal deadline is approaching, escalate immediately to Compliance leadership.

STEP 5 – Notify and Close

1. Communicate the reinvestigation results to the applicant within the applicable legal timeframe.

2. Provide the updated background check report when applicable.

3. Notify the partner and any other required parties of the reinvestigation results, as applicable.

4. Confirm that any required corrections are reflected in the applicant's report and Partner Dashboard.

5. Document the final determination and all notifications in Freshdesk.

6. Update the Compliance Dispute tracking sheet with the final resolution.

7. Confirm that all investigation documents, vendor responses, court records, and communications are attached to the Freshdesk ticket.

8. Close the ticket only after all required reinvestigation, documentation, and notification steps have been completed.

IMPORTANT: Do not close a dispute while required reinvestigation steps, report corrections, or notifications remain outstanding.

3. Important Rules – READ BEFORE CLOSING

DO:

• Treat every dispute as time-sensitive.

• Start the reinvestigation immediately.

• Save both original report versions before any changes.

• Notify the original vendor and request independent verification from Sunshine immediately.

• Conduct an independent search on the official court website for criminal record disputes.

• Document all communications, court searches, and investigation steps.

• Consider all relevant information submitted by the applicant.

• Reinvestigate all adverse information if the applicant does not specify what is being disputed and does not respond.

• Compare the original vendor's findings, Sunshine's results, and official court records.

• Follow up with vendors when necessary.

• Escalate potential reporting errors, conflicting findings, and vendor delays.

• Keep the applicant informed as appropriate.

DO NOT:

• Wait for the applicant to provide supporting documents before starting the reinvestigation.

• Reject a dispute simply because the applicant has no supporting documents.

• Tell an applicant to contact the court or vendor instead of initiating Turn's reinvestigation.

• Promise that disputed information will be removed.

• Change a report without appropriate verification.

• Rely exclusively on the original vendor without following the required independent verification process.

• Skip the official court website search for criminal record disputes.

• Close a dispute simply because a vendor has not responded.

• Tell an applicant that Turn makes hiring decisions.

• Charge the applicant for a dispute reinvestigation.

4. Quick Reference

5. Freshdesk Internal Note Template

DISPUTE CASE

1. Applicant / Turn ID:
2. Partner:
3. Date received:
4. Disputed check:
5. Reason for dispute:
6. Identity verified: Yes / No
7. Supporting documents: Yes / No
8. Original applicant report attached: Yes / No
9. Original Partner Dashboard report attached: Yes / No
10. Original vendor:
11. Vendor notified on:
12. Sunshine verification requested on:
13. Official court website searched:
14. Court search findings:
15. Investigation deadline:
16. Original vendor findings:
17. Sunshine findings:
18. Final reinvestigation determination:
19. Report correction required: Yes / No
20. Applicant notified on:
21. Partner notified (if applicable):
22. Final resolution:
23. Compliance reviewer:
24. Final Checklist

• • Investigation completed

  • Results documented

  • Report updated (if applicable)

  • Required notifications sent

  • Dispute tracker updated

  • Ticket ready for closure

REMINDER: Turn investigates the accuracy and completeness of consumer reports. The employer/partner is responsible for employment decisions. Agents must never promise hiring outcomes or make employment decisions on behalf of a partner.

Final Verification

1. Original reports attached.

2. Original vendor reinvestigation completed.

3. Sunshine verification reviewed or outstanding verification escalated.

4. Official court website search completed and documented for criminal record disputes.

5. All reinvestigation findings compared and documented.

6. Report updated, if applicable.

7. Required notifications sent.

8. Dispute tracker updated.

9. Ticket ready for closure.