What is in-employment screening?

In short: In-employment screening is a background check on someone who is already an employee, run because their role has changed, a regulator requires periodic re-screening, or something specific has prompted a review.

When organisations use it

Three main scenarios:

Role change

Someone moves into a regulated function (e.g. promoted into a finance role with signing authority, or moves into a position with access to vulnerable people). The new role triggers checks that were not relevant before.

Periodic re-screening

Some industries require it on a regular cadence:

• Financial services often require annual PEPs and sanctions re-screening
• Healthcare may require periodic VOG renewal
• Aviation requires periodic re-screening for airside access

Post-incident review

After an incident (compliance breach, internal fraud, complaint), organisations sometimes re-screen relevant staff. This is sensitive: it should be done transparently, with the employees’ awareness, and only checks that are proportionate to the incident.

How it works mechanically

Same as a pre-employment screening:

1. You set up the screening in the dashboard
2. The employee receives a secure consent link
3. They consent and provide the required information
4. We run the checks and return the report

The employee always knows they are being screened. They have the same right to refuse as a job applicant, though refusing may have employment consequences depending on what their role requires.

Important: communication matters

In-employment screening is more sensitive than pre-employment because employees may feel singled out or suspected. Best practice:

• Communicate transparently about why screening is happening (regulatory, role change, organisation-wide policy)
• Apply it consistently within a defined group (e.g. all staff in a function, not just one individual)
• Give employees time to ask questions before the screening starts
• Allow private support contact for sensitive questions

Pescheck’s flow lets employees raise concerns with us directly if they prefer not to discuss with their employer.

Legal basis

GDPR requires a legitimate basis for any processing. For in-employment screening:

• Consent is the cleanest basis, but consent in an employment context is sometimes contested
• Legal obligation is solid when a regulator requires it
• Legitimate interest is appropriate when there is a documented organisational need and a balancing test in your records

We can help you document the legal basis for your screening programme. Get in touch if you need a template.