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Service Description I-9 Management

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Service Description

I-9 Management

Revised October 2, 2008

This document is a service description outlining the major components and features of the TALX I-9 management service and is confidential to TALX Corporation. This document or any part thereof may not be reproduced or transmitted in any form by any means for any purpose without the written permission of TALX Corporation.

TALX, the TALX logo, The Work Number, and The Work Number logo are registered trademarks, and I-9 eXpress and the I-9 eXpress logo are service marks of TALX Corporation. The information contained herein is subject to change without notice.

Copyright © 2008 TALX Corporation. All rights reserved.

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Table of Contents

MISSION STATEMENT ............................................................................................................................ 4

OVERVIEW ................................................................................................................................................. 4

FEATURES .................................................................................................................................................. 5

WEB SITES ....................................................................................................................................................... 6 Employee (Captcha) Site ...................................................................................................................... 6 Employer Site ....................................................................................................................................... 6

COMPLETION ..................................................................................................................................................... 7 RETRIEVAL ....................................................................................................................................................... 8 CONVERSION ..................................................................................................................................................... 9 NOTIFICATION ................................................................................................................................................... 9 REPORTS ........................................................................................................................................................ 10

ADVANTAGES ......................................................................................................................................... 11

SECURITY ................................................................................................................................................. 12

INDEPENDENT AUDITS ...................................................................................................................................... 12 EMPLOYER CODE ............................................................................................................................................. 12 EMPLOYEE ID ................................................................................................................................................. 12 PASSWORD ...................................................................................................................................................... 12

Default Password Scheme .................................................................................................................. 12 Password Management ...................................................................................................................... 13 Call Center Support ........................................................................................................................... 13

SINGLE SIGN-ON ............................................................................................................................................. 13 PORTAL INTEGRATION ...................................................................................................................................... 13 SECURITY AUDITS ........................................................................................................................................... 13

CONTACT US ........................................................................................................................................... 14

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“ ”“TALX is listening to our clients and expanding our suite of solutions by offering new value-added services such as I-9 eXpress, fulfilling our mission of using automation to replace paper processes for HR and payroll professionals.”– William W. Canfield, President, TALX Corporation

Mission Statement

With the electronic I-9 management service, TALX is committed to:

Helping employers maintain compliance with federal and state immigration laws

Provide employers with opportunities to minimize or eliminate liability

Giving employers a paperless way to complete, maintain, retrieve, and report on I-9s

Protecting the data of our clients and their employees

Enabling quick, accurate, and secure completion of electronic I-9s

Providing complementary services for electronic pay stubs, W-2s, electronic time reporting, employee assessments, onboarding, and automated employment verification that allow employers to deliver end-to-end paperless employment processes

TALX Paperless Services

Automated employee notifications via phone

Electronic time entry

Electronic pay stubs, direct deposit, and W-4s

Electronic onboarding

Compliance service for electronic I-9s

Automated verifications for employment,income, social services, and other purposes

Electronic original W-2s, reprints, andcorrections

Electronic employee tests and assessments

Overview

Federal Immigration Laws make it mandatory for employers to verify the employment eligibility of all employees hired after November 6, 1986. This requirement is fulfilled through the

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completion and storage of an I-9 Employment Eligibility Verification form. Completed I-9 forms must be maintained by the employer for three years after the date of hire or one year after employment ends, whichever is later. An individual may not begin employment unless the I-9 form is completed. Failure to comply with the Immigration Reform and Control Act of 1986 as amended will subject employers to civil or criminal penalties including fines.

On October 30, 2004, the president signed public law 108-390, formerly H.R. 4306. This legislation went into effect April 29, 2005. The U.S. Department of Homeland Security (DHS), Immigration and Customs Enforcement (ICE) published the rule governing electronic I-9s on June 15, 2006 in the federal register. This interim rule is effective until a final rule is issued. Rules are not retroactive and take effect on a go-forward basis when published in the federal register.

The law allows I-9s to be completed with electronic signatures and stored electronically. As a result, the I-9 can now be paperless with the TALX I-9 management service.

Employer responsibilities:

Examine work authorization documents presented by the employee

Complete, sign, and date an I-9 for each covered employee

Utilize E-Verify to confirm employment eligibility and comply with state and federal mandates

Retain all completed I-9s per statutory data retention requirements

Reverify an expiring work authorization and update the I-9 prior to expiration

Produce I-9s for audits and inspections

The service helps employers maintain compliance and minimize or eliminate liability. The service also allows employers to eliminate paper and associated manual processes. The complete service includes:

• Securely complete accurate I-9s online with electronic signatures

• Verify work authorization for eligible employees with E-Verify

• Convert new and existing paper I-9s to electronic format (optional conversion service)

• Maintain I-9s electronically eliminating physical storage of paper I-9s

• Leverage The Work Number data to measure compliance, identify missing I-9s, and remove old I-9s for terminated employees after data retention is satisfied

• Retrieve, view, and print I-9s online

• Notification of expiring work authorization via e-mail and online reports

• Reports available online to authorized administrators

• Print copies of I-9s for internal and external audits and inspections

• Remote I-9s completed online at participating partner offices

FeaturesThe following is an overview of the features of the I-9 service. These features allow you to complete new I-9s electronically and convert new and existing paper I-9s to electronic format.

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“ ”“I-9 eXpress is a service requested by our Client Advisory Board and supported by the acquisition of the Sheakley I-9 Administrator service. Today, over 150 clients subscribe to the service.”– David C. Fowler, Senior Director of Product Strategy, TALX Corporation

During the implementation process, your TALX implementation team works with you to configure the service to meet your needs. The implementation process begins with the completion of a Configuration Checklist detailing your service options and an implementation schedule.

The I-9 management service was developed to take advantage of new federal immigration law and programs, allow employers to leverage the data they already provide to The Work Number, and respond to the needs expressed by the TALX Client Advisory Board and other clients.

Web Sites

The I-9 service provides two Web sites that can be used to configure the service to meet your needs. The Employee Site allows new hires to complete Section 1 of their I-9 on or before their first day of work. The Employer Site allows your authorized users to complete I-9s and perform administrative functions.

Employee (Captcha) Site

This site is designed to satisfy the requirement to have at least Section 1 of the I-9 completed by the employee’s first day of work. Section 2 of the I-9 must be completed within three days (72 hours). Utilizing this site allows the service to track the three day requirement. It also helps you make sure you complete I-9s in a timely fashion and in compliance with the law. After the employee completes Section 1, the I-9 is stored as a pending I-9 until the employee presents their documentation for you to complete Section 2. The employee can print and retain a list of acceptable documents relating to the employee for reference and as a reminder to present their documentation to their employer.

Employer Site

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This site is available to your authorized administrators to complete pending I-9s, new I-9s, reverify work authorization prior to document expiration, retrieve existing I-9s, access reports, and perform administrative functions. The menu options presented to the user are determined by the user’s role assignment. This allows you to determine who has access to the service as well as which features a user is authorized to utilize. If you use the optional location feature, you can limit a user to creating and accessing I-9s in a single location, multiple locations, or allow them to access all I-9s in all locations. The location feature also allows you to create groups of locations and assign access by group. This is very helpful in managing territories with multiple locations. In addition, you can assign access to a combination of groups and individual locations. The role settings can also be used to control access to other features such as the administration functions.

The Quick Search box on the main menu page provides real-time statistics about the important types of I-9s. You can drill down into the details by clicking on the links provided. This allows you to see the individual I-9s of each type as well as which I-9s require immediate action for you to maintain compliance. Other features of the Employer Site are detailed below.

Completion

Your authorized users can complete I-9s online. To access the application, the user logs in. The user’s login is the same one they use to access other TALX services. This single sign-on capability eliminates the need for users to remember multiple logins. If the user is authorized, they are allowed to access the Employer Site.

Electronic I-9s provide several compliance benefits such as:

• Built-in editing features to detect input errors help ensure I-9s are completed correctly

• I-9s cannot be completed until all errors are corrected and all required fields entered

• Signing I-9s with electronic signatures• Monitoring expiration dates with notices

for timely reverification of work authorization

• Verifying work authorization via E-Verify can eliminate liability and help employers comply with state and federal mandates

Once the I-9 passes the edits, it is ready to be reviewed and signed with electronic signatures.

The service includes the optional capability to automatically verify work authorization for all new hires with E-Verify. E-Verify, operated by the verification division of the U.S. Department of Homeland Security, U.S. Citizenship and Immigration Services (USCIS), confirms an eligible employee’s work authorization by comparing the information on their I-9 with databases at the

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Social Security Administration (SSA) and DHS. E-Verify returns a status as well as a case number. This process provides several benefits such as:

• Eliminating SSN mismatch letters from the SSA• Crediting withholding to the proper retirement account• Removing the guesswork when reviewing employee documents• Reducing identity theft• Protecting the country and the employer by only hiring authorized workers• Eliminating or minimizing employer liability for compliance with immigration law

While E-Verify is a voluntary program at the federal level, there are now state laws and a Presidential Executive Order that mandate employers participate in the program. E-Verify can minimize or eliminate employer liability, especially those involved in key national security industries such as technology, energy, communications, and transportation. If E-Verify returns a status indicating that an employee is work authorized when the employee is not actually authorized to work, your liability for the employee is eliminated because you verified the employee’s work authorization through E-Verify. If the status indicates the employee is not work authorized, the service helps you refer the employee to the appropriate federal government agency to resolve the issue.

The I-9 regulations allow you to optionally make copies of the employee’s documents and store them with the I-9. This option is not recommended for the reasons listed below. Moving to electronic I-9s provides the employer an opportunity to reevaluate and possibly change the practice of retaining copies of employee documents.

• Copies are not required for I-9 compliance• It can be considered discriminatory if documents are not copied for every employee• Copying documents introduces paper and manual processes into an electronic process• Copies can prove that you knew or should have known documents were fraudulent• Copying documents can increase the risk of identity theft

The preferred solution is to use E-Verify to verify the work authorization of new hires instead of retaining copies of employee documents. With E-Verify, you get all the benefits of a totally paperless electronic solution as well as the assurance from the government that the employee is authorized to work in the United States. In addition, you are released from liability if an authorized employee is later determined to not be authorized to work in the United States.

Retrieval

An authorized user can retrieve I-9s using the online application. This allows a user to view and print an I-9 for review, audit, or reverification purposes. I-9s are stored in Adobe’s PDF and TIFF formats so printed copies are legible, readable, and look like the original.

A user can search for a specific I-9 or obtain a listing. The search feature has several user configurations. A user can have access to the complete search feature or the user can be prevented from using the feature at all. A user can be allowed to use the search feature in a limited way such as only looking for employees who need to be reverified. With the optional location feature, user access can be limited to authorized locations. A user with proper authorization can access all locations as well as target a search to a specific location. Users can

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also export search results in a format compatible with Microsoft Excel or other similar products. This way you can manipulate the information to create your own reports.

Conversion

The service provides several options for converting your new and existing paper I-9s to electronic format. Your best opportunity to standardize, eliminate paper, and achieve 100% compliance is to convert existing paper I-9s to electronic format. With all your I-9s retained electronically, your compliance reports, which are only available to a client of The Work Number, cover your entire organization and include every eligible employee. As a client of The Work Number employment verification service, you will be able to see if you are missing an I-9 for any of your current employees. Your reverification notices and reports will include every eligible non-citizen employee in the automated reverification process. This will allow you to eliminate the costs of manually monitoring work authorization expiration dates and utilize a standard the process across your entire organization.

The conversion process involves entering the indexing information on the I-9, scanning the signed document, and then attaching it to the indexing information. The electronic I-9s are stored in Adobe’s PDF or TIFF formats so printed copies are legible, readable, and look like the original. The service provides conversion services allowing you to send your paper I-9s to the TALX conversion facility where they are indexed, scanned, and entered into the service.

Once your paper I-9s are converted to electronic format they can be returned to you or securely shredded to avoid the storage and maintenance costs associated with manually managing paper documents. In addition to providing a complete compliance and reverification service, converting your paper I-9s to electronic format also eliminates the cost, maintenance, and risk of storing paper. Plus, electronic documents are not susceptible to damage and loss due to fire, water, heat, humidity, and other factors that adversely affect paper documents.

If you have already converted your paper I-9s to electronic format, TALX can bulk load them into the I-9 service. This option requires the electronic images to be supplied as PDF or TIFF images along with the associated indexing information in the standard TALX format.

Notification

One of the most difficult problems you may face with I-9 compliance is timely reverification of an employee’s work authorization. If an employee’s work authorization is expiring, the law requires you to examine the employee’s documentation proving they are still authorized to work in the United States. You must record the document title, document number, and any expiration date in Section 2 of the I-9, and sign the form. The expiration date is captured when the I-9 is completed online or a paper I-9s is converted to electronic storage.

There are two ways you can be notified to reverify an employee’s authorization to work.• Electronic notifications are automatically sent to designated e-mail addresses when an

employee’s work authorization is expiring• An authorized user can see a list of I-9s online that are due for reverification

E-mail notifications can be sent to up to five corporate e-mail addresses and to the employee’s current location, when an employee’s work authorization is expiring. Your reverification window allows sufficient time for you to reverify the employee’s work authorization prior to the expiration date. The window can be any number of days from 30 to 400. You will determine this and other configuration settings during the implementation process. The USCIS recommends you use a window of at least 90 days to allow enough time for an employee’s application to be

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processed. When an employee’s work authorization is expiring and they enter your window, the first e-mail notice is sent. E-mails can also be sent at other notification points.

A list of I-9s with reverifications due can be accessed online by an authorized user. The Quick Search box on the main menu screen gives you a snap-shot view of the number of I-9s within your window. You can then drill down to see the list of I-9s with reverifications due as well as which ones are closest to the expiration date. Like all search results, the results of the reverification Quick Search can be exported to Excel and serve as a work list of reverifications that need to be completed. To maintain compliance, you may start with those I-9s closest to their expiration date and work backward.

Reports

Reports can be obtained by request or through the search feature. The reports are used to monitor compliance with I-9 regulations as well as to monitor activity.

To help ensure compliance, the I-9s are matched against the universe of covered employees in The Work Number. This unique feature is only available to clients of The Work Number. In case the existing paper I-9s have not yet been converted to electronic format, you can specify a compliance start date or go-forward date. Using this date, the compliance report will only report on those employees hired on or after the go-forward date. Your employees with existing paper I-9s will be considered compliant based on your current processes.

Reports obtained by request include:• Data export for completed electronic I-9s on file• Compliance Report – compliance scores for corporate and

locations• Missing Payroll – identifies I-9s on file without a

matching payroll record in The Work Number• Missing I-9 – identifies eligible employees with a payroll

record in The Work Number and no matching I-9 on file• I-9 Statistics – listing of I-9 transactions within the date

range entered

Reports obtained through the search feature in Excel format include:

• Reverification – employees with expiring work authorization documents• E-Verify Issues – employees not yet verified and cases that require employer action• Pending – Section 1 was completed, but Section 2 is not completed• SSN Applied For – employees who have applied for a SSN• Missing I-9 – identifies eligible employees with a payroll record in The Work Number

and no matching I-9 on file

Reports are available to users with appropriate roles. To request a report, the user selects the desired report and enters parameters such as start and stop dates. When the report is completed, an e-mail is sent to the user indicating the report is ready to be picked up. The reports are generated based on the user’s role. If you use the location feature, a user will only receive reports that contain information for their authorized location or locations. A user with access to all locations will receive reports containing information from all locations.

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Advantages

• Compliance with I-9 Regulations• Built-in edits and validations ensure I-9s are completed correctly• Validate employee work authorization with the federal government• Verify that all covered employees have an I-9 on file• Identify missing I-9s with The Work Number• Easily access I-9s online in the event of an audit or inspection• Reverification notices to make sure employees are authorized to work• Updates made automatically to the application when regulations change

• Eliminate Liability• Minimize or eliminate liability by verifying employment authorization with E-Verify• Demonstrate the good faith provision in the law• Complete missing I-9s to maintain 100% compliance• Removing old I-9s for terminated employees eliminates any potential liability• Respond quickly to audits

• Reduce Costs• Eliminate the storage and maintenance of paper I-9s• Reallocate staff responsible for the manual maintenance of paper I-9s• Avoid development and maintenance costs of custom in-house systems• Remove the risk that paper I-9s will be damaged or destroyed• Minimize the risk of civil or criminal penalties and fines

• Leverage The Work Number• Measure corporate and location compliance levels• Identify missing I-9s• Remove old I-9s for terminated employees that satisfy data retention requirements• Single sign-on uses the same login for TALX services

• Maintain Control• Consistent process to complete and retrieve I-9s• Data security is greatly improved utilizing electronic storage versus paper• Compliance and reverification reports

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Web access

SecurityThe security of employee information is a primary concern of TALX and the I-9 service. For your protection, all access to data requires the user to be authenticated. The service will not release information unless the user has been successfully authenticated. This protects your information by ensuring that it is only released to authorized users for the intended purpose.

Independent Audits

TALX recognizes that we incur vital obligations when you entrust your data to us. To protect client data, TALX is committed to secure and reliable service operations. To provide the best security measures, TALX enlists the services of third party auditors to provide a regular Statement on Auditing Standards 70 (SAS 70 Type II) reporting.

Employer Code

You are assigned a five-digit Employer Code. This code along with a valid employee ID and password is required to access the service.

The Employer Code is assigned by TALX and listed on the sites along with your employer name. The Employer Code identifies any special processing requirements such as co-branding, custom login processes, and password change options.

A simple search function is available on the sites for your users to easily find your (company, division, subsidiary) name and click on it to move through the login process. Using this feature, users do not need to memorize the Employer Code.

Employee ID

The employee ID can be the employee’s SSN, e-mail address, or some other unique identifier. You may use a badge number or other identifying number in place of the SSN. If you choose to use something other than SSN for the employee ID, then each employee’s SSN is provided as an additional field in the data file. If you subscribe to The Work Number or other TALX service, the employee ID must be the same for all services.

Password

There are many options available for assigning passwords. Your client relationship manager (CRM) will work with you to determine the one that best fits your organization. If not done properly, issuing passwords can create real problems. We have experience with many password schemes and we know what works. For example, passwords should be numeric since they may be used with the telephone as well as the Web. There are two process components for managing passwords. First, a default password scheme is used to assign an initial password to each user. Second, the user is given the ability to select a custom password by changing their default password to a value they can easily remember.

Default Password Scheme

There are two basic purposes for using a default password scheme.• The process of notifying users of their initial password is simplified.• Should a user lose or forget their password, the user or a client service representative can

reset the password to the default value allowing the user to regain access to the service without revealing their password.

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The most common default password scheme is the user’s eight-digit birthday. Another example is using the last four digits of the SSN and their four-digit month and day of birth.

6789 (last four digits of SSN – 123-45-6789)+ 0130 (four-digit month and day of birth – January 30, 1971)

67890130 (default Password)

Password Management

Once the employee has logged in to the service, they may create a custom password by changing their default password to something more meaningful to them. You can require users to change their default password when they first access the service. You can also prevent users from changing their passwords. This is typically done if you assign specific non-default passwords to your employees.

Call Center Support

Our client service representatives are available Monday through Friday between the hours of 7:00 a.m. and 8:00 p.m., Central time, except holidays. If a user forgets or loses their password, they can reset it online or contact the call center to have it reset to the default. If there appears to be an error in the data, TALX will contact you to verify the error and make the appropriate corrections.

Single Sign-on

TALX has implemented a single sign-on capability so your employees are only required to login one time to access the The Work Number, and other services offered by TALX.

Portal Integration

TALX offers this optional feature for clients and partners to remotely authenticate users and then send the user to the I-9 service. The user is automatically logged on the I-9 service and returned to the calling portal when the I-9 transactions are completed.

Security Audits

TALX periodically conducts independent audits of our security policy and procedures to ensure that our services are secure and that your employees’ information is safe. We also assist our clients in conducting their own security audits and penetration tests. Contact your CRM if you are interested in scheduling an audit.

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Contact UsFor additional information about TALX, electronic I-9s, and other TALX services that can benefit your organization, please contact us.

TALX Corporation11432 LacklandSt. Louis, MO 63146U.S.A

Telephone: (314) 214-7000 or 800-888-8277

Fax: (314) 214-7588

E-mail: [email protected]

Web: http://www.talx.com

http://www.theworknumber.com

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