In 2016, background investigations for prospective Discover employees were handled by placement agencies, outsourced, or managed through individual departments. Although this is a common approach among large companies, Discover’s leadership recognized that consolidating the effort under a single team would ensure a more consistent, equitable, and regulatory-compliant process.

Now three years into their fully revamped approach, Tina Gagliano-Mandell, EEO & Affirmative Action Specialist, leads the 7-person team responsible for reviewing every case that involves the justice system. Recognizing preliminary background investigation results are often wrong or incomplete, the team’s first objective is connecting with the applicant to understand the “big picture.”  

“Our conversations with the candidates are intimate. We want to hear their side of the story,” Tina says, “... and we explain at the outset: here’s who we are, this is what we're trying to accomplish. This is not us pushing you out of the process; we want your participation to help you get to the next step.”

While Discover must follow specific provisions of the Federal Department of Insurance Act (FDIA) requirements, there are no automatic criminal disqualifiers. Applicants are not eliminated just because they have a criminal justice history.

“We treat every person who comes through individually — the FBI rap sheet is not always the last step of the process. We look at the actual court records. We may work with police departments, agencies, or the candidate and say, ‘Can you gather this documentation because we want to know what really happened in your case.’”

Ensuring Fair Chances

By engaging individuals who face severe limitations to gaining employment, Discover achieved a fill rate of over 100% for Chatham Customer Service and Engagement (CSE) roles in 2022. In addition, less than 5% of applicants at Discover are screened out solely due to their background, greatly expanding their reach and talent pool.

Tina offers advice for organizations evaluating their background investigation practices: “Get comfortable working in the gray. You can’t be so focused on black and white. Have empathy. Know there are two sides to every story, and what you see on paper is often a tiny snippet of what’s happening in someone’s life – it’s not necessarily a risk to your company to bring them on board.”