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Free guide · 2026 edition · For nonprofit leaders who screen volunteers

By the Book

A plain-English FCRA playbook for nonprofits that screen volunteers

The disclosure, the authorization, the notices and the waiting period — what courts have punished, and how to screen volunteers the way the law expects.

Cover of By the Book
  • 19 pages, written for nonprofit leaders who screen volunteers
  • The five FCRA steps, in order, with the cases behind them
  • A compliance checklist and a model pre-adverse notice
  • Every statute, case and agency letter cited

Who this guide is for

Executive directors, volunteer managers, HR leads, board members and pastors at any nonprofit that runs background checks — churches, camps, leagues, co-ops, schools, food banks, hospices and everyone in between. If you screen volunteers through a background-check company, the Fair Credit Reporting Act governs how you do it.

$100–$1,000

in statutory damages per person for a willful violation — plus punitive damages and attorney’s fees.

15 U.S.C. §1681n

5 days

is the wait FTC staff called “reasonable” between the two notices. No statute sets a number.

FTC staff letter, 1997

0

extra lines belong on the disclosure form — no waivers, no state notices, no fine print.

15 U.S.C. §1681b(b)(2)(A)

From the executive summary

Six things every nonprofit leader should know about the FCRA

  1. 1

    The FCRA reaches volunteer screening.

    FTC staff read “employment purposes” to include a nonprofit staffed in whole or in part by volunteers.

  2. 2

    The disclosure must stand alone.

    A liability waiver or state notice on the same page has cost organizations in court.

  3. 3

    Get written authorization first.

    One well-worded authorization can cover later re-screening.

  4. 4

    Never say no before the pre-adverse notice.

    Send a copy of the report and the current Summary of Rights, then wait.

  5. 5

    Send a final adverse action notice.

    With the four elements the law requires — in a separate document.

  6. 6

    Decide fairly and consistently.

    Written criteria and an individualized look at each record protect people and your organization.

What's inside

  • 01

    The short version

    The whole case on one page — read it before your next staff or board meeting.

  • 02

    Why the FCRA reaches volunteer screening

    “Employment purposes,” the FTC’s reading, and who’s who in a background check.

  • 03

    Step 1: the standalone disclosure

    What Syed and Gilberg punished, and what to keep off the form.

  • 04

    Step 2: written authorization

    Blanket authorizations for re-screening, state wrinkles and teen volunteers.

  • 05

    Step 3: before you say no — pre-adverse action

    The report copy and the current (2023) Summary of Rights.

  • 06

    Step 4: the waiting period

    Where “five business days” really comes from, and common mistakes.

  • 07

    Step 5: the adverse action notice

    The required elements, in plain English.

  • 08

    Making a fair decision

    Three factors that hold up, and where the EEOC guidance stands in 2026.

  • 09

    State and local add-ons

    California, New York City, New York and Washington.

  • 10

    What a report can — and can’t — include

    The seven-year rule, convictions, and gaps in the records.

  • 11

    What it costs to get it wrong

    Statutory and punitive damages, willfulness and the time to sue.

  • 12

    How VolunteerBadge handles each step

    What the platform carries — and what stays your decision.

  • A

    Appendix A: FCRA compliance checklist

    Audit your process once a year.

  • B

    Appendix B: Model pre-adverse action notice

    A respectful letter to adapt with your counsel.

  • C

    Appendix C: Free tools, further reading and sources

    Letter generator, free FCRA course and every citation.

Get the free guide

Questions

Is the guide really free?
Yes. Sign in with Google or LinkedIn and the PDF opens right away. Signing in doesn’t set up an organization, start a trial, or charge anything.
Does the FCRA apply to volunteer background checks?
FTC staff have read the FCRA’s “employment purposes” to include “a nonprofit organization staffed in whole or in part by volunteers,” and the standard practice is to follow the full process — disclosure, authorization and adverse-action notices — for every volunteer you screen. That coverage rests on FTC staff interpretation rather than the word “volunteer” in the statute, which the guide explains.
How long do we have to wait between the pre-adverse and final notices?
No statute sets a number. FTC staff say a reasonable period must pass and, in a 1997 letter, called five business days reasonable. California and New York City fair-chance laws also give covered job applicants at least five business days, which is why five business days is the common standard.
Is this legal advice?
No. It is general education about federal law and a few state and local rules as of September 2026. Confirm your obligations with qualified counsel.

Keep going

VolunteerBadge is owned and operated by ScreenForge Labs, LLC, an FCRA-regulated Consumer Reporting Agency that has obtained its FCRA Certificate from the Consumer Data Industry Association (CDIA). This guide is general educational information and is not legal advice.