Driver Screening & Background Check Policy

Effective Date: July 5, 2025

Applies To: All driver applicants and active drivers operating on the Ritugo platform in Utah (and any additional jurisdictions where Ritugo expands, subject to local law review).

1. Purpose

Ritugo is committed to protecting passengers, drivers, and the public by ensuring that all drivers meet reasonable safety, legal, and trustworthiness standards. This policy establishes Ritugo’s driver screening requirements, including criminal background checks and motor vehicle record (MVR) reviews, in compliance with applicable federal and Utah state law.

Ritugo’s screening practices are designed to balance public safety with legal fairness, including compliance with the Fair Credit Reporting Act (FCRA), Equal Employment Opportunity Commission (EEOC) guidance, and Utah statutes governing criminal history and expungement.

2. Legal & Regulatory Framework

Ritugo complies with all applicable laws governing background checks and hiring decisions, including:

• Fair Credit Reporting Act (FCRA):
  When using consumer reporting agencies (CRAs), Ritugo provides stand-alone disclosures, obtains written authorization, and follows required pre-adverse and adverse action procedures.

• EEOC Guidance & Anti-Discrimination Laws:
  Criminal history information is evaluated in a manner intended to avoid unlawful discrimination or disparate impact on protected classes. Individualized assessments are conducted where required.

• Utah Bureau of Criminal Identification (BCI):
  Ritugo follows Utah rules governing access to criminal history records and fingerprint submissions where applicable.

• Expungement & Sealed Records:
  Ritugo does not consider records that have been lawfully expunged or automatically sealed under Utah law.
  
  

3. Screening Process Overview

3.1 Pre-Hire Screening (Applicants)

Before activation, driver applicants must:

• Provide valid government-issued identification

• Hold a valid U.S. driver’s license

• Provide proof of insurance and vehicle registration

• Sign a stand-alone FCRA disclosure and authorization

• Undergo:

  • Criminal background check (county/state and national databases)

  • National sex offender registry search

  • Motor Vehicle Record (MVR) review covering the prior 3–7 years

Fingerprint-based checks may be required where mandated by Utah law.

3.2 Conditional Activation

• Applicants who meet Ritugo’s standards may be conditionally activated pending vehicle inspection and onboarding.

• If potentially disqualifying information appears:

  • Ritugo will issue an FCRA-compliant pre-adverse action notice

  • The applicant will receive a copy of the report and an opportunity to dispute or clarify

  • Final decisions follow FCRA adverse-action requirements where applicable
    
    

3.3 Ongoing Monitoring & Re-Checks

• Motor Vehicle Records:
  Reviewed at least annually; continuous monitoring may be used where feasible.

• Criminal Background Re-Checks:
  Conducted at least annually or triggered by safety incidents, complaints, or law enforcement involvement.
  
  

4. Disqualifying Offenses & Thresholds

4.1 Absolute Disqualifiers (Any Jurisdiction)

• Listing on a national sex offender registry

• Violent felony convictions involving bodily harm within the past 10 years

• Unresolved violent felony charges

• Felony driving offenses involving injury within the past 10 years

• Driving without a valid or legally usable license
  
  

4.2 Conditional or Time-Limited Disqualifiers

• DUI / Drug- or Alcohol-Related Driving Offenses:
  Disqualifying if within the past 7 years

• Reckless Driving, Hit-and-Run, Driving on Suspended License:
  Disqualifying if within the past 3–7 years depending on severity

• Multiple Moving Violations or At-Fault Accidents:
  Disqualification may apply where thresholds are exceeded unless mitigating factors support approval

Older non-violent offenses may be reviewed under an individualized assessment consistent with EEOC guidance and Utah law.

5. Individualized Assessment & Mitigation

Before taking adverse action based on criminal history, Ritugo will:

1. Provide the applicant a copy of the report and a minimum of seven (7) business days to respond

2. Consider:

   • Nature and gravity of the offense

   • Time elapsed

   • Relevance to passenger transportation

3. Issue an adverse action notice where required under FCRA
   
   

6. Motor Vehicle Record (MVR) Standards

• Minimum driving experience:

  • At least 1 year of U.S. driving experience (3 years if under age 25)

• License must be valid and unrestricted

• Any active suspension or revocation results in disqualification until resolved

• Major violations may result in disqualification for 3–10 years depending on severity

7. Record Retention & Privacy

• Background screening records are retained for at least two (2) years following the hiring decision, or longer where required by law

• Records are stored securely and access is limited to authorized personnel

• Expunged or sealed records are removed from consideration upon verification
  
  

8. Appeals & Dispute Process

Applicants or drivers may submit a written appeal within fourteen (14) calendar days of receiving an adverse action notice. Appeals are reviewed by Ritugo’s compliance team and resolved within fourteen (14) business days where practicable.

Temporary conditional driving status may be granted in limited circumstances, except where core disqualifiers apply.

9. Non-Discrimination & Accommodations

Ritugo applies this policy in a nondiscriminatory manner and provides reasonable accommodations during the screening process where required by law, unless doing so would impose undue hardship or compromise safety.

10. Policy Review

This policy is reviewed at least annually and updated as necessary to reflect changes in law, regulatory guidance, insurance requirements, or operational standards.