Student Life Background Checking

1. Student LifeBackground Checking Changes in Policy and Procedures HIRE ME! Your Candidate Student Life Human Resources

2. Program Requirements • Policy 4.15, Background Checks requires background checks to be conducted on final candidates for specified university positions. Departments may conduct background checks on candidates for positions not mandated by Policy 4.15. In these cases, the principles in this document must be used to establish department processes to ensure consistent and fair practices. • Applies to faculty, staff, graduate associates, student employees, volunteers, and applicants. • Department background check processes must be applied objectively and consistently within a department or division over time. • Departments must fully document background check processes to ensure consistent application. Documentation must include the business rationale for conducting checks, particularly if the practice is not applied to all final candidates within the department. • The types of background checks conducted must be relevant to the position responsibilities. Policy 4.15, p 1

3. Consumer Reports and/or Investigative Consumer Reports Standards, p. 4

4. Consumer Reports and/or Investigative Consumer Reports, cont. Standards, p. 5

5. Focal Points - Classification Review(OHR Policy 4.15, SL Risk & Emergency Management, SL Background Check Program Review – June 2007) • High security/sensitive workers • Care of children or minors, such as child care workers, camp counselors, etc. • Handling of financial matters; can be limited to those positions with approval authority or access above a set dollar amount. • Access to master keys of residences and areas requiring a high level of security, such as those that store controlled substances or money, research facilities, etc. • Access to controlled substances. • Access to and use of firearms. • Care of patients in health care settings such as hospitals, dental clinics, vision clinics, mental health facilities, etc. • Access to restricted levels of information technology systems or information. • Access to export-restricted information or materials by applicants for research faculty and research scientist positions, who are not naturalized citizens or do not have permanent resident status. • Agency temporary workers • Contractors/vendors/repair persons/delivery persons - (criteria: type/level of access)

6. 12 Commandmentsfor Hiring Managers (HMs) • Hiring manager must include “Requires successful completion of background check(s)” in the “Requirements” section of all position descriptions and employment advertisements for applicable positions (Policy 4.15, p. 4 – College/VP Unit). • Hiring manager conducts education, license, and employment reference checks before submitting materials for BC (Required, p. 1).

7. 12 Commandments for HMs 3. If candidate is a transfer (internal or external), HM contacts SL-HR Specialist for personnel file. • HM should review all information pertaining to the prospective employee’s work performance Transfer Internal/External Candidate SL BC Policy & Procedures, p.2

8. 12 Commandments for HMs, cont. 4. HM should explain to all prospective employees that (if an offer of employment is made) they shall be required to submit to fingerprinting, and must complete the Student Life Background Check Disclosure, Authorization, and Release Form (below) [SL BC Policy & Procedures, p.2]

9. 12 Commandments for HMs 5. HM must notify candidate that background check results are subject to the Ohio Public Records Act (refer to Definitions). FAQ, p. 2 and Policy 4.15, p. 4

10. 12 Commandments for HMs, cont. 6. In interview, HM is required to ask about the nature and circumstances of criminal convictions, if any are disclosed. Discriminatory questions are prohibited. FAQ, p. 1 and Standards, pp. 5-6

11. 7. HM should ask the candidate if there are any criminal convictions not listed on the application and discuss the details with them. If a candidate indicates that a criminal record was expunged, no further questions should be asked about it, as expungements cannot be taken into account regarding the candidate’s employment. 12 Commandments for HMs, cont.

12. Conviction Disclosure Commencing January 1, 2009, employees of SL must inform the Director of SL-HR (or designee) if they are convicted of any criminal offense • within 5 business days of the conviction • excludes traffic infractions • Director of SL-HR consults with employee’s Unit Director and Legal Affairs, to determine relevancy of conviction • Employee may be subject to reassignment, termination, or may be allowed to resign • Reporting of convictions is applicable to all employees, whether or not their positions are/were subject to an original background check. • Reporting requirement is effective for all criminal convictions occurring after December 31, 2008 SL BC Policy & Procedures, p. 3

13. 12 Commandments for HMs, cont. 8. All offers of employment, oral or written, must include a statement as follows: “This offer is contingent on the university’s verification of credentials and other information required by law and/or university policies, including but not limited to a criminal background check.” (Policy 4.15, p. 2) 9. HM confirms contact phone#, obtains candidate signatures, adds title, posting, and authorization data. Forwards completed documents to SL-HR Specialist.

14. 12 Commandments for HMs, cont. 10. HM should advise final candidate that fingerprint customers must present their Social Security card and one form of valid/legal state or federal identification (i.e. drivers license, state ID card, USCIS Permanent ID, or passport). [SL BC Policy & Procedures, p. 2] 11. HM should inform Background Check Coordinator of any negative info revealed in interview that the candidate discloses (Standards, p. 5 and Policy 4.15, p. 3). 12. Once the BC process has begun, the hiring manager must wait on results before offering position to another candidate (FAQ, p. 2).

15. SL-HR ResponsibilitiesHR Specialist BC Coordinator Reviews application materials Registers candidate and telephones to “schedule” fingerprinting Fingerprint customers must present their SS card and one form of valid legal state/federal identification (i.e. drivers license, state ID card, USCIS Permanent ID, or passport). Compiles consumer reports Analyzes the data Reports to the HM whether candidate is clear to work or did not pass Sends to candidates evidencing negative BC information: Summary of Rights under the FCRA, the results of checks performed by third party vendors Candidates have 5 business days to contest and to submit documentation to the BCC proving that the report is in error.

16. Pre- and Post-Adverse Action Letters

17. RECORD RETENTION • For candidates who are hired: • Results must be retained until reviewed by the BCC and a decision of hire is made. Then the BCC will destroy the results to ensure confidentiality. • BCC must retain only the Background Check Disclosure, Authorization, and Release Form. • for the length of employment plus three years, • in a secured location (e.g. locked file drawer) • separate from the candidate’s personnel file.

18. RECORD RETENTION, cont. • For candidates who are not hired due to information revealed in the background check: • BCC must retain both the results and the Background Check Disclosure, Authorization, and Release Form • for three years, • in a secured location (e.g. locked file drawer) • separate from other documents generated by the selection process.

19. Fingerprinting Hardware/Software WebCheck is a secure, web-based application that allows authorized citizens to use the Internet to submit fingerprint-based searches against a State and FBI criminal record database on a fee-for-service basis. • How WebCheck Works • 1. Data Entry: Swipe driver’s license or ID card to automatically extract demographic information. Complete the entry of additional demographic data. • 2. Capture Fingerprints: Capture left slap, right slap, and two thumbs simultaneously in a three-step process. • 3. Quality Check: Image quality check, automatic hand orientation verification for proper fingerprint sequencing, and fingerprint segmentation. • 4. Submit Transactions: Fingerprint images and demographics are encrypted and submitted to the State AFIS and subsequently to the FBI AFIS (IAFIS). • 5. Results Returned: A “No Record” status empowers the requestor to print a “No Record” Letter. If a record is found the requestor will be notified that a printed RAP sheet will be sent via US mail

20. What’s coming…Future Directions of OHR Determining feasibility of centralizing background checks for all academic units into OHR. May expand the list of titles/positions requiring background checks. Exploring required credit checks on some types of positions (i.e. those with financial duties). May implement schedule of routine background checks for positions requiring checks.