Pre-hire Background Verification

Offers of employment, even those of a more temporary nature (e.g., interim, temporary, or casual appointments), are contingent upon completion of background verification with satisfactory results when required by law; University administrative policy; or collegiate unit, coordinate campus, or administrative unit policy. Background verification, as determined by the nature of the position, may include but is not limited to checks in the areas of education, licensing, or employment, criminal history, and sex and violent offender registry. The University also reserves the right to conduct periodic verification updates.

Background verification, using the University designated vendor, is mandated for newly hired, transferred, promoted, reclassified, or reassigned persons in the following categories:

1. Senior administrative positions (refer to Appendix: Senior Administrative Positions Requiring Background Verification);
2. Positions with any fiscal management responsibilities; or
3. Positions where federal or state regulations require criminal checks (e.g., child care workers, cash handlers, police officers, truck drivers, positions that require or permit access to student residence halls or attached facilities).

There are other positions for which background verifications are advisable (refer to Appendix: Positions for which Background Verifications are Advisable). Background verification on all new or other particular types of positions may also be required in policy established at the collegiate unit, coordinate campus, or administrative unit level.

The department is responsible for initiating the background verification through the Office of Human Resources and incurs the cost of the verification. In accordance with University policy and state and federal law, the University acknowledges the individual’s right to privacy and prohibits employees and others from seeking, using, or disclosing personal information except within the scope of assigned duties. Information uncovered in the background verification, including - where permitted by law - criminal convictions, may be cause to disqualify the individual from holding the position.

This policy implements Board of Regents Policy: Employee Recruitment and Retention. It is important for all University students, employees, and visitors to have a safe and secure environment and for the University to take prudent action to protect its funds, property, and other assets. Therefore, the University provides this formal process of pre-hire background verification (1) to minimize institutional risk, (2) to comply with federal and state regulations that require it for specified positions, and (3) to help responsible hiring authorities make sound hires.

• Conducting Pre-Hire Background Verifications

There are no forms for this policy.

For non-senior administrator positions

• UM 1689: Background Check Consent for Non-Senior Administrator Positions
• UM 1690: Personal Disclosure Statement for Non-Senior Administrator Position
• UM 1691: Background Check Request – Cover Sheet for Non-Senior Administrator Positions
• Summary of Rights under the Fair Credit Reporting Act

For senior administrator positions:

• UM 1692: Background Check Consent Form for Senior Administrator Positions
• UM 1693: Personal Disclosure Statement for Senior Administrator Positions
• UM 1694: Background Check Request – Cover Sheet for Senior Administrator Positions
• Summary of Rights under the Fair Credit Reporting Act

Subject	Contact	Phone	Fax/Email
General Information or Procedural Assistance	Primary: OHR Program Lead Secondary: OHR, AHC or UMD – Human Resources Employment Consultants	612-626-9460 Refer to Directory	612-626-7911 d-matc@umn.edu Refer to Directory
Document Processing	HRMS Key Contact Office of Human Resources Call Center	HRMS Key Contact List 612-625-2016	HRMS Key Contact List

Administrative Unit

The support units of the University such as the Office of the General Counsel, Office of Information Technology, and University Relations.

Credit History Examination

A review of the selected applicant’s or employee’s detailed credit information and summary. (Federal laws prohibit discrimination against an applicant or employee as a result of bankruptcy.)

Criminal History Check

A verification that the selected applicant or employee does not have any undisclosed criminal history in every jurisdiction where the applicant or employee currently resides or has resided. Limited checks will mean those checks conducted if the applicant or employee only recently moved to a location near the University of Minnesota.

Educational Verification

The selected applicant or employee possesses all educational credentials beyond high school listed on the application materials or otherwise cited by the applicant or employee that qualifies the individual for the position sought.

Employment Verification

The selected applicant or employee worked in the positions listed on the application materials or otherwise cited by the applicant or employee that qualifies the employee for the position sought. All employment during a period of at least seven (7) years immediately preceding application at the University will be checked. This verification should include dates of employment and verification of last position held.

License Verification

The selected applicant or employee possesses all the licenses listed on the application materials or otherwise cited by the candidate that qualifies the individual for the position sought and verification of the license required for the position, including verification of the disposition of such licenses. This includes motor vehicle driver’s licenses required for a particular position.

Sex and Violent Offender Registry Check

The selected applicant or employee does not have undisclosed convictions of certain sex and violent crimes in the jurisdiction where the applicant or employee currently resides, or where the applicant or employee last resided. Limited checks will mean those checks conducted if the applicant or employee only recently moved to a location near the University of Minnesota.

Social Security Trace

The verification of all the known aliases and addresses associated with the applicant employee name.

Hiring Authority/Department

• Determines if a background verification is to be conducted and, if so, what type of checks are to be made.
• Ensures all related posting information, including the requisition, states if a background verification is to be conducted.
• Ensures the selected applicant is provided a summary of rights under the Fair Credit Reporting Act (FCRA) and the required forms to complete.
• Provides applicant with information on the appropriate location for submitting completed forms.
• Submits payment to the background verification vendor.

OHR, AHC, or UMD-HR Employment Team

• Consults with hiring authority regarding required background verification and where checks may be advisable.
• Ensures that all posting/advertising related information contains appropriate background verification information.
• Requests background verification when selected applicant is known.
• Reviews results of the background verification.
• Makes initial determination of suitability for employment.
• Communicates appropriate information to the selected applicant and outlines appeal rights in situations of adverse action.
• Provides the Background Verification Program lead with copy of report for filing and deletes electronic background verification results upon completion of the report evaluation.

OHR Employment Manager and Background Verification Program Lead

• Assists in establishing policy, procedures, and criteria for determining whether a background verification is required for specific vacancies, job families/codes, and/or special programs.
• Provides template letter to communicate with selected applicant regarding background verification results.
• Makes final determination of suitability for employment.
• Manages the process with the outside background verification vendor.
• Ensures compliance with background screening policy and requirements.
• Oversees the proper use of the vendor contract.
• Secures and maintains central storage of paper copy of background report results.

Selected Applicant

• Signs required forms and submits (mailed, faxed, or delivered) to the OHR, AHC, or UMD Human Resources, as appropriate.

• Positions for Which Background Verification Is Advisable
• Senior Administrative Positions Requiring Background Checks
• Vendor (Hire Right) Customer Packages

1. When a current employee, who has previously undergone a background verification, is hired or is transferred, promoted, reclassified, or reassigned into a different position where a background check is required, must another verification be conducted?

   It depends on when the last background verification was completed and what checks were done. If the verification was completed within the past year, another one is not required unless the functions of the position call for different checks than were originally conducted. If the previous verification was conducted over a year ago, then another is required regardless of the functions of the new position.

2. Are background verifications to be conducted on the position finalists or on the selected applicant only?

   The background verification is to be conducted on the selected applicants, the individuals to whom the offer of the position will be made.

• Board of Regents Policy: Employee Recruitment and Retention
• For residential dorm access: Minn. Stat. § 299C.68
• Nuclear Regulatory Commission: http://www.nrc.gov/security/byproduct.html
• Payment Card Industry: http://www.finsys.umn.edu/ar/pcidss.html
• State Regulation for child care workers: Minn. Stat. § 299C.62
• Criminal Offenders, Rehabilitation: Minn. Stat. § 364.01

Amended:

January 2009 - Edits made and language clarified in the policy statement. Administrative unit was added under the Definition section.

Adopted:

August 2008 - The Pre-employment Background Verification Program has been in place since March 2006 and has now been formalized in this administrative policy.

Effective: