Background Checks and Verifications

POLICY STATEMENT

Background checks and verifications are used to evaluate individuals’ eligibility to be engaged in certain work by the University on a case-by-case basis. Units are required to initiate background checks at the University for those covered by this policy, and must coordinate with Central Office of Human Resources (OHR) to use the University’s designated vendor. Background checks and verifications must be completed before the first day of work.

Background Checks

Standard background checks through the University’s designated vendor (as defined in Appendix: Background Check and Verification Packages) are required for:

• individuals being offered employment in, or being transferred or reassigned to, non-student positions;
• individuals, including non-employees and student employees, who are assigned duties where checks are legally or contractually required; and
• individuals, including non-employees and student employees, being engaged by the University encompassing work with minors (see administrative policy Safety of Minors).

Non-employees are required to complete a successful background check if they will be performing security-sensitive work for the University. Units must obtain confirmation of the successful completion of a background check for the non-employee with the vendor. Refer to appendix: Background Checks for Non-Employees for more information. If not available, then the unit must conduct a background check through the University’s designated vendor prior to the first day of work.

Senior leaders and other high-level leader positions (as defined in Appendix: Senior and Other High-Level Leader Positions for Background Checks and Verifications) as well as members of the University of Minnesota Police Department will be subject to more extensive background checks, whether triggered by an employment offer, a transfer, or a reassignment into one of these positions.

Individuals who completed a background check at the University with satisfactory results within the last twelve months will not be required to undergo another background check unless the new position or newly-assigned duties require different checks or verifications than those originally conducted.

Offers of employment, transfers, and reassignments and assignment of duties are contingent upon completion of background checks and specified verifications with satisfactory results.  Accordingly, units must plan and submit background check and verifications requests before employment or assignments occur.

Verifications of Credentials

Individuals, who are being offered employment or reassignment to a position where the assigned work requires certain educational, employment, and licensing credentials, must have their credentials verified.  Units are responsible for ensuring that licensures are tracked and demonstrated.

Results Review

Departments are responsible for initiating background checks and verifications through OHR and incur the costs. OHR staff will conduct individualized assessments of background check and credentials verification results taking into consideration important factors such as the nature and severity, time frame, and relevancy of any criminal convictions.

REASON FOR POLICY

This policy supports Board of Regents Policy: Employee Recruitment and Retention and provides business processes for Board of Regents Policy: Safety of Minors. It furthers important University efforts to provide a safe and secure environment for all University students, employees, and visitors to protect its funds, property, and other assets. Therefore, the University provides this formal process of background checks and verifications (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.

PROCEDURES

FORMS/INSTRUCTIONS

APPENDICES

FREQUENTLY ASKED QUESTIONS

CONTACTS

DEFINITIONS

Non-Employees

Individuals performing work on behalf of or in concert with the University, including vendor contractors or consultants working onsite, who are not actively employed by the University.

Student Positions

Positions that are non-academic student positions (2xxx job classification series); undergraduate academic teaching and research assistant positions); and graduate assistant positions

Other High-Level Leaders

For purposes of this policy, refer to Appendix: Listing of Senior and Other High-Level Leader Positions for Background Checks and Verifications.

Senior Leaders

Individuals specified as senior leaders in Board of Regents Policy: Reservation and Delegation of Authority. For purposes of this policy, refer to Appendix: Listing of Senior and Other High-Level Leader Positions for Background Checks and Verifications.

RESPONSIBILITIES

Hiring Authority/Department

Identify and communicate about circumstances where legal, contractual or the nature of the work justify conducting background checks and verifications; ensure licensures are tracked and demonstrated where necessary; identify selected applicants and employees and facilitate the exchange of information with them to conduct background checks and verifications; obtain confirmation from vendors of successful completion of a background check for non-employees when required; and hold responsibility for costs of background checks and verifications in their department.

College/Administrative Unit Human Resources

Verify with departments that all background checks are completed before the individual’s first day of work; determine whether to require background checks for additional positions, such as students, where the unit could be adversely impacted or where there is undue liability.

Office of Human Resources

Advise hiring authorities/departments about circumstances where legal, contractual, or legitimate business needs justify conducting background checks and verifications; ensure postings include appropriate information about background check requirement; and conduct individualized assessment of background check and verification results.

RELATED INFORMATION

• Board of Regents Policy: Employee Recruitment and Retention
• Board of Regents Policy: Safety of Minors
• Administrative Policy: Safety of Minors
• For residential dorm access: Minn. Stat. § 299C.68
• Nuclear Regulatory Commission: http://www.nrc.gov/security/byproduct.html
• Payment Cards/PCI DSS Standards Compliance
• State Regulation for child care workers: Minn. Stat. § 299C.62
• Criminal Offenders, Rehabilitation: Minn. Stat. § 364.01

HISTORY

Amended:

December 2017 - Comprehensive Review, Major Revision: 1. Expands requirements for background checks to include individuals who are not employees but are contracted by the University to perform security-sensitive work. 2. Establishes that the background checks and verifications must be completed before the first day of work. 3. Eliminates the separate cover sheet for senior leaders to simplify the process.

Amended:

June 2013 - Comprehensive Review. This revision creates a consistent system-wide requirement of background checks on all individuals being offered employment in, or being transferred or reassigned to, non-student positions. Checks will also be conducted for individuals, including volunteers, who are involved in work with minors, or where background checks are legally or contractually required.

Amended:

October 2012 - Senior leaders and other high-level leaders replaced the term, senior administrator. The classification job codes and titles assigned to each of these new terms are found in the Appendix: Senior and Other High-Level Positions Requiring Background Checks.

Amended:

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

Effective:

September 2008

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.