Units are required to initiate background checks at the University for those covered by this policy, and must coordinate with the Central Office of Human Resources (OHR) to use the University’s designated vendor and adjudication process. 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. Background checks and verifications must be completed before the first day of work.
Standard background checks through the University’s designated vendor 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, provided this check is comparable to the University’s background check for a similar position. Refer to appendix: Background Checks for Non-Employees for more information. If not available, then the unit must conduct a background check on the non-employee 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 substantially different checks (e.g. Safety of Minors, driving, financial responsibilities) or verifications than those originally conducted.
Individuals who are rehired into a previously-held position do not need to complete a new background check provided that:
- the individual previously passed a background check for that position,
- the break in service for that position was less than 12 months (365 days) from the new hire date, and
- the position does not fall under other background check requirements (e.g. Safety of Minors, federal requirements, financial responsibilities, driving University vehicles).
Current employees taking an additional position at the University do not need to complete a new background check unless the new position falls under other background check requirements (e.g. Safety of Minors, federal requirements, financial responsibilities, driving University vehicles).
With the exception of reclassifications, 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 verification requests before employment or assignments occur. Reclassifications are exempt from this requirement.
In rare circumstances, individuals may be granted an exception by the Office of Human Resources and start their appointment prior to the completion of the background check and verification. Exceptions will only be considered if the required background check and verifications have not been completed after 5 days from when the individual submitted their information and:
- the position provides a service critical to the mission of the University and the delay in their employment impacts the University’s ability to provide this service; or
- the background check and verification process has been impacted by extenuating circumstances, such as a natural disaster, pandemic, etc.
Requests for exception must be sent to Talent Acquisition, to be reviewed and approved by the Talent Acquisition Director and in consultation with the Vice President of Human Resources and the Office of the General Counsel, as needed (see Background Check Exception Form for Extenuating Circumstances.
International Criminal Checks
Where a background check is already required, a criminal background check for other countries of residence will be included for:
- U.S. Residents who have resided outside of the United States for a period greater than 12 months in the past 7 years.
Foreign nationals without current visa or authorization to work in the United States must be able to pass the security checks required through the visa or work authorization prior to beginning employment.
Education and Credential Verifications
Individuals offered employment or reassignment to a position where the assigned work requires certain education (e.g. degree requirement for P&A positions), employment, and/or licensing credentials, must have their credentials verified. Units are responsible for ensuring that licensures are tracked and demonstrated.
No checks or reviews of non-professional social media, either through a vendor or informally as part of a search process, should be performed without prior consultation and approval from OHR. For senior and other high-level leaders (see Appendix: Senior and Other Higher Level Leader Positions for Background Checks and Verifications) and for roles that have obtained approval from OHR, a background check on non-professional social media is required through an approved vendor or approved process by OHR. Results of social media checks are reviewed by Central OHR or University staff authorized by OHR for final determination if the results require adjudication.
Departments are responsible for initiating background checks and verifications through OHR and incurring 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 to the position. OHR Staff will follow the requirements in Minn. Stat. § 364.01, et seq. and will consult with the Office of the General Counsel (OGC) as needed when issues arise on an individual’s background check.
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 hiring decisions.