University of Minnesota  Administrative Policy

Background Checks and Verifications

Policy Statement

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.

Background Checks

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.

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.

Social Media

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. 

Results Review

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.

Contacts

Subject Contact Phone Email
General information, procedural assistance, and exception requests Primary: OHR  or UMD Program Lead– Human Resources Employment Consultants Refer to directory [email protected]
Document processing Office of Human Resources Contact Center 612-624-8647 (UOHR) [email protected]

Definitions

Non-Employees
Individuals performing work on behalf of or in concert with the University, including vendor contractors or consultants working onsite or remotely with sensitive University data, 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: 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: Senior and Other High-Level Leader Positions for Background Checks and Verifications.

Responsible Individuals

Responsible Officer
Ken Horstman
Vice President, Office of Human Resources
Owner
Brandon Sullivan
Director - Leadership and Talent Development
Primary Contact
See Contacts Section

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; conduct individualized assessment of background check and verification results; consult, review, and act on requests for social media background checks; and review and act on exception requests for an employee starting before a background check completes.
Office of the General Counsel
Consult with the Office of Human Resources on (1) decisions regarding hiring exceptions for individuals starting prior to the completion of a background check and (2) issues that arise on an individual’s background check, ensuring compliance with state and federal background check legal requirements.

Related Information

Board of Regents Policies

Administrative Policies

Other Related Information

History

Amended:
September 2022 -
  1. New guidance on when social media checks are allowed or required
  2. Allowing exceptions to individuals starting employment prior to the completion of their background check only under extenuating circumstances
  3. Requiring international criminal checks to be done only where a foreign national does not have a current visa or authorization to work in the United States, or where US Nationals have lived outside the US for greater than 12 months.
  4. Clarifying when background checks are required for current or recent employees transfer or seasonal rehire situations.
  5. Clarifying and updating language according to current business practices
Amended:
January 2018 - 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.