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Human Resources

Background Checks (VI.F.6)

Volume VI: Human Resources
Chapter F: Terms and Conditions of Employment
Responsible Executive: Vice President of Human Resources
Responsible Office: Vice President of Human Resources
Date Issued: May 1, 2011
Date Last Revised: November 15, 2012

TABLE OF CONTENTS

Statement of Policy
Reason for This Policy
Individuals and Entities Affected by This Policy
Who Should Know This Policy
Exclusions
Website Address for This Policy
Contacts
Definitions
Responsibilities
Procedures
Related Documents, Forms and Tools
History and Updates
Appendix

STATEMENT OF POLICY

Purdue University strives to provide the safest possible environment for its students, faculty, staff and visitors; to preserve university resources; and to uphold the reputation and integrity of the University. In order to support these goals, the University will conduct Criminal History and Sex and Violent Offender Registry Checks for new hires to the University. Additional checks, such as to verify for education and certifications, and Credit History Checks, may be required based upon job responsibilities. Positions with the same or similar job responsibilities will require the same or similar Background Checks. All job postings will indicate Background Check requirements for the position, including any requirement that current University Employees applying for the position undergo a Background Check appropriate to the position’s responsibilities. All offers of employment to new hires to the University will be made contingent upon the results of the Background Check. If an Employee applies for a position that requires a Background Check, the offer for the new position will be contingent upon the results of the Background Check.

Candidates for employment who fail to participate fully or who provide inaccurate information in a Background Check will be eliminated from consideration for the position. Candidates may decline to authorize a Background Check; in such cases, no Background Check will be performed, but the Candidate will not be considered further.

All individuals applying for a position with Purdue University are required to disclose Criminal Conviction information. Individuals with Criminal Convictions may be disqualified from holding a position at the University based on the conviction’s relevancy to the position. Criminal Conviction information will not be used to discriminate against Candidates. The existence of a Criminal Conviction will not automatically disqualify an individual from employment or employment consideration. The University will consider the nature and seriousness of the offense, the nature of the position, and the length of time since the conviction. When a finding adversely impacts employment eligibility, the Candidate will be notified and may be withdrawn from employment consideration after Human Resources consults with the Senior Leader on the matter.

The University will provide Candidates access to a copy of their Background Check report upon request, regardless of outcome and without charge to the Candidate. In cases where information in the Background Check report will result in an adverse hiring decision, the University will provide a copy of the report to the Candidate without his or her request. Cases in which information in a Consumer Report will result in an adverse employment decision, the University will provide the Candidate with all required notifications pursuant to the Fair Credit Reporting Act.

The University recognizes the need to protect an individual’s right to privacy. As such, all Background Check records will be kept in secured, access-restricted personnel files. Any member of the Purdue University community not required by this policy to have access to Background Check records is prohibited from seeking, using or disclosing such records.

REASON FOR THIS POLICY

Purdue University strives to provide the safest possible environment for its students, faculty, staff and visitors; to preserve university resources; and to uphold the reputation and integrity of the University. This policy supports the University’s efforts to minimize institutional risk and assists hiring authorities in making sound hiring decisions.

INDIVIDUALS AND ENTITIES AFFECTED BY THIS POLICY

  • Candidates for full-time and part-time faculty and staff, benefits-eligible positions
  • Temporary Employees not sponsored by a staffing agency
  • Staff
  • Faculty
  • Individuals involved in the screening and hiring process

WHO SHOULD KNOW THIS POLICY

President
Vice Presidents
Chancellors
Vice Chancellors
Vice Provosts
Deans
Directors
Department Heads and Chairs
Hiring Supervisors

EXCLUSIONS

The following groups are not required to undergo Background Checks in connection with this policy:

  • Individuals employed by outside staffing agencies
  • Student and graduate student appointments
  • Individuals appointed to non-paid positions

Notwithstanding the forgoing, this policy will not prohibit hiring departments from working with Human Resources to conduct Background Checks, when deemed appropriate, in connection with specific job functions. If a hiring department seeks to employ individuals in one of the above groups and the position involves one or more of the following tasks, the department should consult with Human Resources to verify whether a Background Check should be initiated:

  • Master key access to buildings, including residences or other facilities
  • Direct responsibility for the care, safety and security of people, or the safety and security of personal and university property (includes child care workers, physicians, student affairs officers, residence hall supervisors, coaches, transit drivers, etc.)
  • Direct responsibility for the care, safety and security of animals
  • Direct access to or responsibility for cash, cash equivalents, checks, credit card account information, or university property disbursements or receipts
  • Extensive authority for committing the financial resources of the University
  • Direct access to or responsibility for controlled substances or hazardous materials
  • Direct access to or responsibility for protected, personal or other sensitive data (includes auditors, information systems personnel, Human Resources and payroll staff, registrars, etc.)

WEBSITE ADDRESS FOR THIS POLICY

www.purdue.edu/policies/human-resources/vif6.html

CONTACTS

Subject Contact Telephone E-mail/Web Address
Policy Clarification West Lafayette Human Resources-Employment (765) 494-0603 empofficer@purdue.edu
Campus-Specific Questions West Lafayette Human Resources-Employment (765) 494-0603 empofficer@purdue.edu
Calumet Human Resources (219) 989-2251
IPFW Human Resources (260) 481-6677
North Central Human Resources (219) 785-5300

DEFINITIONS

Background Check
Verification of credentials and other information about a Candidate or Employee. Such verification may include any or all of the following:

  • Educational Verification
  • License Verification
  • Credit History Check
  • Criminal History Check
  • Sex and Violent Offender Registry Check
  • Limited Criminal History Check
  • Limited Sex and Violent Offender Registry Check
  • Employment Verification

Candidate
Applicant for employment with the University.

Consumer Report
Any communication of information by a Consumer Reporting Agency bearing on a consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics or mode of living.

Consumer Reporting Agency
Any person or entity which, for a fee, dues or on a cooperative nonprofit basis, regularly engages in the practice of assembling or evaluating consumer credit information, or other information, on consumers for the purpose of furnishing Consumer Reports to third parties. For the purposes of this policy, a Consumer Reporting Agency refers to the vendor used by Purdue University to conduct Background Checks.

Credit History Check
Review of the selected Candidate’s or Employee’s detailed credit history, as contained in a Consumer Report. (Federal laws prohibit discrimination against an applicant or Employee as a result of bankruptcy.)

Criminal Conviction
Being found guilty, entering a guilty plea or pleading no contest to a felony and/or misdemeanor other than a minor traffic violation. This includes Criminal Convictions for which the individual’s record has been expunged.

Criminal History Check
Verification that the selected Candidate or Employee does not have any undisclosed Criminal Convictions in any jurisdiction where he or she has ever resided, including the jurisdiction where he or she currently resides.

Educational Verification
Confirmation of the selected Candidate’s or Employee’s educational credentials listed on the application, resume or cover letter, or otherwise cited by the Candidate or Employee.

Employee
Any person employed by Purdue University, whether full- or part-time.

Employment Verification
Confirmation that the selected Candidate or Employee actually worked in the positions listed on the application, resume or cover letter, or otherwise cited by the Candidate or Employee, as well as all employment during a period of at least seven years immediately preceding application to Purdue University. This verification includes the dates of employment and reasons for leaving each position.

Fair Credit Reporting Act (FCRA)
A Federal law designed to promote the accuracy, fairness and privacy of information in the files of Consumer Reporting Agencies, codified at 15 U.S.C. §1681 et seq.

License Verification
Confirmation that the selected Candidate or Employee possesses all licenses listed on the application, resume or cover letter, or otherwise cited by the Candidate or Employee, including verification of the disposition of such licenses. This includes any motor vehicle driver’s licenses required for a position.

Limited Criminal History Check
Verification that the selected Candidate or Employee does not have any undisclosed Criminal Convictions during the last seven years in the jurisdiction where he or she currently resides or last resided.

Limited Sex and Violent Offender Registry Check
Verification that the selected Candidate or Employee does not have undisclosed convictions of certain sex and violent crimes during the last seven years in the jurisdiction where he or she currently resides or last resided.

Purdue, University and Purdue University
Any campus, unit, program, association or entity of Purdue University, including but not limited to Indiana University-Purdue University Fort Wayne, Purdue University Calumet, Purdue University North Central, Purdue University West Lafayette, Purdue Cooperative Extension Service and Purdue University College of Technology Statewide.

Senior Leader
For the purposes of this policy, the Senior Leader will be considered as one or more of the following:

  • President
  • Provost
  • Vice Presidents
  • Chancellors
  • Vice Chancellors
  • Vice Provosts
  • Deans
  • Directors
  • Department Heads and Chairs

Sex and Violent Offender Registry Check
Verification that the selected Candidate or Employee does not have undisclosed convictions of certain sex and violent crimes in every jurisdiction where he or she has ever resided, including where he or she currently resides.

RESPONSIBILITIES

Vice President for Human Resources and Regional Campus Chancellors or their Designee
Ensure policy compliance and establish Background Check procedures as appropriate for their respective campuses.

Candidates
Disclose Criminal Conviction information when applying for a position.

Consent to a Background Check.

Provide complete and accurate information in a timely manner.

Human Resources
Work with Hiring Supervisor to identify appropriate Background Check components based upon the position’s responsibilities.

Ensure appropriate Background Check language is incorporated into each job posting.

Provide the Hiring Supervisor with the appropriate Background Check language to share with Candidates.

Ensure that the appropriate consent forms have been obtained, and work with Purdue’s Consumer Reporting Agency to complete the Background Check.

Ensure University compliance with the FCRA, and work directly with Candidates to provide required FCRA disclosures and notifications.

Update Hiring Supervisor and Business Office on the status of the Background Check.

Communicate and provide necessary training regarding this policy.

Perform, or contract as necessary with a third-party vendor(s) to perform, Background Checks on specified Candidates and Employees.

Hiring Supervisor and Business Offices
Ensure that all offers of employment are made contingent upon the results of the Background Check, and assist Human Resources in securing the necessary consent from the Candidate.

Notify Human Resources to initiate the Background Check when a contingent job offer has been made.

PROCEDURES

The Vice President for Human Resources and the Chancellors of the Regional Campuses, or their designee(s), will establish procedures for their respective campuses to implement this policy. Such procedures will include:

  • Background Check requirements will be identified and included in all job postings.
  • Background Checks may be initiated when a contingent offer of employment is made to an individual or a department elects to conduct Background Checks on a small group of Candidates who were notified that they are one of several finalists for appointment to a position.
  • Consent for a Background Check must be obtained prior to conducting such checks. If the services of a Consumer Reporting Agency will be used, FCRA compliant authorizations and disclosures must be provided to the Candidate.
  • Human Resources, the Consumer Reporting Agency and the Candidate will work collaboratively to validate and ensure accuracy of Background Check reports. If the Background Check results reveal negative information contained within a Consumer Report provided by a Consumer Reporting Agency, which will be used to make an adverse employment decision, the Human Resources Team must provide the Candidate or Employee with a copy of the Consumer Report, and a copy of the Federal Trade Commission’s Summary of Your Rights Under the Fair Credit Reporting Act, prior to notifying the Employee or Candidate that an adverse employment action will be taken. Once the Employee or Candidate has received a copy of the Consumer Report and summary of rights, the Human Resources Team must notify the Candidate of the adverse action, meeting all requirements for notification contained in the FCRA.
  • Human Resources will notify the supervisor of the final status of the Candidate.

RELATED DOCUMENTS, FORMS AND TOOLS

Summary of rights under the Fair Credit Reporting Act: www.ftc.gov/bcp/edu/pubs/consumer/credit/cre35.pdf

Supervisor Resources (West Lafayette campus) — page includes links to process outlines for staff positions and temporary staff positions: www.purdue.edu/hr/careers/resources/supervisor.html

Forms:

HISTORY AND UPDATES

November 15, 2012: Related Documents, Forms and Tools section updated.

March 1, 2012: The exclusion of temporary Employees employed 90 days or less was removed from this policy.

November 18, 2011: Policy number changed to VI.F.6 (formerly IV.14.6).

May 1, 2011: This is the first such policy to address this issue.

APPENDIX

There are no appendices to this policy.