Background Checks (VI.F.6)

Volume VI: Human Resources
Chapter F: Terms and Conditions of Employment
Responsible Executive: Vice President for Human Resources
Responsible Office: Office of the Vice President for Human Resources
Date Issued: May 1, 2011
Date Last Revised: August 1, 2022

TABLE OF CONTENTS

Contacts
Statement of Policy
Reason for This Policy
Individuals and Entities Affected by This Policy
Exclusions
Responsibilities
Definitions (defined terms are capitalized throughout the document)
Related Documents, Forms and Tools
Website Address for This Policy
History and Updates
Appendix

CONTACTS

Policy Clarification

Title/Office

Telephone

Email/Webpage

Office of the Vice President for Human Resources – Talent Acquisition

765-494-0603

careers@purdue.edu

 

Campus Specific Questions

Title/Office

Telephone

Email/Webpage

Fort Wayne: Human Resources

260-481-6677

hr@pfw.edu

Northwest: Human Resources

219-989-2251

hr@pnw.edu

West Lafayette: Talent Acquisition

765-494-0603

careers@purdue.edu

 

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 conducts Criminal History and Sex and Violent Offender Registry Checks on Candidates for employment with the University. Additional checks, such as Credit History Checks or verification of education and certifications, may be required based upon job responsibilities. Positions with the same or similar job responsibilities require the same or similar Background Checks.

Notification, Disclosure and Consent

All job postings indicate when a Background Check is required for the position. All offers of employment, whether to a Candidate who is new to the University or a current Employee, are contingent upon the results of the Background Check.

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 is not used to discriminate against Candidates. The existence of a Criminal Conviction does not automatically disqualify an individual from employment or employment consideration. The University considers 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 is notified and may be withdrawn from employment consideration after Human Resources consults with the Senior Leader on the matter.

Consent for a Background Check must be obtained prior to conducting the check. If the services of a Consumer Reporting Agency are used, FCRA-compliant authorizations and disclosures must be provided to the Candidate. Candidates may decline to authorize a Background Check; in such cases, no Background Check is performed, but the Candidate is not considered further. Candidates who fail to participate fully or who provide inaccurate information in a Background Check are eliminated from consideration for the position.

The University provides 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 results in an adverse hiring decision, the University provides a copy of the report to the Candidate prior to notifying the Candidate that an adverse employment decision will be made. If information in a Consumer Report results in an adverse employment decision, the University provides the Candidate with all required notifications pursuant to the Fair Credit Reporting Act prior to notifying the Candidate that an adverse employment decision will be made.

Appointments Not on Payroll

Candidates for one of the four appointments defined in the policy on Appointments for Personnel Not on Payroll (VI.B.3) are subject to Background Checks in accordance with this policy, except that appointments expected to last 14 days or less are subject only to a Sex and Violent Offender Registry Check. If the appointment continues beyond 14 days, the appointing department must initiate via Human Resources the Criminal History Check and any other checks or verifications applicable to the position.

Outside Staffing Agencies

Departments that utilize outside staffing agencies to hire temporary employees must verify that the agency conducts Background Checks on its employees that meet the requirements of this policy. The Background Check components need to be commensurate with the responsibilities of the position. If the agency’s Background Check does not include a Sex and Violent Offender Registry Check, the department is responsible for completing this step prior to engaging the services of the individual.

Student Appointments

Candidates for undergraduate student and graduate student appointments are subject to a Sex and Violent Offender Registry Check prior to their appointment with the University.  

Hiring departments that seek to employ students in a position that involves one or more of the following tasks must consult with Human Resources regarding which additional Background Checks to initiate:

  • 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 childcare 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.)

Background Checks on Current Employees

The University reserves the right to conduct Sex and Violent Offender Registry Checks (Limited or otherwise) on all current Employees at regular intervals. These checks do not require prior consent from the Employee when viewing only information that is public record.

Additional Background Checks may be conducted on a specific Employee or group of Employees in connection with job responsibilities and in consultation with Human Resources. These additional checks are conducted no more frequently than annually. If an Employee takes on new responsibilities, applies for a new position or otherwise triggers a Background Check, a new check is not required if the University conducted the requisite check within the previous 12 months. The results of the most recent check are considered in any pending employment decision. All requirements for consent and access to the report outlined in this policy apply.

Failure to participate fully or provide accurate information in a Background Check, regardless of the reason for the check, may result in disciplinary action, up to and including termination of employment. In the event a Background Check results in an adverse finding, Human Resources consults with the Senior Leader to determine whether the Employee will be allowed to remain with the University, and if so, under what conditions.

Records

The University recognizes the need to protect an individual’s right to privacy. As such, all Background Check records are 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 positions
  • Temporary employees
  • Staff
  • Faculty
  • Individuals involved in the screening and hiring process

EXCLUSIONS

There are no exclusions to this policy.

RESPONSIBILITIES

Vice President for Human Resources and Chancellors or their Designees

  • 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.

Current Employees

  • Consent to a Background Check as applicable in connection with job responsibilities and 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 Hiring Supervisor with appropriate Background Check language to share with Candidates.
  • Ensure that appropriate consent forms are 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 and Employees to provide required FCRA disclosures and notifications.
  • Update Hiring Supervisor and Business Office on the status of the Background Check.
  • Review reported matches with offender registries and advise departments on the appropriate action to take if the match is confirmed.
  • 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 Departments and Business Offices

  • Ensure that all offers of employment are made contingent upon 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 upon making a contingent job offer, including offers for positions covered by the policy on Appointments for Personnel Not on Payroll (VI.B.3) that are expected to last longer than 14 days.
  • Conduct a Sex and Violent Offender Registry Check upon extending a contingent job offer to student and graduate student appointees, and for appointments to positions defined in the policy on Appointments for Personnel Not on Payroll (VI.B.3) that are expected to last 14 days or less. Notify Human Resources if there is a reported match.

Senior Vice President for Administrative Operations

  • In consultation with the Vice President for Human Resources (West Lafayette campus) and the Vice Chancellors for Finance and Administration (Fort Wayne and Northwest campuses), designate administrative units to carry out Sex and Violent Offender Registry Checks (Limited or otherwise) on all current Employees at regular intervals.

DEFINITIONS

All defined terms are capitalized throughout the document. Refer to the central Policy Glossary for additional defined terms.

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 a position with the University, including Employees who apply for an open position.

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 they ever resided, including the jurisdiction where they currently reside.

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-time, part-time or temporary.

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 the application. 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 they currently reside 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 they currently reside or last resided.

Senior Leader
For the purposes of this policy, the Senior Leader includes:

  • 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 they ever resided, including where they currently reside.

RELATED DOCUMENTS, FORMS AND TOOLS

Summary of Your Rights under the Fair Credit Reporting Act (PDF)

Manager Resources for Recruiting and Hiring

Appointments for Personnel Not on Payroll (VI.B.3)

Operating Procedures for Misconduct Screenings

WEBSITE ADDRESS FOR THIS POLICY

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

HISTORY AND UPDATES

August 1, 2022: Expanded Background Checks to current Employees and appointments to positions defined in the policy on Appointments for Personnel Not on Payroll (VI.B.3). Added requirement for Sex and Violent Offender Registry Checks on student and graduate student positions. Clarified the expectation that outside staffing agencies meet the requirements of this policy. Included language regarding registry checks at regular intervals on all current Employees. Linked to new procedures for misconduct screenings.

September 21, 2016: Contacts and Related Documents, Forms and Tools sections updated.

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.

 

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