CRIMINAL BACKGROUND CHECK AT POINT OF HIRE

 

Focus of Check

All Merit, Professional and Scientific, faculty, and student staff positions, temporary or regular, that are designated security-sensitive at the time of hiring by the appropriate Dean or Vice President are checked.  Security-sensitive positions may include, but are not limited to, those meeting one or more of the following criteria: 

·         access to secured or sensitive areas including, but not limited to, those containing cash or financial receipts, or confidential documents

·         access to select agents (biological agents or toxins) and/or controlled substances

·         patient and/or child and/or dependent adult population contact

·         cash/check handling and/or processing responsibilities

·         financial management and/or payroll processing responsibilities

·         security responsibilities

·         performance of duties related to critical infrastructure services or significant health or safety responsibilities

·         access to information technology: “root” or “administrator” access level to enterprise systems, “administrator” access level to institutional databases, unsupervised physical access to critical infrastructure services or systems such as telephone switch equipment, networking routers and switches, and data centers

·         supervisory duties related to the above.

 

Scope of Check

The Human Resources Senior Leadership Representative in each college or division uses the designated University vendor to verify Social Security Number and conduct a criminal background check to include all counties and states of residence for the past seven (7) years, in addition to a federal criminal background check for this time period.  As appropriate in individual instances, an alternate designated by the Vice President or Dean conducts the check.  Individual departments, in consultation with the HR Senior Leadership Representative, may have more comprehensive background check guidelines.  Background checks for access to select agents will be conducted by the Department of Justice.

 

Designation, Notice and Timing of Check

1.        At the time of a vacancy, positions are evaluated by the hiring department in consultation with the HR Senior Leadership Representative and a recommendation is made to the appropriate Dean or Vice President whether the duties and responsibilities are such that the position should be designated security-sensitive. If the Dean or Vice President determines the position is security sensitive then the position is so indicated on the requisition.  Candidates are informed during the interview stage that employment at the University of Iowa in this security-sensitive position is contingent on a successful criminal background check.  The department secures from each candidate, at the close of the interview, a signed release for information and declaration of conviction history, which permits the HR Senior Leadership Representative to conduct a criminal background check on the candidate(s) of choice.  The release form can be downloaded at (URL).  Checks must be conducted only on the candidate(s) of choice.

 

2.        If the offer letter is given to the candidate of choice(s) prior to completion of the background check, the offer letter reiterates that a criminal background check is being conducted and that University of Iowa employment in this security-sensitive position is contingent on a successful outcome.

 

3.        The HR Senior Leadership Representative conducts a criminal background check through the designated University vendor upon selection of the candidate(s) of choice and completes a standard check no later than 15 days following the candidate’s first day of employment.  A more comprehensive check may require a longer period of time. 

 

Documentation and Record Keeping

1.        Departments identify on the human resources transaction (appointment or transfer) whether the position is security sensitive and, if so, whether the criminal background check has been completed.

 

2.        HRIS departmental reports indicate incomplete criminal background checks.  HR Senior Leadership Representatives are responsible for reviewing these criminal background check reports on a bi-weekly basis.

 

3.        The HR Senior Leadership Representative maintains all acquired and supporting documentation in a confidential and secure location.

 

4.        University Human Resources and the Provost Office will conduct an annual audit on positions checked and scope of checks to ensure reasonable consistency between colleges and divisions.

 

Existence of a Criminal Record

1.        When the check reflects a criminal conviction, the HR Senior Leadership Representative evaluates the conviction to determine the nexus to the position.  Such information in possession of the University for purposes of evaluating employment is not considered to be public record and should be treated as a confidential personnel matter.

 

2.        The HR Senior Leadership Representative presents the evaluation of the information to the Dean or Vice President.  When the Dean or Vice President determines that a nexus to the position exists, the Dean or Vice President makes a recommendation to University Human Resources (or the Office of the Provost, in the case of faculty).  University Human Resources (or the Office of the Provost) evaluates the information and makes a final decision regarding the nexus to the position.

 

3.        When the conviction has been determined to have a nexus to the position, the HR Senior Leadership Representative discusses the information with the candidate to provide a reasonable opportunity for the individual to provide clarifying information.

 

4.        After the candidate has provided clarifying information (or has not done so after having had a reasonable opportunity to do so), the HR Senior Leadership Representative contacts University Human Resources (or the Office of the Provost, in the case of faculty) to present their final evaluation of the conviction, its nexus to the position, and a recommendation regarding the hire.  University Human Resources (or the Office of the Provost) evaluates available information and, in consultation with the department and college, if appropriate, makes a final decision regarding the hire.

 

5.        If the conviction has significant nexus to the position such that the candidate will no longer be considered for employment, or if already employed should be terminated, the HR Senior Leadership Representative or the Dean/Vice President, if s/he so chooses, provides written notification to the candidate/employee immediately.

 

6.        If a disqualified candidate/employee seeks future employment in a security-sensitive position at the University of Iowa within three months of the last criminal background check, the vendor informs the HR Senior Leadership Representative of the results of the previous check, who takes this information into consideration to evaluate the candidate/employee according to steps 1-5 in this section.

 

7.        If the last criminal background check was conducted more than three months previous, a new criminal background check must be conducted per above.