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effective 10-17-2003
 

Purpose: This policy provides a standard requirement and process for obtaining and evaluating background information in order to make a contingent offer of employment to an applicant or continue the employment of a current employee.

Policy: Offers of employment and continued employment shall be contingent upon obtaining a signed authorization for the procurement of an investigative consumer report (including a criminal background check) for employment purposes and a satisfactory report. Both the authorization and the report are to be filed in the employee’s personnel file or in a master verification file filed by year and alphabetized for applicants not employed. Current employees will be required to authorize and undergo annual investigations.

Who Must Undergo a Background Investigation?

SCHOOLS: All employees, whether part-time, full-time or temporary (i.e. substitute teachers), must have a background investigation completed. All current and prospective volunteers who have regular contact (see note #2) with students, transports students to any school activity, or participates in an overnight activity with students must undergo a background investigation. Examples of volunteers who require a background investigation include, but are not limited to: coaches, assistant coaches, bus drivers, adults who transport students to extra-curricular activities, individuals who read to elementary students and lunch room workers. Volunteer money counters or other volunteers with direct access to school funds/accounts must also undergo a background investigation.

PARISHES & ALL OTHER NON-SCHOOL ORGANIZATIONS: All employees, whether part-time, full-time or temporary, must have a background investigation completed. All current and prospective volunteers that have any opportunity for regular contact (see note #2) with minors, transports minors to parish activities, or participates in an overnight parish activity with minors must also have a background investigation completed. Examples of volunteers who require a background investigation include, but are not limited to: religious education teachers, youth ministry volunteers, and adults who transport minors to functions on behalf of the church. Volunteer money counters or other volunteers with direct access to parish funds/accounts must also undergo a background investigation.

Note:

1. All clergy and women religious who work or volunteer in schools or parishes must undergo a background check.
2. Regular contact with minors is defined as involvement in activities once per month or more.
3. Employees and volunteers who have had a background check completed through the Diocese since 7-1-03 will not be required to complete another one at this time. However follow up background checks may be required in the future.

Any questions regarding whether or not a background investigation is required on someone should be referred to the claims/risk manager at 712-233-7548.

Notice of Investigation
Applicants shall be provided with notice of the policy and practice of conducting background investigations before a candidate is hired.

How to initiate a Background Investigation.
If the applicant is a current or new full-time or part-time employee, then check “Employee” and have the applicant read, sign and date the following Employee/Volunteer Background Investigation Consent. If an applicant is a new or current volunteer, then check “Volunteer” and have the volunteer read, sign and date the Employee/Volunteer Background Investigation Consent. When properly completed, the consent form should be faxed as soon as possible to the claims/risk manager’s attention at 712-233-7598.

All offers of employment or the opportunity to volunteer will be contingent on receipt of an acceptable background investigation. New employees should not be allowed to start until the background investigation has been completed and approved.

What is the Process After the Forms are Faxed to the Claims/Risk Manager?
Upon receipt of a properly completed Employee or Volunteer Background Investigation Consent form, the claims/risk management staff, will enter the employee or volunteer’s information into the ChoicePoint ScreenNow or VolunteerSelect Internet site. All employees and volunteers will undergo the following investigations:

• National Criminal File
• Sexual Offender Search
• Social Security Verification

Prospective employees and volunteers may also undergo additional searches depending on the position for which they are applying. For example, credit files will be checked for those filling bookkeeper, business manager, finance manager, accounting, stewardship, development, school administrator and other positions that have access to school or parish funds and department of motor vehicle records will be reviewed for any position that requires the operation of a motor vehicle for job-related purposes.

Once the information is entered into the Internet site, we should have the completed background report within 24 hours on most searches.

If the report is returned with acceptable findings, the location that submitted the authorization will be advised of the acceptable results.

If the report is returned and it contains items of concern, the report may be reviewed by three or more of the following individuals: the claims/risk manager, the director of personnel/benefits, the operations manager, the Diocesan superintendent of schools, the Chancellor and the Bishop of the Diocese of Sioux City and/or The Corporate Board of the Diocese of Sioux City.

If the report contains adverse information it may become the basis for no longer considering an applicant or employee qualified for employment.

Use of information obtained from a background investigation report will be taken in context with the job for which the applicant has applied or the employee is filling. Adverse information learned from a background investigation report should be considered with all other information known about an applicant or employee and a case-by-case determination should be made as to the applicant’s or employee’s suitability for employment or continued employment. The reviewer(s) may seek clarification from the applicant/employee regarding the adverse information.

Information obtained from the investigation should remain confidential and not be shared with anyone except on a need-to-know basis.

Notice to Applicant/Employee of Adverse Report
Before taking any adverse action based in whole or in part on the report, the applicant or employee will be provided with a copy of the report and a description in writing of the rights of consumers under the Fair Credit Reporting Act, as prescribed by the Federal Trade Commission. Generally, a waiting period of five days should be required between giving this notice and taking any final adverse action.

Once the final adverse action is taken, final notice to the applicant or employee of the action should be given in writing.

Other steps that each entity must follow in making hiring decisions:

1. Contact all former employers listed. This is important even with jobs the applicant had many years ago. Find out if the applicant is eligible for rehire with their former employer. Ask this question every time, as the answer/response will speak volumes about the applicant.
2. Look for inconsistencies when reviewing the dates of employment. A gap in the applicant’s work record could mean that the applicant is trying to hide a former employer who might give the applicant a poor reference
3. Try to determine why the applicant left each of their previous jobs and why the applicant is considering leaving their current employer.
4. Ask former employers about the applicant’s interactions with co-workers, management and customers. Also discuss the applicant’s strengths, weaknesses and achievements.
5. If you determine that an applicant has moved frequently, consider contacting prior landlords or prior churches/schools they volunteered at to see what reasons for relocating other parties may be aware.

Any questions regarding this policy and its interpretation should be referred to the claims/risk manager at 712-233-7548.