XXI. Background Checks

The purpose of this policy is to establish consistent and non-discriminatory guidelines for pre-employment background reviews, as part of the selection process for college employees.  Background investigations confirm the candidate's qualifications, credentials and suitability relative to the requirements of the position for which he/she is being considered.  Background reviews are regulated by federal and state statutes, such as the Fair Credit Reporting Act, when the checks are conducted by a contracted party.

This policy applies to all new hires, including adjunct faculty and staff. The level of pre-employment screening is based on the requirements of the position, however at a minimum will consist of verification of identity, and criminal history  and sex offender  background checks. With respect to student applicants (work study and student hourly) background reviews are left to the discretion of the hiring department to determine if a position falls within the category of security or safety sensitive positions based on job responsibilities (i.e.; where there is the potential for unsupervised contact with vulnerable populations).

The Office of Human Resources will assist the hiring department in determining the appropriate level of background review based on the level of exposure and risk factors associated with the position's responsibilities. The Office of Human Resources is responsible for maintaining a continuing contract for background investigating services with a reputable external firm. Employment is contingent on the successful completion of the background review process.  Holyoke Community College may refuse to hire the finalist, may rescind an offer of employment of a finalist, or may review and terminate the employment of a current employee not successfully completing the background review process

Background Checks Definitions: ·        
Adverse Action Notice:  To withdraw the applicant from consideration, the hiring department must send an Adverse Action Notice that includes a copy of a statement of consumer rights under the Federal Fair Credit Reporting Act (FCRA). 

Credit History Check: Checking the credit history of the selected applicant or employee.  (Federal laws prohibit discrimination against an applicant or employee as a result of bankruptcy).  Credit reports qualify as consumer reports under the Federal Fair Credit Reporting Act (FCRA).  An applicant must provide his/her consent for a credit check.

Criminal Background Check:  Verifying that the selected applicant or employee does not have any criminal conviction or pending criminal matter in any jurisdiction where the applicant or employee currently resides or has resided that would disqualify him/her from holding the position. The College will continue to conduct CORI in Massachusetts.

Education Verification:  Ensuring the selected applicant or employee possesses all educational credentials beyond high school listed on the application, resume or cover letter or otherwise cited by the applicant that qualify the individual for the position sought.  The highest degree declared on the application will be verified.  In addition, where appropriate, the process will include verification of any subordinate degree, license, certificate, or other academic credentials required for the position.  An applicant recommended for hire may be required to submit official transcripts as proof of college degrees, when the attainment of the position is based upon the candidate having certain academic credentials.

Employment Verification:  This verification should include dates of employment and reasons for leaving each position.    

Motor Vehicle Record:  Obtaining information on an individual's accident history, convictions for moving violations, license suspensions or revocations, and personal information including name, birth date and address of the individual (if needed). This includes any motor vehicle drivers licenses required for driving positions. 

Pre-Adverse Action Notice:  
When a background check report indicates potentially disqualifying information, the hiring department must provide the applicant with a Pre-Adverse Action Notice that sets the basis for the disqualification with a copy of the report and a copy of a statement of consumer rights under the Federal Fair Credit Reporting Act (FCRA). 

Professional Licenses:  Verifying that the selected applicant or employee possesses all the licenses listed on the application, resume or cover letter or otherwise cited by the applicant that qualify the individual for the position sought, including verification of the disposition of such licenses. 

Reference Check Process:  Contacting prior employers or co-workers who are specifically identified by an applicant, as references that could provide information on the applicant's work history, experience, skills and knowledge needed for the position.  Verifying past employment, work habits and skills is currently done in-house.  Applicants must be informed that reference checks will be made before employment offers are final.

Security Sensitive Positions:  Positions with the potential to expose the college to extensive liability and are designated as such by Holyoke Community College.

Sex Offender Registry Check:  Verifying that the selected applicant or employee does not have any sex offenses. The College will continue to conduct SORI checks in Massachusetts  ·        

Social Security Trace:  Currently using E-Verify.

 

Holyoke Community College
303 Homestead Ave. Holyoke, MA 01040
(413) 538-7000