Policy & Procedure No. HR-020
Northshore Technical Community College
Title:
Background Checks
Effective Date:
11/11/2013
Last Revision Date: 10/24/2013
Cancellation:
Office:
Human Resources (HR)
Background Checks
I. PURPOSE
Northshore Technical Community College (NTCC) strives to provide the safest possible environment for its
students, faculty, staff, and visitors; to preserve College resources; and to uphold the reputation and integrity of the
College. This policy supports the College’s efforts to minimize institutional risk and assists the appointed authority
in making sound hiring decisions.
II. SCOPE AND APPLICABILITY
This policy applies to:
 Candidates for full-time and part-time faculty and staff, benefits-eligible positions
 Temporary Employees not sponsored by a staffing agency
 Staff
 Faculty
EXCLUSIONS
The following groups are not required to undergo Background Checks in connection with this policy:
 Individuals employed by outside staffing agencies
 Existing employees being hired in an secondary/overload position
 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
 Direct responsibility for the care, safety and security of people, or the safety and security of personal and
College property
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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
College property disbursements or receipts
Extensive authority for committing the financial resources of the College
Direct access to or responsibility for controlled substances or hazardous materials
Direct access to or responsibility for protected, personal or other sensitive data (includes information
systems personnel, Human Resources, Finance, Registrars, etc.)
III. DEFINITIONS
A. Applicants are current, former, or prospective employees who submit information to be considered for
positions at NTCC, including individuals not currently employed by NTCC and current NTCC employees
seeking promotional or transfer opportunities to different positions. This Policy shall apply to all Applicants
for the following types of positions at NTCC:
1. All full and part-time faculty members
2. All classified staff members including classified staff transferring from other state agencies or
institutions of higher education;
3. All exempt professionals.
4. Student employees meeting the definition of Security-Sensitive;
5. Temporary position employees who are in a faculty, exempt professional or classified staff position of
a short-term nature (e.g. six months, semester, academic year, generally do not have continuing
funding, etc.) and
6. Anyone else NTCC employs.
B. Background Check means the process of verifying credentials and other information about an Applicant. Such
verification may include any or all of the following:
1. Employment Verification
2. Education/Academic Verification
3. Professional License Verification
4. Personal/Professional Reference Verification
5. Consumer Credit Report
6. Social Security Number Verification
7. Motor Vehicle Search
8. Criminal History Search
9. Sex Offender Register
C. Consumer Credit Report means the process of gathering and reviewing Applicants detailed credit history, as
contained in a Consumer Report. (Federal laws prohibit discrimination against an Applicant as a result of
bankruptcy.)
D. Conviction means a guilty verdict, a guilty plea or a plea of Nolo Contendere (“No Contest”) of felony or
misdemeanor, other than minor traffic offenses.
E. Criminal History Check means the process of gathering and reviewing criminal history records or information
furnished by a criminal justice agency or third party vendor in the business of obtaining and providing criminal
history records relating to an individual’s criminal convictions. Criminal records include in-state, out-of-state
and international criminal history, including all felony convictions, misdemeanor convictions and related
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activity on record (including open arrest warrants or charges for failure to appear in court).
F. Education/Academic Verification means the process of verifying the applicant’s academic institution to obtain
verification of the highest degree earned reported by the applicant.
G. Employment Verification means the process of verifying the applicant’s employer(s), title(s), and dates of
employment within the last ten years or with the last three employers if the candidate has been with the last
employer for ten or more years. If available, reasons for termination, rehire status, and job performance
information for each employer will be collected.
H. Final Applicant means a current, former, or prospective employee recommended for hire, transfer or
promotion and to whom a contingent offer will be made.
I.
Motor Vehicle Search will include validation of license, class, status, and expiration date. Accident and
violations on record will also be gathered and reviewed.
J. Personal/Professional Reference Verification means the process of conducting personal and professional
reference verifications based upon references reported by the Applicant.
K. Privileged Access are rights to computer or application systems that have been granted to an individual beyond
that of a typical user that can bypass, modify, or disable technical or operational security controls. Examples
may include the ability to install software; install or modify system processes; create or modify system
configurations; create or modify system access controls; and/or view or control the screen of the user through
remote access technologies in order to assist them.
L. Professional License Verification means the process of verifying through issuing state authority license or
certificate status.
M. Promotion means job advancement, title enhancement, and/or pay increase action or process open to current
NTCC employees which involve increased and/or different job duties and responsibilities. For classified staff
positions, a promotion occurs when the employee is appointed to a class with a higher pay grade maximum
than his/her current or previous position. For exempt professional positions, a promotion occurs when the
employee accepts a higher-level job title or is appointed to a job title with a higher salary. For the purpose of
this Policy, a promotion does not include appointments built into a current position, e.g., academic progression
from assistant professor to associate professor. Background checks will not be required in such cases.
N. Security-Sensitive means work that meets one or more of the following criteria:
1. Responsibility for patient, animal or child care in a child care center as defined by state law;
2. Access to “select agents or toxins” or “controlled substances” as defined under state and federal law;
3. Access to secured facilities as determined at the sole discretion of Human Resources in consultation
with the appropriate Dean or Appointing Authority as needed;
4. Positions that serve a Vulnerable Population Program;
5. Primary responsibility for driving a College vehicle; or
6. Positions with information technology responsibilities that meet the criteria for Privileged Access.
O. Sex Offender Register means the process of searching the sex offender database register for any state in which
the Applicant has resided in the last seven years.
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P. Social Security Number Verification process of verifying the Applicant’s social security number and check for
possible multiple SSN and/or aliases (AKA’s). Criminal records will be searched using AKA’s found; previous
locations of residence may be used to determine jurisdictions for criminal record searches.
Q. Transfer refers to a lateral movement in the same job class title and with the same or similar job
responsibilities. A transfer typically involves moving to a position in a different campus department and/or
with a different supervisor.
R. Volunteer refers to an individual who is not an employee or an Applicant, and who is providing a service to
NTCC without expectation of remuneration.
S. Vulnerable Population Program means program activities, including but not limited to academic programs
that include:
1. Working or assisting with programs servicing minors or at-risk adults;
2. Working or assisting in child care facilities;
IV. POLICY
A. Roles and Responsibilities
1. Applicants will:
i. Disclose Criminal Conviction information when applying for a position.
ii. Consent to a Background Check
iii. Provide complete and accurate information in a timely manner.
2. The Department of Human Resources is solely authorized to conduct and oversee the Background
process necessitated pursuant to this Policy on behalf of NTCC and will:
i. Work with law enforcement or contract with outside agencies in executing any of the
obligations set forth in this Policy.
ii. Work with the Hiring Supervisor to identify appropriate Background Check component’s
based upon the position’s responsibilities.
iii. Ensure appropriate Background Check language is incorporated into each job posting.
iv. Provide the Hiring Committee with the appropriate Background Check language to share with
Applicants.
v. Ensure that the appropriate consent forms have been obtained to conduct Background Check.
vi. Ensure that all offers of employment are made contingent upon the results of the Background
Checks
vii. Ensure College compliance with Fair Credit Reporting Act (FCRA), and work directly with
Applicants to provide required FCRA disclosures and notifications.
viii. Update Hiring Committee Chair and Appointing Authority on the status of the Background
Check.
ix. Communicate and provide necessary training regarding this policy.
3. Hiring Supervisors will
i. Assist Human Resources in ensuring that all offers of employment are made contingent upon
the results of the Background Check.
ii. Assist Human Resources in securing the necessary consent from the Applicant.
4. All NTCC employees are responsible for ensuring the integrity and confidentiality of the Background
Check process.
B. Applicant Background Check General Requirements
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1. Consent and Providing False Information. Applicants must consent to a Background Check to be
considered for a position. Any Applicant who refuses to consent to the Background Check, refuses to
provide information necessary to conduct the Background Check, or provides false or misleading
information will not be considered for the position for which s/he has applied. Any Applicant who has
already been hired or promoted and is subsequently found to have provided false or misleading
information related to the Background Check may be subject to disciplinary action, up to and including
termination.
2. When Background Checks Are Conducted. Background Checks are typically conducted after a
single Final Applicant has been identified; however, they may be conducted prior to that time for a
high-profile position where Human Resources, in consultation with the Appointing Authority,
determines that there is potential for NTCC to suffer reputational harm if the check is not conducted on
more than one potential Final Applicant.
3. Offers are Contingent. All offers of employment and continued employment are contingent upon a
satisfactory Background Check. Employment shall not be effective until Human Resources has
notified the department that the Applicant has satisfactorily completed the Background Check.
4. Promotions. Applicants or employees who are otherwise considered for a Promotion shall be subject
to a Background Check, unless Human Resources previously conducted a Background Check
appropriate for the position within the previous three years.
C. Type of Background Check Required
1. Reference Checks must be completed for all Final Applicants.
2. A Criminal History Check must be conducted for Final Applicants, unless a Criminal History Check
has been conducted within the previous three years.
3. Financial History Check must be conducted for Final Applicants for the following positions:
Administrators at or above the Vice Chancellor level; leadership positions at or above the director
level; and positions in College departments with centralized and primary responsibility for significant
College resources. (See Appendix A)
4. A Sex Offender Search must be conducted for Final Applicants for positions in Vulnerable Population
Programs.
5. In compliance with NTCC Safety Manuel, all NTCC Employees who will be permitted to drive while
on state business will be required to have a Motor Vehicle Check conducted.
D. Vulnerable Population Programs
Employees, Volunteers and student employees providing services for a NTCC affiliated Vulnerable Population
Program shall be required to satisfactorily complete a Criminal History Check and Sex Offender Search.
V. BACKGROUND CHECK REVIEWING PROCEDURE
A. Arrests Not Considered, Charges and Convictions are Considered
Human Resources will not consider arrest information unless the arrest resulted in pending criminal charges. In
such circumstances, Human Resources will contact the Applicant, and may contact other parties, to obtain
further information in order to assess reliability of the charge information. Human Resources will consider any
information revealed regarding Convictions, as defined in Section III, although a Conviction shall not
automatically preclude initial or continued employment.
B. Job-relation and Business Necessity Criteria
When considering pending charges and Convictions, Human Resources will evaluate the time frame, nature,
gravity, and relevancy of the Conviction or charge offense as it relates to the job duties and NTCC business
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necessities.
VI. ADVERSE ACTION NOTIFICATION PROCEDURES
If information is revealed in a Criminal Background Check, Financial History Check, or Sex Offender Search
report that could potentially result in an adverse employment decision, Human Resource shall take the following
steps:
A. Pre-Adverse Action Notice
Human Resources will notify the Applicant in writing that negative information was revealed during the
Background Check process which may impact the employment decision and will provide a copy of the
supporting report to the Applicant or employee along with a copy of “A Summary of Your Rights Under the
Fair Credit Reporting Act.” The Applicant or employee will be provided no less than five days to challenge the
information provided in the report and take steps to correct inaccuracies or provide explanation.
B. Decision Stay
A final employment decision shall not be made until the Applicant’s or employee’s new information has been
considered or such time that the Applicant or employee fails to respond as required.
C. Adverse Action Notice
If, after considering any Applicant or employee response, Human Resources determines that the negative
information revealed results in an adverse employment decision, a second written notification will be sent to
Applicant or employee. This notice shall include the following:
 the name, address, and phone number of the vendor Consumer Report Agency (CRA) that supplied
the report
 a statement that the CRA (vendor) supplying the report did not make the decision to take the
adverse action and cannot give specific reasons for it
VII. SECURITY SENSITIVE CONTRACTORS
A. Contractor Responsibility for Conducting Background Check
Contractors performing Security Sensitive work are responsible for conducting Background Checks on all
employees, agents, and subcontractors that provide services to NTCC and, upon NTCC request, certifying
that such employees and agents have satisfactorily completed the Background Check.
B. Required Contract Provision
The following provision shall be included in all contracts with Security Sensitive contractors:
Contractor acknowledges that Contractor’s activities involve heightened risks as a result of access or
exposure by Contractor’s employees or agents to one or more security environments. Contractor
expressly acknowledges that Contractor shall take all commercially reasonable measures to mitigate any
such risks, which measures shall include but are not limited to conducting criminal history checks,
financial background checks when appropriate, and reference checks on all employees or agents who will
be performing work at the College. Upon College request, Contractor shall certify in writing that it has
complied with this provision and that all employees, agents, and subcontractors performing work
hereunder have satisfactorily completed Contractor’s background check.
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Northshore Technical Community College
VII. ACCESS TO AND STORAGE OF BACKGROUND CHECK RESULTS
A. Access
All information obtained through the background check process, including criminal history, is highly
confidential and access to such information is limited to those individuals who have a direct “need to know.”
This may include but is not limited to hiring personnel and those processing employment applications.
B. Storage
NTCC will store hard copies in employee’s private personnel record, locked and secured location with limited
access. Electronically-stored Background Checks results will be password protected and encrypted with
limited password access.
Policy Reference:
Louisiana Revised Statute 15:587.2
Hiring Policies and Procedures -NTCC Policy # HR 008
NTCC Safety Manuel
Summary of Rights Under the Fair Credit Reporting Act
Review Process:
X
X
X
X
Distribution:
Reviewing Council/Entity
Business Affairs Committee
Deans
Chancellor
Review Date
11/05/2013
11/05/2013
11/05/2013
Effective Date
11/11/2013
11/11/2013
11/11/2013
Distributed Electronically via College’s Internet
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NTCC BACKGROUND CHECK POLICY – APPENDIX A
A Financial History Check must be obtained for Final Applicants as outlined below.
Required
Administrators at or above the Vice Chancellor level.
Leadership positions at or above the director level
All positions in College departments with centralized
and primary responsibility for significant university
resources.
Examples
Chancellor & Vice Chancellors
Deans, Chief Officers, Directors
This includes all positions in following departments,
regardless of job title or function:
IT, Finance, Human Resources, and the Office of
Financial Aid.
Not Required
Infrequent or incidental access to cash, checks or
credit/debit card information. Access to finance system
for purposes of conducting university business.
Examples
Access to petty cash in a department. Administrative
Assist responsible for accepting occasional payments in
the form of cash, check, and/or credit card.
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