Human Resources - Pre-employment Background Verification Policy at the Connecticut State University System
The Connecticut State University (“CSU”) System and its four universities value their reputation for honesty and integrity. Therefore, in order to ensure the hiring of employees of the highest integrity and to maintain a safe university community, the CSU System and its four universities will conduct pre-employment background investigations on all individuals for whom employment is to be tendered. This policy sets forth the requirements and guidelines for performing such background investigations.
All regular, full-time and part-time external candidates for employment with a CSU university or the CSU System Office, as well as potential re-hires with a break in service, must undergo a pre-employment background investigation according to this procedure as part of the employment screening process. Full-time and part-time employees including University Assistants, Lecturers and other temporary and contracted employees are covered by this policy.
No external employment candidate may begin work for the University or the CSU System until the appropriate screenings have been completed. The background investigation may reveal certain information that may disqualify the candidate from further consideration for the position. Special circumstances may, on occasion, require an applicant to start work before all pre-employment background checks are completed. Such exceptions may occur only with prior approval by the Chief Personnel Officer at the University, or by the Chief Administrative Officer or Executive Officer for Human Resources at the CSU System Office. Written notification will be sent to the applicant that continued employment is contingent upon completion of a pre-employment background investigation acceptable to the university or the CSU System Office.
Elimination of a candidate from consideration for hiring on the basis of information revealed by the background investigation must be reviewed and approved by the Chief Personnel Officer at the university, or by the Chief Administrative Officer or Executive Officer for Human Resources at the CSU System Office. Access to the background investigation shall be limited to the President and the Chief Personnel Officer or their designees at the University or the Chancellor, Chief Administrative Officer or Executive Officer for Human Resources at the CSU System Office.
The CSU System has selected an approved background investigation vendor. All universities within the CSU System will utilize a background investigation vendor approved by the CSU System for pre-employment background investigations and shall comply with this procedure.
1. Notification & Authorization
Candidates will be informed during the pre-employment process that selection is subject to completion of a background investigation acceptable to the university or the CSU System Office. Applicants who have been designated as finalists for positions will be required to complete a consent form, which requests specialized information for use by the approved background investigations vendor, and an application for employment. The Chief Personnel Officer or designee at the university, or the Chief Administrative Officer or Executive Officer for Human Resources at the CSU System Office, will initiate all background investigations.
2. Collecting Background Information
Before awarding the position, the University or CSU System Office will conduct the following pre-employment background check on all candidates:
- Social Security Verification;
- Prior Employment Verification;
- Education Verification (highest level);
- Residence Verification;
- Criminal Background Investigation – Local, State, & Federal;
- Sexual Offender Database Search.
In addition, candidates for designated positions may also be subject to the following additional types of checks, depending on the requirements of the position:
- Motor Vehicle Record;
- Professional Reference Checks;
- State/Federal Civil Litigation, Lien & Judgments;
- Credit Verification;
- Corporate Filing and Status Search;
- Media Search;
- Professional Licensing Check.
University and CSU System Office human resources departments will maintain a summary of job classifications and applicable categories of inquiry that may be amended as necessary by the university or CSU System Office as needs and requirements may evolve.
3. Use of Background Investigation Results
Listed below are examples of factors that may disqualify an applicant for employment (this is not an all inclusive list, merely examples):
- Inconsistency of information provided by the candidate versus that obtained by the background investigation. (Examples might include, but not be limited to, significant differences in prior employment dates, education obtained, or licenses held.)
- Omissions of significant information by the candidate. (Examples might include, but not be limited to, failure to disclose being dismissed for cause or loss of certifications qualifying the applicant for the position.)
- Unsatisfactory information uncovered by the background investigation. (Examples might include, but not be limited to the following: Recent felony or misdemeanor convictions related to the position applied for; unsatisfactory job performance on a prior job; poor attendance or disciplinary problems on a prior job; record of moving violations (for a job requiring driving a University or state vehicle); credit history that would indicate an inability to manage finances or which would create undue personal financial pressure (for jobs handling management of significant financial resources).
4. Fair Credit Reporting Act (“FCRA”) Compliance:
The FCRA and the regulations promulgated there under are intended to give a candidate for employment the opportunity to correct any factual errors in his or her consumer report, as defined in the FCRA, before an adverse employment action is taken. The candidate must be provided notice of any disqualifying information revealed by the consumer report, including, but not limited to, credit history information, and a reasonable period of time to correct discrepancies.
When the university or CSU System Office receives information in a consumer report that will disqualify a candidate from consideration, the university or CSU System Office will comply with the following FCRA protocol:
- The candidate shall be sent a letter notifying him/her that the University or CSU System Office has received disqualifying information from the consumer report.
- To the letter shall be attached a copy of the report and a summary of the candidate’s rights under FCRA.
- The notification shall be sent to the candidate before any adverse employment action may be taken based on the consumer report.
- After five (5) business days, barring the receipt of any new information that changes or clarifies the consumer report and eliminates any discrepancies, the university or CSU System Office shall send the candidate a second letter rejecting his/her candidacy based on the disqualifying information generated by the consumer report.
5. Record Retention:
All information obtained, as part of a background investigation, shall be held in strictest confidence. Documentation shall be retained for the appropriate retention period for employment records promulgated by the State of Connecticut and by university and CSU System Office personnel search policies and procedures. Such records shall not be included in an employee’s personnel file. Unauthorized disclosure of information gathered through the background investigation will not be tolerated and may subject the discloser to disciplinary action.
6. Use/Review Criteria:
- Criminal Convictions: The universities and the CSU System Office will not knowingly hire applicants who have been convicted of job-related crime within the allowable reportable time period for reporting such offenses. This time period is normally seven (7) years. This also applies to those situations when the date of disposition, release, probation, or parole (whichever is most recent) relating to the crime occurred within the past seven (7) years.
Pursuant to Connecticut General Statutes Sections 46a-79 and 46a-80, in determining whether conviction of a criminal offense will disqualify an applicant for a particular position, the following factors will be considered:
- The nature of the offense and its relationship to the position;
- The degree to which the applicant has been rehabilitated; and
- The length of time elapsed since conviction.
- Pending Criminal Charges: If the university or CSU System Office becomes aware that the applicant has criminal charges that are currently pending, but no court disposition has yet been made, the university or CSU System Office shall assess the criminal charges on a case-by-case basis to determine if the charges are job-related.
Pursuant to Connecticut General Statutes Section 46-80(d), no record of arrest that was not followed by conviction, or record of conviction that has been erased, shall be considered in connection with an application for employment.
- Accelerated Rehabilitation: The university or CSU System Office is not prohibited from considering accelerated rehabilitation or other alternative dispositions when evaluating an applicant. The university or CSU System Office shall consider the accelerated rehabilitation as it would a pending charge.
- Motor Vehicle Records Check: Motor vehicle records which evidence a revoked or restricted driver’s license, invalid driver’s license, or traffic violations (including, but not limited to, alcohol-related violations) shall be reviewed as they relate to positions requiring driving duties and in conjunction with all other factors disclosed by the background investigation.
- Credit History: An applicant’s credit history shall be reviewed as it relates to jobs requiring financial responsibilities. An applicant’s credit history shall be considered in conjunction with all other factors disclosed by the background investigation and alone shall not be a determining factor in denying employment.
Fair Credit Reporting Act - Connecticut General Statutes, Sections 31-51i, 46a-79, 46a-80, 46a-80(d), 46b-146, 54-760, 54-142a
Responsible Function Area: Office of Human Resources