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Diocese
of Bridgeport
Policy for Conducting Background Checks
on Employees, Volunteers and Contract Employees
Policy
It is
the intent of the Diocese of Bridgeport in compliance with the Charter
for Protection of Children and Young People to provide a safe environment
for all children serviced by the Diocese.
Given
this, all employees, volunteers and on premise contract employees age
18 and over must submit to a background check prior to commencing employment,
volunteer work or initiating services with any entity of the Diocese of
Bridgeport. All checks will include a review of the applicant's history
relative to any record of criminal convictions. Additional checks may
be completed to validate social security number, degree(s), driver license,
reference checks and/or credit history check. The items reviewed are determined
by pre-established criteria for background checks as they relate to the
position or services potentially being completed by the individual. A
signed authorization to complete the check(s) must be obtained from the
individual prior to initiating the process.
Contracts
with organizations to provide services in any of the Diocesan Schools
or any Diocesan institution primarily servicing youth and/or children
will include the requirement that the organization providing the service
has conducted criminal background checks on their employee(s) assigned
to the Diocese. A contract or vendor employee will not be assigned to
the Diocese unless they have successfully completed that check. In the
event that the organization does not have a process for completing criminal
background checks, they may utilize the process in place within the Diocese
of Bridgeport. The expense of these background checks will be the responsibility
of the Contractor.
The diocese
and its entities have the right to deny an applicant employment, the opportunity
to volunteer or decline a contract employee based on their not completing
these items and/or adverse information obtained thought the background
check process.
If an
applicant is denied employment, the opportunity to volunteer or the opportunity
to provide services based on adverse information, in compliance with the
Fair Credit Reporting Act 15 U.S.C. 1681-1681U, as amended by the Consumer
Credit Reporting Reform Act of 1996, the Diocese will send a Notice of
Adverse Action to the individual along with the report and a copy of their
rights.
Procedure
Current
Employees
1.
Prior to conducting any background check an authorization form must
be obtained from the individual authorizing the completion of the check.
2.
All completed forms should be kept in a secure location under lock
and key. Forms should be kept in a general file labeled as Background
Checks with the year the checks were conducted on the label. No authorization
forms should be retained in employee personnel files.
3.
Effective with this policy current teachers, grand-fathered from background
checks in 1997, are no longer grand-fathered. This group may complete
their background check via the current fingerprinting process being
used by the Diocese of Bridgeport Education system or via a MYB authorization
form.
4.
The areas to be investigated for any employee will be based on the position
the employee holds. The criterion for all is as follows:
All
Positions:
Positions
with Financial Responsibility add:
Positions
with responsibility for driving on behalf of the diocese:
5.
Results for all background checks go only to the Director of Support
Services. In the event the background check does reveal a problem each
case will be assessed individually on the merits of the information
relative to the position held. The Diocese Director of Support Services
will do this evaluation along with the Diocese General Counsel. Any
checks that divulge information regarding crimes against children or
sex crimes will result in the candidate not being eligible for employment.
The Director of Support Services will notify the individual location
of the decision
6.
If the background check does reveal a problem in any category that
results in a decision not to continue employment of the individual a
notice of Adverse Action must be sent to the employee along with a copy
of the report from MYB and a copy of the individual's rights. See
Adverse Action Form for Employees provided.
7.
If the employee believes misinformation exists on the report they should
work through MYB to resolve any information issues and notify the Director
of Support Services that they are disputing the report.
8.
If a corrected and 'clean' report is obtained the employee may continue
their employment. If a corrected or 'clean' report is not available
then, the decision will stand and the individual will not be allowed
to continue their employment.
9.
After completing the background check MYB will invoice the requesting
location for checks completed on their behalf.
10.
All correspondence relative to this process should be filed by year
in a separate topic file for background checks and not retained in the
personnel files. All records will be retained for a period of 30 years.
All files should be kept in a secure location, with limited access,
under lock and key.
New
Employees
1.
All applicants must sign an authorization for the completion of a background
check at the time they complete an employment application and prior
to any interviews. See Employee release form provided.
2.
An employer should conduct their normal interviews and selection process
identifying a final applicant(s) as they normally would without any
consideration to the background check process.
3.
Upon identification of the final applicant(s), and prior to extending
an offer of employment, the employer will order a background check be
completed. Prior to conducting any background check an authorization
form must be obtained from the individual authorizing the completion
of the check.
4.
All applicants for positions within the Diocese of Bridgeport Education
System will be background checked via fingerprinting. Fingerprint cards,
with instructions, will be obtained from the office issuing the application
forms.
5.
All completed forms should be kept in a secure location under lock and
key. Forms should be kept in a general file labeled as Background Checks
with the year the checks were conducted. No authorization forms should
be retained in employee personnel files.
6.
The areas to be investigated for any applicant will be based on
the position being applied to. The criterion for all is as follows:
All
Positions:
- State
Criminal Check
- Social
Security Number Tracing
- Education
Verification, if the position requires a degree
Positions
with Financial Responsibility add:
Positions
with responsibility for driving on behalf of the diocese:
7.
If the background check does not reveal any problem a written offer
of employment can be extended.
8.
Results for all background checks go only to the Director of Support
Services. In the event the background check does reveal a problem each
case will be assessed individually on the merits of the information
relative to the position held. The Diocese Director of Support Services
will do this evaluation along with the Diocese General Counsel. Any
checks that divulge information regarding crimes against children or
sex crimes will result in the candidate not being eligible for employment.
The Director of Support Services will notify the individual location
of the decision. The individual location will only be told to hire or
not hire. They will not be given any details regarding the decision.
9.
If the background check does reveal a problem in any category that results
in a decision not to employ of the individual a notice of Adverse Action
must be sent to the applicant along with a copy of the report from MYB
and a copy of the individual's rights. See Adverse Action Form provided.
10.
If the applicant believes misinformation exists on the report they should
work through MYB to resolve any information issues and notify the Director
of Support Services that they are disputing the report.
11.
If a corrected and 'clean' report is obtained the manager may extend
an offer of employment. If a corrected or 'clean' report is not available
then, the manager should stand by their decision to not extend an offer
of employment.
12.
After completing the background check MYB will invoice the requesting
location for checks completed on their behalf.
13.
All correspondence relative to this process should be filed by year
in a separate topic file for background checks and not retained in the
personnel files. All records will be retained for a period of 30 years.
All files should be kept in a secure location, with limited access,
under lock and key.
14.
Individual locations will conduct work and personal reference checks
on their own.
Volunteers
1.
Prior to conducting any background check an authorization form must
be obtained from the individual authorizing the completion of the check.
2.
All potential volunteers must sign an authorization for the completion
of a background checks at the time they sign-up for volunteering and
prior to commencing any volunteer duties. See ChoicePoint release
form provided.
3.
Prior to the volunteer initiating work the office managing the volunteer
will order a background check be completed.
4.
The areas to be investigated for any applicant will be based on the
position being applied to. The criterion for all is as follows:
All
Positions:
- State
Criminal Check
- Social
Security Number Tracing
Positions
with Financial Responsibility add:
Positions
with responsibility for driving on behalf of the diocese:
5.
Results for all background checks go only to the Director of Support
Services. In the event the background check does reveal a problem each
case will be assessed individually on the merits of the information
relative to the position held. The Diocese Director of Support Services
will do this evaluation along with the Diocese General Counsel. Any
checks that divulge information regarding crimes against children or
sex crimes will result in the candidate not being eligible for volunteering.
The Director of Support Services will notify the individual location
of the decision. The individual location will only be told to allow
the person to volunteer or not volunteer. They will not be given any
details regarding the decision.
6.
If the background check does reveal a problem that results in a decision
to not allow the individual to volunteer a notice of Adverse Action
must be sent to the individual along with a copy of the report from
Choicepoint and a copy of the individual's rights. See Adverse Action
Form for Volunteers provided.
7.
If the individual believes misinformation exists on the report they
should work through Choicepoint to resolve any information issues and
notify the Director of Support Services that they are disputing the
report.
8.
If a corrected and 'clean' report is obtained the individual may volunteer.
If a corrected or 'clean' report is not available then, the decision
will stand and the individual will not be allowed to volunteer.
9.
After completing the background check ChoicePoint will invoice the requesting
location for checks completed on their behalf.
10.
All correspondence relative to this process should be filed by year
in a separate topic file for background checks and not retained in the
personnel files. All records will be retained for a period of 30 years.
All files should be kept in a secure location, with limited access,
under lock and key.
Contract
Employees
1.
All contracts or service agreements will include the language, "Prior
to commencing services all employees routinely on the premise of _______________
will submit to a criminal background check at the contractor's expense.
Acceptance onto the premise at________________ is contingent upon successful
completion of this check."
2.
The Contractor will not place any employee in a Diocesan location that
has not successfully completed the criminal background check search.
Any employee convicted of a sex crime or crime against children will
not under any circumstances be placed in employment at a Diocesan location.
If the contractor does not have a Criminal Background Search service
searches can be completed via the Diocese using Choicepoint. All expenses
associated with the Diocese conducting the search will be billed back
to the Contractor or credited on their invoice.
3.
The Contractor will assume responsibility for providing their employee
an Adverse Action Notice if it is determined that an employee if negative
results are returned.
4.
It is the Contractor's responsibility to maintain compliance relative
to the Fair Credit Reporting Act and the Consumer Credit Reporting Reform
Act of 1996 relative to their employee.
5.
All correspondence relative to this process should be filed by year
in a separate topic file for background checks and not retained in the
personnel files. All records will be retained for a period of 30 years.
September
2004
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