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1 CSCU Pre-employment Background Verification Policy BR# 16-04 01-21-2016
Introduction/Purpose:
The Connecticut State Colleges and Universities System (“CSCU”) is committed to providing a safe
learning and working environment for its students, faculty and staff. Therefore, in order to ensure the
hiring of employees of the highest integrity and to maintain a safe educational community, the CSCU
System, comprised of its seventeen institutions and the System Office, 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.
Scope:
Upon adoption by the Board of Regents for Higher Education, all full-time and part-time external
candidates for employment with a CSCU institution or the System Office, as well as potential re-hires
with a break in service of more than one year, shall undergo a pre-employment background investigation
pursuant to this policy as part of the employment screening process. This policy covers all full-time and
part-time employees, including University Assistants, Educational Assistants, Adjuncts/Lecturers and
other temporary and contracted employees.
This policy shall also apply to the following student worker positions (including graduate assistant or
graduate intern positions), beginning with hiring for the fall 2015 semester:
• Resident Assistants;
• Students assigned to the Public Safety Department;
• Students who handle DCL3 data as defined in the CSCU Data Management Standards (DCL3 is
protected confidential data, which comprises identity and financial data);
• Students who have a fiduciary responsibility, handle cash or credit transactions, or have a primary
responsibility related to finance or budget; or
• Students deemed by the institution’s chief human resources officer to be in safety- or security-
sensitive positions.
It is understood that there is movement in the CSCU workforce between institutions (including the
System Office) due to transfer and promotional opportunities, as well as dual employment situations.
This policy applies to these situations as detailed below:
The following CSCU employees shall be covered by this policy:
• CSCU employees who apply for and are offered a transfer or promotional opportunity to a
different CSCU institution and have not already undergone a background investigation.
• CSCU employees who are candidates for transfer or promotion to a management/confidential
professional position.
• CSCU employees who are candidates for transfer or promotion to positions that handle DCL3
data, have a fiduciary responsibility, handle cash or credit transactions, or have a primary
responsibility related to finance or budget.
The following CSCU employees shall not be covered by this policy:
• CSCU employees who apply for transfer or promotion within the same institution.
• CSCU employees who transfer to or become dually employed at a different CSCU institution and
have already had a background investigation done at the former CSCU institution.
• Former CSCU employees who are rehired at the same or different CSCU institution after a break
in service of less than one year and have already undergone a background investigation.
Policy:
No external employment candidate may begin work for an institution or the System Office 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
human resources officer at the institution, or the Vice President for Human Resources at the 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 institution or the 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 human resources officer at the
institution, or by the Vice President for Human Resources at the System Office. Access to the background
investigation report shall be handled with the strictest confidence and be limited to the President and
the chief human resources officer or their designees at the institution or the President of the Board of
Regents for Higher Education or Vice President for Human Resources at the System Office or their
designees.
Procedure:
The CSCU System shall select and contract with an approved background investigation vendor. All
institutions and the System Office must utilize the approved designated background investigation vendor
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 institution or the System Office. Applicants who have
been designated as finalists for positions will be provided a disclosure and will be required to consent to
a background investigation. Applicants will be required to provide information for use by the approved
background investigations vendor. The institution’s or System Office’s chief human resources officer or
designee will initiate all background investigations.
2. Collecting Background Information
Before awarding the position, the institution or System Office will conduct the following Level I pre-
employment background check of all candidates (for non-student worker positions):
Level I Screening
• Social Security Trace or SSN Validation: CBSV (Consent Based SSN Verification);
• Prior Employment Verification (prior 7-10 years);
• Education Verification (highest degree attained or highest education level if no degree attained);
• Professional Reference Checks;
• County/Statewide Criminal Search (where lived, worked, attended school – as obtained from
disclosure form or Social Security Trace);
• Federal Criminal Search (where lived, worked, attended school – as obtained from disclosure
form or Social Security Trace); and
• Multi-Jurisdictional Criminal Search (includes National Sex Offender).
Before awarding the position, the institution or System Office will conduct the following Level II pre-
employment background check on all candidates for executive-level positions (Dean and above) and at
the option of the institution or System Office other positions that direct a substantial operational unit as
designated by the institution’s or System Office’s chief human resources officer or president:
Level II Screening
for Executive–Level Positions
• Includes all elements of the Level I Screening; AND
• Motor Vehicle Record;
• State/Federal Civil Litigation;
• Credit Verification (in accordance with state and federal laws); and
• Media Search.
Before awarding the position, the institution or System Office will conduct the following Level III pre-
employment background check on all candidates for the following student worker positions (including
graduate assistant or graduate intern positions): (1) Resident Assistants; (2) Those in the Public Safety
Department; (3) Those who handle DCL3 data as defined in the CSCU Data Management Standards; (4)
Those who have a fiduciary responsibility, handle cash or credit transactions, or have a primary
responsibility related to finance or budget; or (5) other positions that are deemed by the institution’s
chief human resources officer to be safety- or security-sensitive positions:
Level III Screening
for Student Workers
• Social Security Trace or SSN Validation: CBSV (Consent Based SSN Verification);
• County/Statewide Criminal Search (where lived, worked, attended school - as obtained from
disclosure form or Social Security Trace);
• Federal Criminal Search (where lived, worked, attended school – as obtained from disclosure
form or Social Security Trace); and
• Multi-Jurisdictional Criminal Search (includes National Sex Offender )
In addition, candidates for designated positions may also be subject to the following types of screenings,
depending on the requirements of the position:
Position-Specific Screening
• Motor Vehicle Record (for positions that require driving as part of the job);
• Credit Verification (for positions that have a fiduciary responsibility, handle cash or credit
transactions, or have a primary responsibility related to finance or budgets, in accordance with
state and federal laws);
• Professional Licensing Check (for any positions that require a professional license); and
• International Screening – criminal search and credential verification, as needed.
Prior employment verification, education verification, professional reference checks and media searches
may be conducted by the background investigations vendor or the institution/System Office at the
option of the institution/System Office.
3. Use of Background Investigation Results
Listed below are examples of factors that may disqualify an applicant for employment. This list is not an
all-inclusive list, but is provided merely as 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: 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 an
institution 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 thereunder 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 institution or System Office receives information in a consumer report that will potentially
disqualify a candidate from consideration, the institution or System Office will comply with the following
FCRA protocol:
• The candidate shall be sent a letter notifying him/her that the institution or 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 and any relevant state required forms.
• 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 institution or System Office shall send
the candidate a second letter rejecting his/her candidacy based on the disqualifying information
generated by the consumer report.
Services of the approved background investigation vendor may be utilized to produce the adverse action
notifications, or the institution or the System Office, may produce the notifications themselves.
5. Record Retention:
All information obtained, as part of a background investigation, shall be held in strictest confidence.
Documentation of a successfully completed background investigation shall be retained for the
appropriate retention period for employment records promulgated by the State of Connecticut and by
institution or System Office personnel search policies and procedures. The detailed background
investigation report shall be retained by the approved background investigation vendor in compliance
with state and federal retention requirements and 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:
a. Criminal Convictions: The institutions and the 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 three 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.
Notification of rejection of employment will be sent via registered mail and will specifically
describe the evidence presented and state the reason(s) for disqualification.
b. Pending Criminal Charges: If the institution or System Office becomes aware that the
applicant has criminal charges that are currently pending, but no court disposition has yet
been made, the institution or System Office shall assess the criminal charges on a case-by-
case basis to determine if the charges are job-related or would otherwise impact the potential
employee’s ability to serve in the position.
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.
c. Accelerated Rehabilitation: The institution or System Office is not prohibited from
considering accelerated rehabilitation or other alternative dispositions when evaluating an
applicant. The institution or System Office shall consider the accelerated rehabilitation as it
would a pending charge.
d. 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.
e. 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 shall not be a solely
determining factor in denying employment.
7. Prior State of Connecticut Service:
When a candidate’s employment history includes prior service with the State of Connecticut, a
reference must be obtained from the candidate’s employing state agency(ies). Such reference
shall be obtained by the human resources office of the prospective employer from the human
resources office(s) of the prior state employer(s), reduced to writing, made a part of the record,
and retained as specified herein. No screening shall be considered complete without such
written record(s).
Statutory/Administrative Regulation:
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
