The Catholic University of America

Employment: Faculty and Staff
Background Investigation Policy

Approved by: President and His Council  
History: Issued   -- November 22, 2011  
  Revised --  
  Additional History
Related Policies:
Additional References:  
Responsible Official: Associate Vice President and Chief Human Resources Officer, tel. (202) 319-5598
I.     Introduction
The Catholic University of America is committed to preserving the safety of the campus community and the integrity of the institution by taking appropriate steps to protect its people, property and other assets. To that end, the University will perform background investigations as part of its hiring processes for all staff and for all regular full-time faculty hired after the implementation date of this policy. Background investigations will be performed on current employees only in very limited situations, such as where needed as part of an investigation into an incident or allegation, where safety or security is a concern, or when a current employee applies for a new position.
II.     Definitions
A.   Finalist Candidate means an applicant who is being considered for employment.
B.   Background Investigation ordinarily means to check the criminal or other histories of applicants to a designated position. It can include, but is not limited to the following: educational record verification, license verification, employment history verification, professional references, driving record check, social security number tracer, credit history, sex and violent offender registry check, and checks for misdemeanor or felony convictions. Driving records per se will only be checked if driving is required as a job function. 
A criminal history check in the individual’s prior countries of residence will be conducted only if the individual’s visa and/or authorization to work in the United States was issued before implementation of the PATRIOT Act on October 24, 2001. The University will not require that a criminal history check be conducted in the individual’s prior countries of residence if the visa or authorization to work was issued or renewed under the provisions of the PATRIOT Act.
C.   Employee includes full and part-time faculty and staff. Employee for purposes of this policy also includes priests or other non-student individuals living in Residence Halls (e.g. spouses of staff living in residence halls). Full-time students who are temporary part-time employees will not ordinarily be subject to this policy.
III.    Coordination of Background Investigations
A.  Role of Human Resources
The Office of Human Resources shall coordinate background investigations for finalist candidates and for other limited situations where a background investigation is necessary for safety or security. Additional background investigations are conducted for campus police officers under the direction of the Director of Public Safety. The type of background investigation that is to be performed shall be based on the requirements of the position/situation and will be at the discretion of the Chief Human Resources Officer in consultation with the cognizant Vice President or Provost overseeing the specific position. All background investigations must be coordinated through the Office of Human Resources, except those conducted in conjunction with an external academic affiliation program (e.g., clinical experiences for nurses or social workers).
Background results are not an automatic bar to employment at the University. Background investigation results will be used only to determine the finalist’s qualifications and suitability for employment, and will not be used to discriminate on any basis protected by applicable law.
B.   Notification and Authorization from Applicants
All finalist candidates will be informed of the University's intent to obtain a background investigation. Applicants and employees will be specifically notified and will be asked to sign an electronic authorization form for any background investigation considered an "investigative consumer report" as defined in the Fair Credit Reporting Act (15 USC §1681a). In the event of unsatisfactory background investigation results, the candidate will be provided with notice of the unsatisfactory result, a copy of the report, and a summary of rights under the Fair Credit Reporting Act.
C.   Time Frame for Performing Background Investigations
In those cases where necessity demands employment prior to the time frame in which the background investigation can be obtained, continued employment remains contingent on background investigation findings that are satisfactory to the University.
D.   Disposition and Retention of Background Investigation Documents
Documents with results of background investigation findings will not be stored or maintained by the University unless there is a legal reason for doing so. Any stored documentation will either be encrypted or printed out and kept in a locked file in the Office of Human Resources and/or the Department of Public Safety as necessary. Specific results will not be given to departments; managers will be told only that the applicant has satisfactory or unsatisfactory background investigation results.