210: Background Checks
This policy describes the basic requirements and processes Georgetown University uses to conduct employment related background checks.
Georgetown University takes meaningful and reasonable actions to promote a safe and secure environment for the entire University community. This policy explains the University’s use of background checks to verify credentials, criminal history, credit status, and other information related to employment decisions.
Employees Starting Work On or After April 1, 2012
Candidates who are offered employment in regular and term staff and Administrative and Academic Professional (AAP) positions to start work on or after April 1, 2012 shall have the following background checks completed as a condition of employment with Georgetown University.
- Social Security Number Trace and Address Locator
- Criminal History Check
If relevant for the position, a background check may also include:
- Tax Payment Check
- Education Verification
- Professional License or Certification Verification
- Motor Vehicle Record Check (See University Vehicle Operation Policy)
- Sex Offender Registry
Candidates who are offered employment in temporary or special positions to start work on or after April 1, 2012 must satisfactorily clear a background check if required by local, state, or federal law or the hiring department.
Current Employees as of April 1, 2012
Individuals already employed by Georgetown University as of April 1, 2012, will not be subject to retroactive background checks, except (1) if applying for a promotion or transfer to a position for which a background check is required by local, state or federal law or the hiring department, (2) if transferring from a temporary or special position that did not require a background check into a regular or term position or (3) as otherwise set forth in this policy.
An employee whose relationship to the University is severed-either through resignation or termination but not for an unpaid leave of absence- and who subsequently re-applies, will be considered a new hire.
Other Circumstances Warranting Background Checks
In the event that the University has reason to believe that a University employee has engaged in criminal conduct, conduct that raises questions about his/her ability to execute the duties of the position, conduct that may pose a danger to others, or any other reason deemed sufficient by the University to warrant a background check, the University reserves the right to require the employee to satisfactorily clear a background check as a condition of continued employment.
Process for Conducting Background Checks
Background checks for hew hires, transfers or promotions must be conducted post-offer and pre-employment. All offers of employment shall be made contingent upon satisfactory clearance of the required background checks. At no time should an employee begin work until Human Resources has indicated that the background check has been satisfactorily cleared.
The hiring department is responsible for advising the candidate that the job offer is conditioned upon satisfactory clearance of a background check and for notifying Human Resources to make arrangements for the candidate to authorize the background check. All written offers of employment shall include the following statement: “Your position requires a background check. This offer is conditional upon your consent to and satisfactory clearance of the background check.” Similarly, hiring managers shall advise candidates of this requirement at the time a verbal offer is made.
The Department of Human Resources will obtain background checks through a third-party vendor which shall conduct the background checks in accordance with local and federal law, including the Fair Credit Reporting Act, as amended (FCRA).
Timing and Fees for Background Checks
It usually takes from 3 to 5 business days from time of request for the Department of Human Resources to receive the completed background check report.
The hiring department will be responsible for fees associated with the background check process. The Department of Human Resources will coordinate payment of the vendor’s fees and the billing of departments.
Verification of Background Checks
The Department of Human Resources will receive and review the background check report from the third-party vendor.
If the report reveals no adverse information or unfavorable results, the Department of Human Resources will advise the hiring department that an individual has “satisfactorily cleared” the background check.
If the report includes adverse information or unfavorable results, the Department of Human Resources, in consultation with the hiring department, will make an individualized assessment, taking into account the following:
- the nature of the finding;
- the job for which the applicant is being considered;
- the underlying event(s) that occurred;
- the time elapsed since the finding;
- the applicant’s employment history and other evidence of his or her activities in the intervening time since the finding; and
- other relevant information.
A prior conviction shall not automatically disqualify an applicant for employment, but shall be considered using the criteria identified above.
Based on relevant available information, the Department of Human Resources, in consultation with the hiring department, will determine whether the hire will proceed or the offer will be rescinded.
Adverse Action Notifications and Appeals
If the results of the background check result in a decision to rescind an offer of employment or take other adverse action, the Department of Human Resources will then direct the third-party vendor to send a letter to the candidate, as required by the FCRA, notifying him/her that Georgetown University intends to take an adverse action based on the results of the background check, along with a copy of the background check report and a summary of his or her rights under the FCRA.
If the candidate does not dispute the accuracy of the information contained in the background check report within five days, then the third-party vendor will inform the candidate in writing that the University is rescinding its conditional offer of employment or taking other adverse action. This letter will be accompanied by information and disclosures required by the FCRA.
Georgetown complies with the requirements of the Fair and Accurate Credit Transactions Act of 2003, as amended. If Human Resources receives a notice of address discrepancy from its third-party vendor in response to a background check that informs the University of a substantial difference between the address provided by the post-offer job candidate and the address(es) on file with the third-party vendor, the Department of Human Resources will take reasonable steps to verify the correct address. To verify the address, Human Resources may contact the post-offer job candidate directly, review University records (including the job application) to confirm the address, verify the address through third party sources, or use all other reasonable means. The Department of Human Resources will then respond to the third-party vendor and provide confirmation of the accurate address.
Confidentiality and Record Retention
Background check information will only be shared on a need to know basis. It will be retained in files separate from the personnel files in the Department of Human Resources and will be retained and disposed of in accordance with the University’s records retention policy and applicable law.
Candidates, employees, the Hiring Department and the Department of Human Resources are responsible for complying with the requirements and processes for conducting background checks as outlined in this policy.
Please contact your Client Services Partner or Human Resources Director for more information: https://hr.georgetown.edu/Contact-HR