Human Resources

1.085 Background Investigations

This policy outlines background investigation requirements for new employees.

Origination date: 10/1/93
Revised: 2/1/2006
Applicability: Academic Professionals, Administrators, Classified Staff, Faculty, Service Professionals, Student Employees, Temporary Employees, Graduate Assistants, Adjunct Faculty, Volunteers, Interns

A criminal background and an employment history investigation will be completed for the final candidate for all regular full-time and part-time positions, with the addition of an academic credentials check for all faculty and administrator positions. A minimum of a criminal background investigation, employment history investigation, and a fingerprint check, with the addition of an academic credentials check for faculty and administrator positions, will be completed on the final candidate (including for internal candidates for whom any portion of this process has not been previously completed) who indicate, or who have been determined through a background investigation to have, a prior criminal conviction and/or are being hired for or assigned to a safety or security-sensitive position as defined by one or more of the following criteria:

• University administrators (including any officer who reports directly to the president or to a vice president and who is responsible for planning, organizing, directing, controlling and evaluating the activities of a major segment of the University or is responsible for promulgating and implementing University rules and regulations, or for preparing and administering the University’s organizational budget, or for maintaining relationships with administrative officials and members of business, government, or civic communities).
• Positions that have unsupervised contact with minors who are not enrolled students of the University.
• Positions for which a fingerprint check is prescribed by federal or state law (such as positions that have direct access to Select Agents, as defined by the USA Patriot Act of 2001 and the Public Health Security and Bioterrorism Preparedness Response Act of 2002, except where excluded by law because the Principal Investigator does not, at any time, exceed the Select Agent regulatory thresholds quantities specified under the applicable regulations, or employees of the Northern Arizona University Police Department (NAUPD) where preemployment screening for these individuals shall be conducted in accordance with NAUPD hiring protocols).
• Positions with unrestricted access to campus housing units.
• Positions with control over fiscal assets as a job responsibility, including but are not limited to, final approval authority and/or the ability to generate disbursements within the University’s financial accounting systems without further approval, or having direct and regular access to cash and cash equivalents of $500 or more, or having other fiduciary duties to NAU such as fund custodian supervision, as determined by the Chief Human Resources Officer (or designee) on a case-by-case basis.
• Positions with delegated authority to sign contracts that bind the University or require the expenditure of University funds.
• Positions with management responsibilities for institutional systems and/or access to information that poses a significant risk to the University, as determined by the Chief Human Resources Officer (or designee) on a case-by-case basis.

All forms of background investigations, with the exception of fingerprinting, must be completed prior to a candidate’s first day of employment and no offer of employment may be made either orally or in writing until either:

• The background investigation and/or fingerprinting check has been completed and its results provided to the hiring official, or;
• The candidate has been notified that any offer made by the hiring official is contingent upon successful completion of a background investigation and/or fingerprinting check.

Adverse Findings

In the event that a final candidate makes false representation or omits factual information in the application/selection process, they will at a minimum not be selected for the position and, in the case of internal applicants, be subject to disciplinary action up to and including termination (see HR Policy 5.19). An employee who has a record of a criminal conviction prior or subsequent to being hired may be subject to disciplinary action up to and including termination. The hiring of any applicant convicted of a felony offense shall require written approval by the President. In considering whether to hire, retain, or terminate an employee or candidate who has been convicted of a criminal offense prior to or during employment, the University shall consider the following factors:

• Whether the nature of the criminal conviction is relevant to the position’s duties;
• If the criminal offense was committed by a minor for which proceedings were held under the jurisdiction of a juvenile or an adult court;
• If the employee or candidate has been pardoned or if the sentence has been commuted or reversed on appeal; and
• The employee’s or candidate’s employment history since the commission of the criminal offense.

Procedure

The University may release the results of a reference check and background investigation to another university under the jurisdiction of the Arizona Board of Regents for employment screening purposes. The University may require a background investigation and/or fingerprinting check for volunteers or other affiliates associated with the University under certain circumstances as may be determined by the appropriate vice president or the Provost from time to time.

As determined by the hiring official in consultation with Human Resources, additional background investigations may be required and shall be identified by focusing on specific risk factors such as degree verification, certification or licensure requirements, health care providers (e.g., employees of Campus Health Services, Counseling Services, Employee Assistance and Wellness, athletic trainers, etc.), or for positions that involve investing University funds, etc.

Additional information about background investigations is available from the Human Resources website.

References

ABOR Policy 6-709
A.R.S. 15-1649