Procedure Details
Procedure Title: Employment Background Check
Procedure #: HR.5008
Revision #: 000
Unit Responsible: Human Resources
Individual Responsible: Human Resources Director of Total Compensation & Employment
Effective Date: 11/01/2023
Initial Approval Date: 02/23/2023
Last Review/Update Date: 10/28/2024
Next Review Date: 10/01/2026
*Does this procedure support a Board Policy? Yes
If yes, identify: 4.070-Ethics and Standards of Conduct for Employees Supplement to Standard of Conduct
Board policies can be found at: LCC Board of Trustees Policy Page
*Does this procedure support HLC criteria? No
If yes, identify: N/A
HLC Criteria can be found at: HLC Accreditation Criteria
*Does this procedure support a State or Federal Regulation? Yes
If yes, identify: Title IX Regulations and other statutes, rules, and regulations relative
to licensing of certain employees as well as the limitations imposed by job descriptions
that prohibits hiring certain individuals in certain capacities.
*Note: Standard Operating Procedures should be in furtherance of some LCC policy and/or accreditation criteria, even if the relationship is not direct. Assistance in determining this information can be obtained from the Academic Procedure Advisory Committee (APAC) and/or the Accreditation Liaison Officer.
Employment Background Check, BP 4.070
1. Purpose
Lansing Community College (LCC) is committed to providing a safe environment for its students and employees. This policy is intended to help LCC achieve that goal by mandating the use of criminal background checks in the hiring process for all employees.
This policy also requires arrests, convictions, and/or events as outlined in the board policy, employment agreements, contracts, and bargaining unit language to be disclosed within three (3) business days of their occurrence.
2. Scope
This procedure applies to all employees, full-time or part-time, temporary or permanent, including executive management, administrators, faculty, academic professionals, support staff, student employees, volunteers, contractors and specialized professionals, whether paid or unpaid.
3. Prerequisites
n/a
4. Responsibilities
The HR Director of Total Compensation & Employment is responsible for the administration of the employment background check, in coordination with Human Resources Employment staff.
5. Procedure
An employment background check, including degree verification, is required for all potential employees, full-time or part-time, temporary or permanent, including executive management, administrators, faculty, academic professionals, support staff, student employees, volunteers, contractors (third party payer), and specialized professionals, whether paid or unpaid.
General Information
- The College will conduct pre-employment background checks on applicants for positions within specified classifications keeping with its goal of providing a safe and secure environment. The College Human Resources website and job postings will include the following statement: “The College will conduct pre-employment background checks on applicants for this position”.
- Upon successful completion of the employment application, applicants will receive notice of rights under the Fair Credit Reporting Act (FCRA) as well as a request for an executed release of information contemplated under FCRA.
- Following the identification of a preferred candidate for the position, the Human Resources Department will initiate a background check and notify the candidate that a background check is in progress. A contingent job offer of employment will be extended that is conditional on the results of the background check.
- Final offers of employment will not be made until the background check results have been obtained and reviewed by the Director of Human Resources or designee and shared with the hiring manager.
- Current employees applying for new positions at the College will be subject to the background check process.
Requirements of Criminal Background Check
- The employment background checks required for all employees consist of:
- State of Michigan Internet Criminal History Access Tool (ICHAT);
- Michigan Sex Offender Database; and
- Offender Tracking Information System (OTIS)
- Regular (non-student) employees, internships, and volunteers will include these additional
background check item(s):
- National Criminal History Check;
- Social Security Number Verification; and
- National Sex Offender Database
- Additional screening may be required for job/role specific situations:
- Driving record
- Credit record
- Drug screening
- Fingerprinting
- All background checks for non-student employees and volunteers are completed by Human Resources. Questions regarding results and eligibility are reviewed and approved by the Human Resources leadership in compliance with applicable law.
- All background checks for student employees are completed by the Student Employment Specialist in Human Resources. Questions regarding results and eligibility are reviewed and approved by Human Resources leadership in compliance with applicable law.
- Background checks for FT certified Police Officer candidates are completed by the Chief of Police based on approved procedures.
- Background checks for Contractors (third party payers) are completed by the third-party vendor who reviews and verifies the screening results of the employment background check. Results are not shared with LCC Human Resources or supervisor.
- Detailed results of background checks are maintained within the Human Resources department and are not available to hiring supervisors.
- Human Resources will communicate when the background screening has been completed to hiring supervisors.
Pre-Adverse and Adverse Reports
- When an adverse report is received regarding a candidate, the College will notify the candidate in writing that the result of the background check revealed information that necessitates further review. The College will also send to the candidate a copy of the Background Inquiry Statement of Explanation and a notice of their rights under the Fair Credit Reporting Act together with a timeframe within which the candidate could dispute the information. Prior to making a final decision, Human Resources will provide the affected candidate with an opportunity to provide additional information relative to the result of their background check results.
- The adverse information obtained from the reporting process will be reviewed by the Human Resources Employment staff in consultation with executive leadership and/or legal counsel.
- If the College were to decide not to hire an individual because of information obtained as a result of a background investigation, then the College will complete the actions necessary to comply with existing statutes. As required under the FCRA, Human Resources will notify the individual that they are not eligible for employment at the College.
- Documents relative to investigations of background information of applicants for employment will remain in files segregated from personnel files in the Human Resources department for the required documents retention period. Access to these documents may be shared with College staff based who have legitimate needs for these documents.
Self-Disclosure Process
- Conviction of a criminal offense or charged with an offense which may affect the public perception regarding one’s performance given one’s position or which may affect LCC’s public image will require disclosure by the individual. Individuals currently employed, volunteering, or engaged by the College are required to notify Human Resources of arrests, charges, convictions, or events within three (3) business days or at the earliest possible opportunity by using the Criminal Charges or Conviction Disclosure form located on the Human Resources website.
- A criminal arrest, charge, or conviction is not in and of itself grounds for termination. However, failure to disclose such information, or making any misrepresentation in connection with the disclosure, may be grounds for termination.
- Human Resources, in consultation with Risk Management and Legal Services and/or legal counsel, will evaluate the relevancy of the criminal history and/or events disclosed and determine whether the individual can successfully fulfill the responsibilities of the position.
6. Reference
Board Policy: Standards of Conduct for Employees Supplement
7. Definitions
FCRA: Fair Credit Reporting Act