I11: Background Checks

Responsibility for Maintenance: Human Resources

Date of most recent changes: June 25, 2024

I. Policy Statement 

Background checks serve as an important part of the hiring and volunteer process at the College. Conducted after a verbal offer has been accepted by the candidate, the information received is critically important to confirming employment-related information that bears directly on an applicant’s candidacy. Accordingly, the College will conduct background checks on all persons hired for full-time positions that are Professional Administrators, unrepresented administrators (including Management/Confidential), full-time faculty positions, and adjunct faculty positions. In addition, the College reserves the right to conduct a background screening on any employee, regardless of title or employment status, where it is warranted based on job duties, including those who work in close proximity with minor children and anyone working and/or volunteering in athletics.

II. Reason for Policy 

The Fair Credit Reporting Act (“FCRA”), 15 U.S.C.A. §§ 1681  

III. Applicability of the Policy 

This policy applies to all College employees and persons as identified above.   

IV. Related Documents 

(See Forms § VIII below)   

V. Contacts 

VI. Definitions 

The requirements of the FCRA apply to consumer reports which are defined as “any written, oral, or other communication of any information by a consumer reporting agency bearing on a consumer’s creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living, which is used for . . . employment purposes."

VII. Procedures 

The background checks will be conducted by one of the College’s authorized third-party consumer reporting agency (CRA) vendors who will be charged with ensuring that the checks are in compliance with the FCRA. The College will be responsible for the following steps in the process:

• Step One: all persons applying for employment and/or volunteer status at Onondaga Community College complete an application. Within that application is a statement that, by virtue of their signature, the applicant and/or volunteer is permitting the College to conduct a background screening. 
• Step Two: The College representative submits the request to the third-party vendor. As part of this process, the College representative certifies to the third-party vendor that it will only use the information it receives according to the requirements of the FCRA. 
• Step Three: If, after reviewing the background check information, the College determines it may be best to rescind an offer because of the information contained in the report, it must provide the individual with a copy of the report and a written statement of the individual’s rights under the FCRA before the decision is made.
• Step Four: If the College proceeds with its decision not to hire the candidate, it must again provide the candidate with a copy of the consumer report and another written summary of his or her consumer rights (the same form used in Step Three can be used in Step Four) the College must inform the individual that information contained in the consumer report was the basis for the employment decision and provide the name, address and telephone number of the third-party vendor which issued the report. This notification must also include a statement that the third-party vendor did not make the decision and will not be able to explain the specifics of the College’s decision. Finally, the College’s notice must inform the affected individual that he or she may dispute the accuracy or completeness of the information in the report with the third-party vendor.

VIII. Forms/Online Processes

• Step One: Applicant Disclosure & Authorization 
• Step Two: Certification to Third-Party Vendor 
• Step Three: Pre-Decision Notice &   FCRA Summary of Rights (for the most current version of the FCRA notice go to www.consumerfinance.gov/learnmore)
• Step Four: Post-Decision Notice & FCRA Summary of Rights   

Approved by the OCC Board of Trustees April 3, 2006  

Updated and approved by the OCC Board of Trustees June 17, 2014

Updated and approved by the OCC Board of Trustees June 18, 2019

Updated and approved by the OCC Board of Trustees June 25, 2024