Pre-Employment Background Check Policy

Washington University performs pre-employment background checks to promote the safety of its community and operations. Background checks will be conducted only after an offer of employment has been made, and include verification of a candidate’s criminal record and review of applicable federal and state registries or other job-related information. Background checks are distinct from pre- or post-offer reference checks or reviews of a candidate’s licensure or other qualifications.

Scope

Background checks will be performed on all new hires.

Current employees are not subject to a background check unless they are transferring into a position for which a background check is required, such as positions involving direct responsibility for patient care or access to certain controlled substances or regulatory controlled areas.

Background checks will not be required for former employees who return to the University within 90 days, unless (1) the position to which they are returning requires a background check, and (2) they have not undergone a University background check within the preceding year.

Procedures

Authorization. Candidates should be informed that any offer of employment or transfer is contingent upon a successful background check. Prior to conducting the background check, a signed or e-signed consent to conduct the check must be obtained from the candidate. Refusal to authorize a background check will disqualify the candidate. Background checks may be conducted by the University or an external vendor.

Evaluation of Background Check Results. Generally, employment in the position may not begin until the University has reviewed the results of the background check and made a final determination regarding the contingent offer. Exceptions may be made with the approval of Human Resources and applicable administrators.

Human Resources will review the results of the background check. If the results raise questions concerning the candidate’s suitability for the position, Human Resources will inform the hiring unit of the concerns and consult with, as applicable, the hiring manager, Vice Chancellor, Executive Vice Chancellor, Dean, and/or Provost.

A prior criminal record will NOT automatically disqualify the candidate. In determining whether a criminal record will result in revocation of the offer, the University conducts an individualized assessment that includes the following considerations: the nature, number and gravity of the offense(s); the length of time that has elapsed since the offense; and whether and the degree to which the offense is related to the duties and responsibilities of the position.

If adverse action is probable based on the results of a background check, the candidate will receive a copy of the background check report, a pre-adverse action notice, and a document summarizing the candidate’s rights under the Fair Credit Reporting Act (FCRA). Candidates may provide responsive information within five business days.

The final determination regarding the contingent offer will be made jointly by Human Resources and the applicable administrators referenced above. If the offer is rescinded, the candidate will receive an adverse action notice and a document summarizing the candidate’s rights under the FCRA.

Confidentiality. Information obtained through background checks is confidential and will be shared only with individuals with a legitimate business need to know. Records of background checks will be maintained by Human Resources.

Miscellaneous

Use of Information. Information discovered through the background check process will be used solely for the purpose of evaluating a candidate’s suitability for employment and will not be used to discriminate against a candidate on the basis of race, color, religion/creed, sex/gender, age, sexual orientation, gender identity/expression, national origin, genetic information, marital/familial status, disability, military, veteran status, or any other protected status.

Reporting Obligation. All employees have an ongoing responsibility during their employment to inform Human Resources of any criminal conviction (including guilty or no contest pleas).

Supervision of Minors. For information about background checks of employees whose job duties include supervision of minors, please see the University’s Youth Protection Policy.

Policy Exceptions. Exceptions to this policy may be made at the discretion of the University through the Vice Chancellor of Human Resources or designee.

General WashU HR Recruitment Contacts

When hiring a new employee, please contact your assigned recruitment representative to start the pre-employment background check process.

Joanna Johnson
314-362-4994
 joannajohnson@wustl.edu

Mike Sullivan
314-362-4920
mikesullivan@wustl.edu