16.6 Background Screening

(Amended 5/20/22)

The following criminal background screening requirements apply to students, faculty, staff, and volunteers who are anticipated to have direct contact with minors in the course of their university activities.

  1. Criteria and process for determining who must be screened.
    1. Anyone, including but not limited to graduate/undergraduate student assistants, faculty, staff, volunteers, and consultants or contractors, who in the course of their university programs with minors duties or assigned responsibilities will or may have direct contact with minors is subject to criminal background screenings regardless of the supervision structure in place. 
    2. Colleges/departments/units and/or programs are responsible for determining who meets the criteria for undergoing a criminal background check. Each individual who meets the defined criteria shall be subject to the criminal background check, and its results will be evaluated for program participation by the appropriate dean, senior HR leadership representative, and direct supervisor. If the criminal background check reflects criminal history within the designated time period, the following offices will review the results and determine how to proceed: University Human Resources, Office of the General Counsel, and Office of the Executive Vice President and Provost. The Dean of Students will participate in any determination regarding a criminal background check report on a University of Iowa student. No adverse action will be taken without providing the individual a copy of the criminal background check report and an opportunity to respond to the report to correct errors and to provide context.
  2. Scope. 
    1. The senior HR leadership representative in each college or division shall use the designated university vendor to verify social security number and conduct a criminal background check for all university students, faculty, staff, and volunteers in compliance with the procedures set forth in III-9.3 Criminal Background Check at Point of Hire. As appropriate in individual instances, an alternate designated by the vice president or dean or, in the case of faculty, the Associate Provost for Faculty, may conduct the check.
    2. In the case of consultants or contractors, the criminal background check requirements shall be included in the contractual agreement between the university and the consultant or contractor.
  3. Timing/frequency. Screening must be done as follows:
    1. Initial screening:
      1. New employees at the point of hire.
      2. Returning/seasonal employees upon rehire.
      3. Consultants/contractors prior to commencing any project.
    2. Current employees: 
      1. All current employees determined to be subject to background screening will undergo a criminal background check and be required to complete a self-disclosure form upon implementation of this policy, unless an equivalent screening has taken place within the past year. 
      2. Internal job transfers or any change of duties that adds activities with direct contact with minors, prior to commencing those duties.
    3. Rechecks:
      1. All current employees determined to be subject to background screening will undergo a criminal background check at least every five years utilizing the designated university vendor.  
      2. A criminal background check will be conducted upon self-disclosure of criminal activity as discussed below in II-16.7.
      3. The university reserves the right to conduct background checks of current employees when it has reasonable grounds to do so (e.g., no recent check was performed, a workplace incident has occurred, upon self-disclosure of criminal activity, or upon the university being informed of such activity).
  4. Notice and authorization.
    1. Consistent with III-9.2 and III-9.3, job candidates are informed during the interview stage that employment at the university is contingent upon the successful completion of a background check and a check of their credentials. university students, faculty, staff, and volunteers are notified at the time they become subject to this policy’s background check requirements according to the criteria stated herein.  
    2. In accordance with federal law, the university must secure a signed authorization which permits the university to obtain background check results from a third-party reporting agency. Such authorization shall remain in effect for the duration of an individual’s employment with the university, unless or until employment duties no longer include contact with minors.