Background Check and Pre-Employment Screening Policy (Interim)

Effective Date:
June 29, 2006
Last Revised Date:
June 26, 2026
Applies To:
Classified Staff, Appointed Personnel, University Staff, Students
Responsible Unit(s):
Human Resources
Responsible Unit Email(s):
hradmin@arizona.edu
Status:
Active
Under Consideration
Reference:
University Handbook for Appointed Personnel 2.23

Purpose and Summary

To assist in creating a safe and secure environment, the University of Arizona (University) will conduct screening, including criminal background checks, as described in this Policy. 

Scope

This Policy applies to all Employees and Designated Campus Colleagues (DCCs). 

Definitions

Authorized Representative means, for the purpose of this Policy, Employees and DCCs who are at least 18 years of age and are within the scope of the Non-Enrolled Minors Policy (Interim).

Designated Campus Colleagues (DCCs) means affiliates, associates, volunteers, and interns who are granted DCC status by the University, and who contribute their time, services, and expertise to help the University accomplish its mission of teaching, research, and service. 

Employee means all University employees, including faculty, staff, appointed personnel, graduate assistants/associates, and student workers, whether their employment is full-time, part-time, permanent, or temporary.

Finalist means any person who is offered and accepts employment at the University as a new hire or rehire or any current Employee who accepts a qualifying job change (such as reclassification/title change, promotion, transfer, additional job, reassignment, or other similar change) in the same or different position, or the same or different department.

Fingerprint-Based Criminal Record Background Check means state and nationwide checks for criminal convictions based on the Finalist's fingerprints.

Motor Vehicle Record Check means driver’s license and citation history checks. 

Name-Based Criminal Background Check means checks of court records and criminal convictions.

Security- or Safety-Sensitive Position means any position or assignment designated as Security- or Safety-Sensitive by the University due to applicable federal or state law or pursuant to rules or policies adopted by the Arizona Board of Regents (ABOR) or the University. These include, but are not limited to, the following:

  • University leaders and others with significant financial oversight responsibilities as follows:
    • Senior leaders; vice presidents; assistant and associate vice provosts; assistant and associate vice presidents; assistant and associate deans; department heads; and others appointed under the Conditions of Administrative Service; and
    • Positions at the Manager & Leader V (M5) job level and above; positions in the Finance Function at a Manager & Leader I (M1) job level and above; positions with an Administrative Operations Manager job code at a Manager & Leader I (M1) job level and above; and positions with an Administrative Operations Professional job code at a Professional Contributor III-IV (PC3 or PC4) level.
  • Positions that have one-on-one interactions with minors who are not enrolled students at 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 threshold quantities specified under the applicable regulations).
  • Positions with unrestricted access to residence hall rooms.
  • Employees and DCCs who have a prior felony conviction.
  • Other positions designated by Human Resources as Security- or Safety-Sensitive.
  • University of Arizona Police Department (UAPD) Employees. Pre-employment screenings for these individuals are conducted in accordance with UAPD hiring protocols.

Policy

  1. Standard Pre-Employment Screening
    1. The hiring authority from Human Resources or the hiring manager or their designee will check and verify the following information prior to extending an offer of employment (including internal hires):
      • Professional references
      • Educational credentials
      • Employment history and past performance
      • Professional license or certification (if required)
    2. Human Resources will arrange the following checks to be conducted after an employment offer, including for an internal hire or job change, is accepted:
      • Criminal background check
      • Motor Vehicle Record Check (if required to drive as part of their job duties)
      • Degree verification (faculty qualifications for instruction)
    3. Additional pre-employment screening and background checks required by statute, contract, or policy will be coordinated by Human Resources.
    4. All employment offers are contingent upon the Finalist’s successful completion of University pre-employment screening.
  2. Background Checks on Employees
    1. Faculty, Staff, Appointed Personnel, and Graduate Assistants/Associates: A Finalist for a faculty, staff, appointed personnel, or graduate assistant/associate position must undergo a Name-Based Criminal Background Check at a minimum. A Finalist for a Security- or Safety-Sensitive position must undergo a Fingerprint-Based Criminal Background Check.
    2. Student Workers: Finalists for student worker positions are not required to undergo criminal background checks except for:
      1. A Finalist for a student worker position who will be an Authorized Representative must undergo a Name-Based Criminal Background Check.
      2. A Finalist for a Security- or Safety-Sensitive student worker position must undergo a Fingerprint-Based Criminal Background Check.
    3. For Finalists accepting a qualifying job change for an Employee position, Human Resources may waive conducting a duplicate criminal background check if the Finalist successfully completed the same type of check, conducted by Human Resources, during their continuous employment at the University.
    4. When a Finalist is rehired within 12 months from their last day of employment at the University, Human Resources may waive conducting a duplicate criminal background check if the Finalist successfully completed the same type of check, conducted by Human Resources, during their most recent continuous employment at the University.
    5. If a Finalist is required to drive on University business as part of their job duties, Human Resources will conduct a Motor Vehicle Record Check in accordance with the Fleet Safety Policy.
  3. Background Checks on Designated Campus Colleagues
    1. DCCs are not required to undergo criminal background checks except for:
      1. DCCs who will also be Authorized Representatives must undergo a Name-Based Criminal Background Check.
      2. DCCs who will perform a Security- or Safety-Sensitive assignment must undergo a Name-Based Criminal Background check.
    2. Medical residents and fellows who are DCCs undergo background checks through their employment with Banner and are generally exempt from the University background check requirement.
    3. If a DCC is required to drive on University business as part of their assignment, Human Resources will conduct a Motor Vehicle Record Check in accordance with the Fleet Safety Policy.
  4. Responsibilities
    1. Human Resources coordinates all criminal background checks and the resulting reports.
  5. Considerations
    1. When considering whether to pass a Finalist or DCC who has been convicted of a criminal offense, the University will take the following factors into account:
      • The relevance of a criminal conviction to job duties.
      • The date of the most recent offense and employment history since the commission of the crime.
      • The nature of the offense.
      • The accuracy of the information the individual provided on onboarding and background screening forms.
      • If the criminal offense occurred when the individual was a minor, consideration will be given to whether the minor was treated as an adult for purposes of prosecution.
    2. Any material misrepresentation or omission on any employment application materials or pre-employment forms, including but not limited to the job application, résumé, vita, or background screening consent and disclosure forms may be grounds for rejection of the application, withdrawal of an offer, or termination of any subsequent employment or DCC relationship with the University.
    3. The University may refuse to hire a Finalist, may rescind an offer of employment to a Finalist, or may review and terminate the employment of a current Employee who does not successfully complete and pass all pre-employment screening requirements.
  6. Compliance with the Fair Credit Reporting Act
    1. An outside vendor may uncover information that may disqualify a Finalist or DCC from consideration. In such a case, the University will notify the Finalist or DCC of the information and provide a minimum of five business days for the Finalist or DCC to refute, explain, or correct the information.
  7. Record Retention
    1. Human Resources manages criminal background check information. Criminal background check information collected is maintained by Human Resources in confidential files, separate from official personnel records. Access is limited to authorized Human Resources personnel.
    2. Documents related to pre-employment screening information collected by hiring departments are filed and maintained in the departments and destroyed after three years, in accordance with the State of Arizona Records Retention Schedule.
  8. Information Release
    1. Criminal history information provided to or obtained by the University is regarded as confidential and will only be released in a manner consistent with applicable law.

Compliance

Human Resources is responsible for overseeing compliance with this Policy.

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