Background Checks on New Hires

A Background Investigations Program should be conducted on an "initial and continuing" basis. The intensity of the investigation also should depend upon an employee's or a contractor's level of responsibility and access. For certain positions, updating information every three (3) years may be appropriate -- and examples include:

• Teller
  
• Note clerk
  
• New accounts representative
  
• Groundskeeper

For other positions, updating information every year is more appropriate. Typically, positions that contain responsibilities for the management of assets or property -- or those positions that have "secrecy provisions" -- may cause the institution a more substantial loss. Examples of those positions include:

• Board of Directors or Supervisory Committee;
  
• President;
  
• Chief Financial Officer;
  
• Chief Information Officer;
  
• Chief Lending Officer;
  
• Human Resources Manager;
  
• Security Officer;
  
• Legal Counsel;
  
• Auditor; and
  
• Janitor if he/she is an employee.

Pre-Employment Checklist
Many institutions furnish job applicants with pre-employment correspondence that contains a checklist of the applicant's "things to do and know about" before employment will be offered. This checklist is a valuable tool for the background investigator because it reduces the number of investigations that he/she has to conduct. If an applicant cannot afford this level of scrutiny -- or is unwilling to furnish the requested information -- he/she will simply not apply for the position. The pre-employment checklist should vary according to the position or project applied for, and it should include:
For Institution-Affiliated Parties

• Accreditation or license validation (initially if the position requires credentials);
• Account waivers (initially for checking and savings account review, with an emphasis upon the first 90 days, then periodically);
• Code of Conduct (initially, at the time of promotion and annually);
• Credit check (annually and at the time of promotion, including bankruptcies, liens and judgments);
• Criminal history check from the last two counties of residence (initially and periodically for a marginally-performing person);
• Disclosures that address privacy issues -- and employee rights and obligations (initially, at
• the time of promotion and annually);
• Driving record (initially and annually for all persons who operate a vehicle while working for the institution);
• Drug screen (initially and upon the display of objective symptoms);
• Employee handbook (initially, at the time of promotion and annually);
• Financial statement (initially and annually);
• Fingerprints (initially);
• Handwriting (initially and every three years);
• Photograph (initially and annually); Reference validation (initially); and
• Waiver advising of unannounced searches of institution-owned property including (initially, at the time of promotion and annually):
  • Facility;
  • Computer;
  • Desks; and
  • Vehicles.

For Non-Institution-Affiliated Parties

• Accreditation or license validation (for each new project if the position requires credentials);
• Better Business Bureau check (for each new project);
• Business license and appropriate certificates and permits (for each new project);
• Code of Conduct (for each new project, if appropriate);
• Confidentiality agreement (for each new project);
• Criminal history check on all principals (for the initial project and periodically for different types of projects);
• Drug screen (for the initial project, if appropriate);
• Employee handbook (for each new project);
• Financial statement (for the initial project, if appropriate); and
• Reference validation (for the initial project).

First published on BankersOnline.com 1/17/05