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Volunteer Background Screening Policy

1. Purpose

COMMUNITY ONE, INC. (COMMUNITY ONE) is concerned about the safety of its volunteers while on duty (whether on or off premises), the safety of its constituents (staff, community, etc.) and the protection of its assets and reputation. To reduce these risks, prospective and, as applicable, current volunteers of COMMUNITY ONE will undergo a criminal background check that complies with the Fair Credit Reporting Act (FCRA). Volunteers are treated as applicants under the FCRA.

This policy sets forth guidelines for performing such background screens. COMMUNITY ONE has selected an approved background screening provider, namely SECURESEARCH, INC. (SECURESEARCH).

Any questions or special considerations concerning this policy should be directed to COMMUNITY ONE's Executive Director.

2. Policy Statement

This policy applies to all prospective and current volunteers over the age of 18 who are applying to the Neighbors Helping Neighbors program. COMMUNITY ONE reserves the right to recheck criminal backgrounds at any time during the course of the volunteer's service with the organization.

3. Checks to be Conducted

COMMUNITY ONE contracts a third-party screening company that utilizes name-based systems to obtain data for individual background checks, but at a minimum each background shall include:

  1. Social Security Trace (SS Trace)
  2. County/State Residence Criminal Search (Current)
  3. County/State Search(es)
  4. Nationwide Criminal History Search with Validation
  5. National 50 State Sex Offender Registry Search (Dru Sjodin/NSOPW)
  6. Office of Foreign Asset Control (OFAC) Watch List Search
  7. Office of the Inspector General (OIG) / GSA

4. Disqualification Criteria

Background check findings shall be reviewed in a fair, impartial, and confidential manner. COMMUNITY ONE may, in its sole discretion, decide that an applicant will not be approved as a volunteer or reassign a former convict to a job involving less exposure to risk. Conditions that may disqualify an individual from volunteer service may include, but are not limited to:

  1. Refusing to consent to a background check
  2. Making a false statement in connection with such background check
  3. A felony conviction in the past 5 years-- these serious crimes are usually defined by statutory guidelines, and in general, are punishable by more than 1-year incarceration.
  4. Theft -- including burglary, embezzlement, forgery, fraud.
  5. Violent crimes -- including murder, robbery, assault, battery.
  6. Sex offenses -- including rape and sexual assault.

Arrests that are not pending and did not result in conviction should not be considered. Arrests pending disposition that are role-related may be considered subject to state law.

5. Fair Credit Reporting Act (FCRA) & State Law Compliance

Denial of an individual's application will be communicated via email complying with FCRA Adverse Action guidelines. If the disqualification decision is not based on a misrepresentation or omission in the volunteer application, it is a best practice to discuss the potentially disqualifying information with the individual prior to issuing the pre-adverse action notice.  A Pre-Adverse Action email will be sent to the applicant with a copy of their background check results, a pre-adverse action letter, and a copy of the FCRA notice of rights. The applicant has 5 days to dispute the findings with SECURESEARCH. If the applicant does not respond at all to the notification, COMMUNITY ONE may proceed with its decision to deny the volunteer role. If the applicant responds, COMMUNITY ONE may carefully consider the information and make a decision. If the applicant's explanation is determined to be insufficient, an Adverse Action notice will be issued. This written notice of the adverse action will include the name, address, and phone number of the reporting agency, FCRA summary of rights, and a statutorily required statement that the consumer reporting agency did not make the decision and does not know why the decision was made should be included as well as a notice of the applicant’s right to obtain the report and dispute the information. For all adverse decisions, each step will be documented and timestamped using SECURESEARCH's website and retained for five years.

6. Process

  1. Applicants are given the option to pay for their own screening or have COMMUNITY ONE cover the cost and select the appropriate link based on their decision.
  2. Applicants are linked to SECURESEARCH's website and sign a consent and disclosure form that allows the background check to be conducted.
  3. Applicants complete required information and screening is conducted by SECURESEARCH.
  4. Results are delivered to COMMUNITY ONE via PDF and are reviewed to make a decision.
  5. If no disqualifying criteria are present, applicant is approved as a volunteer on Neighbors Helping Neighbors platform and automatic email is generated.
  6. If disqualifying criteria are present, COMMUNITY ONE may contact the individual for further information and make a decision based on the results of the screening.
  7. If applicant is disqualified, a Pre-Adverse Action notice is emailed.
  8. Applicant has 5 days to respond to Pre-Adverse Action notice. If they do not respond, an Adverse Action Notice is emailed.
  9. Applicant is removed from the Neighbors Helping Neighbors platform but records are retained on SECURESEARCH's website.

7. Provisions for Groups and Minors

For groups of two or more people wanting to volunteer with Neighbors Helping Neighbors, only one volunteer is required to register on the COMMUNITY ONE website and pass a background screening. This volunteer acts as a "group leader" and is responsible, in every way, for any additional people they allow to participate on a project.

Minors age 14-17 are able to participate in the Neighbors Helping Neighbors program. They are not required to submit a background screening but will be required to have a guardian sign a waiver and release form.

8. Record Retention

All documents related to the background screen process must be retained for at least five years.

9. Equal Employment Laws

COMMUNITY ONE will adhere to all equal opportunity laws. When reviewing any criminal record information that appears on a background check, the organization shall factor in any known factors relating to:

  • The facts and circumstances surrounding the offense.
  • The number of offenses for which the individual was convicted.
  • The age of the individual at the time of conviction or release from prison.
  • Evidence that the individual has performed the same type of work, post-conviction, with the same or a different organization, without incidents of criminal conduct.
  • Any efforts of the application towards rehabilitation.
  • Employment or character references obtained regarding the individual's fitness for the particular position.
  • Whether the individual will be bonded for the position.

Policy Effective Date: 04/01/2021

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