How to Build a Background Check Policy into a Screening Program

A background screening program might run smoothly for years if an organization has established roles and a small hiring team. But eventually, those hiring needs may change. The business expands. New regulations take effect. More recruiters come on board. As those changes add up, having a background check policy can help keep the screening process fair and consistent.

A background check policy documents your organization’s screening standards, while a screening program puts those rules into practice through roles, workflows, technology, and training. Together, they can give your team a documented approach to follow, even if your hiring process becomes more complex.

What Should a Background Check Policy Actually Include?

A background check policy is only as useful as the information that’s in it. It should clearly explain the reason for background screening and outline how to use the policy for making employment decisions.

Our InCheck team recommends including these components:

• Purpose: Explain why your organization conducts background screening. Some common reasons include hiring consistency and fairness, workplace safety, and role-specific requirements.
• Role-specific background checks: Document what checks apply to specific jobs and why. A delivery driver may need a motor vehicle record check, while a credentialed role may call for license and education verification. More than likely, not everyone in the organization will need the same screening package.
• Timing: State when and how often checks occur. Your organization might screen candidates before employment, when promoting or reassigning employees, and at other defined periods, such as work anniversaries.
• Disclosure and authorization: Address the process for providing required background check disclosures and obtaining appropriate authorization before conducting background screening.
• Review process: Document who reviews the results, how potentially disqualifying information is evaluated, and when the check gets escalated. A consistent process can help prevent snap judgments and compliance missteps.
• Adverse action process: Document the process to follow when the organization is considering an adverse employment decision based on background check information, including applicable pre-adverse and final adverse action requirements. 
• Other background check compliance requirements: Account for other compliance requirements under federal, state, and local laws, including fair chance hiring and ban-the-box laws where they apply.

With a documented background check policy, hiring managers should be able to make informed decisions using a consistent process for similar applicants and employees.

What Happens If There’s No Background Screening Policy?

A company might get by without a background screening policy for a while. Over time, though, cracks may start to show. A recruiter might be unsure about which screening packages to order, or a manager may ask for extra checks on a case-by-case basis. Candidates may receive unclear or conflicting instructions about how to proceed.

With a background check policy in place, those problems become less likely. No matter who’s in charge of hiring, similar roles get evaluated through the same lens. It helps prevent candidates from getting unfair treatment, and it gives organizations a shared standard for using background checks consistently.

A written policy can also help employers make better hiring decisions. Matching the screening package to the role means hiring teams get information that actually matters. A driving record may be relevant for someone applying to operate a company vehicle, while employment verification may be essential for someone applying for a highly specialized role.

Here’s the bottom line: a background check policy should create internal clarity about the ownership, timing, and communication surrounding background checks. In turn, that leads to a smoother external experience, preventing mixed messages and unnecessary delays.

How to Build a Background Check Program

Imagine you’re an HR manager for a company that has grown over the last few years. As the company has added more positions, you’ve realized the old way of doing background checks doesn’t really work anymore. So what do you do?

It may be time to build or update your screening program. Here’s how to make it happen:

1. Review What’s Changed

Start by reviewing the organization’s hiring activity over the past 12 months or so. Consider what’s changed and how it may impact hiring expectations moving forward. For example, has the company expanded with new roles, acquired another business, or transitioned to remote work?

In our example scenario, the HR manager at a growing company should think about hiring volume and new positions that may be added in the near future. From there, they can identify “job families” that may require similar screening packages. These might include company drivers, employees who handle sensitive financial or customer data, and positions that require licensure or professional credentials.

2. Audit Your Screening Process

Your organization may be doing some things well when it comes to background screening, but there may also be room for improvement. Audit your existing process from the time you request a background check to the moment you get the candidate’s report.

As you review this process, ask yourself where the sticking points are. Do recruiters feel unsure about which checks to order? Do candidates struggle to understand directions? Is there uncertainty about who has the final call after a report comes back?

As our example HR manager reviews the company’s background screening process, they may discover that recruiters are ordering different packages for similar roles. One recruiter may order a criminal background check for a warehouse position, while another may order a criminal background check, plus employment and education verification. The HR manager can make a note to address this discrepancy moving forward.

3. Consider Background Check Compliance Requirements

Compliance needs to be built into the screening process. It can help remove uncertainty about which requirements apply, especially if you’re hiring for multiple roles and locations.

Necessary compliance steps for your screening policy should include background check requirements under the Fair Credit Reporting Act (FCRA) and federal anti-discrimination laws, including Title VII. Other regulations, such as ban-the-box laws, may vary based on where you’re hiring. Check those requirements and use them to outline your screening process, including when checks occur, how to handle disclosure and authorization, and what happens when a background check report may affect a hiring decision.

For our example employer, documenting federal regulations and state or local requirements may help bring much-needed consistency to the screening process.

4. Create Role-Based Screening Requirements

To determine which checks to run for different applicants or employees, use a role-to-screening exercise. For each position or group of similar positions, define the job’s primary responsibilities and consider the potential risks connected to the role. Working backward, you can then decide which background checks provide the most relevant information.

Our example HR manager may start with a role-to-screening exercise for delivery drivers. This role involves driving a company vehicle on public roads. If a driver gets into an accident, it may result in injuries, insurance claims, or potential liability for the organization. Based on the job’s responsibilities and potential risks, the HR manager may decide to run MVR checks for all delivery driver candidates.

5. Choose a Background Check Provider

Once you know which screening packages you need, find a background check provider that can help you put them into practice. As you evaluate potential partners, ask questions like these:

• Who can help us design a background screening program?
• Who do we call when something unusual happens?
• What support do candidates get when they have questions?
• Can the screening workflow be flexible based on the role or location?
• How do escalations get handled?
• How can you help us improve our background check program as hiring needs change?

Most importantly, look for a provider that can offer the support your organization actually needs. Depending on your criteria, you may focus on finding a partner that can integrate with your ATS, improve the candidate experience, or provide compliance guidance.

For our HR manager, the top priority may be finding a background check provider that can build role-specific screening packages and adjust them as positions change or new roles get added.

6. Document and Review the Policy

Now, it’s time to bring everything together. Document the background check policy in writing and share it with recruiters and hiring managers. Train hiring teams on how to use it, so everyone understands what checks apply, when screening occurs, and how to handle exceptions.

At this point, our example HR manager has turned background screening into a consistent, repeatable process that everyone involved in hiring can now follow. The manager can continue to review the policy after it goes live, making changes as the company continues to grow.

Background Check Policy Template

A background check policy should be specific to an organization, but that doesn’t mean you have to start entirely from scratch. A sample template can give you a starting point and help you identify areas your organization needs to address.

A background check policy template often includes these elements:

• An overview of the policy
• The scope of background checks
• When and how often background checks occur
• Role-based screening requirements
• Disclosure and authorization 
• Review process
• Adverse action requirements

For more help with writing a background check policy, our InCheck team recommends checking out the sample background check policy template from the Society for Human Resource Management (SHRM). It’s designed for HR leaders and business owners who want a comprehensive reference point for creating a background screening policy.

FAQs

Who should own the employee background check policy?

It depends on the organization, but a senior HR leader or a compliance manager commonly owns the background screening policy, with input from legal counsel and key stakeholders.

Should every role use the same checks?

No. Screening requirements should match a role’s responsibilities and risk profile, which means different positions may require separate checks.

How often should employers review a background check policy?

We recommend reviewing the organization’s background check policy at regular intervals, ideally at least once a year. Changes within the organization — such as new positions, locations, or regulations — should also trigger a policy review.

Build a Background Screening Program That Works with InCheck

As your organization’s hiring needs change, your screening process should, too. A clear background check policy built into a broader screening program can give your team a shared reference for handling the screening process and making employment decisions.

InCheck helps employers design holistic screening programs that fit how they actually hire, from role-based requirements to compliance considerations. Our team offers practical guidance, candidate support, and ongoing review to make sure your organization’s screening program does what you need it to do. Connect with InCheck to discuss how your screening program can better support your hiring goals and needs.