Background Check Policy

Background Check Policy

Updated: 21 June 2026

Background checks are a valuable tool when used within the right culture and expectations. They are a moment-in-time snapshot and susceptible to significant false negatives. They belong in every organization’s security toolbox and should be part of your minimum standards. Note that a background check on an individual is different from a due diligence check on suppliers and partners — both are necessary.

Key Minimum Elements:

• Criminal arrests
• Criminal convictions
• Financial trust verification (required if the individual will handle financial elements of the organization)
• Previous employer verification
• Reference checks conducted by a trained professional
• OFAC screening
• Interpol screening (required for foreign nationals)
• Politically exposed persons (PEP) check
• Adverse media check
• SSA Death Index
• TIN/EIN check
• Driver’s license validation
• CDL or other licensing validation (as applicable)

Scope: These rules apply to leadership, recruiting, hiring, and supervisory personnel; personnel overseeing any element of the supply chain; and, in church and NGO settings, those responsible for donor and volunteer management.

Note: This policy sample does not cover adjudication criteria — but your final policy must include that criteria as policy, not as a guideline. A small number of adjudication criteria elements may require a supporting guideline (for example, handling an individual who was incarcerated for three months and released on good behavior four years ago, where your policy sets a five-year reject threshold).

Requirements — HR, Legal, Security, and Compliance:

• I will ensure all required elements are included in the final policy and procedures, including adjudication criteria.
• I will ensure the policy covers all personnel the organization is legally permitted to screen.
• I will ensure the program is audited at least twice per year.
• I will ensure supplier contracts require background check standards that meet or exceed those applied to employees, with audit rights included.
• I will ensure the policy requires background checks to be re-run at least every two years, or upon any significant role change — especially if the new role involves financial responsibilities.
• I will ensure the final policy, procedures, and guidelines include callouts for applicable state and international requirements and limits.

Requirements — All Personnel:

• I will not support any individual beginning work unless I have confirmation that the full background check is complete and signed off as “CLEAR.”
• I will track background check re-run dates for all personnel and suppliers under my management.
• I will develop contingency plans for all single-point-of-failure roles in the event that a re-run background check returns “NOT CLEAR.”
• I will protect all background check information — positive and negative — at the highest confidentiality level available within our organization.

---

Related Resources

• One-Time Check vs. Recurring Re-Screen comparison
• Church/NGO Partner Due Diligence Checklist
• Converged Supply Chain Security FAQ

---

Signature Note: I am a huge fan of wet signatures on these types of documents for accountability and investigation reasons. You can add the signature lines below to each rule/policy document, or have a collective wet signature with references in the Security Commitment Agreement document available on the One-Pager library page. Organizational preference.

________________________
Print Full Legal Name

________________________
(Blue Ink) Full Legal Signature
Style of signature must closely match Driver’s License

________________________
Date

---

🖶 To save or print this policy, use your browser’s Print function (Ctrl+P / Cmd+P) and select “Save as PDF” if needed.