University Policy 6.6.2
Reference Checks, Information Verification, and Background Checks
Policy Statement
Cornell University, including Weill Cornell Medicine (WCM) and Cornell Tech (collectively the “university”), requires units to conduct a thorough reference check, and education and employment verification, on any applicant (internal and external) to whom an offer of benefits-eligible employment is to be made. In addition, a background check is required, as outlined in the procedures in this policy; in such cases, offers of employment must be contingent upon the satisfactory completion of the background check.
Note: Weill Cornell Medicine (WCM) conducts reference checks, and education and employment verification for all non-academic external candidates. For internal non-academic candidates, only an internal, informal reference check is recommended.
Reason for Policy
To promote a safe and productive environment, the university conducts comprehensive reference checks, background checks, and verification of information presented by job applicants.
Entities Affected by this Policy
- Cornell University
- Weill Cornell Medicine
- Cornell Tech
Who Should Read this Policy
All members of the university community, especially the following individuals, in the performance of their jobs:
- Members of the human resources community
- Hiring supervisors, faculty, or staff
- Volunteer coordinators
Related Resources
University Policies and Information Applicable to All Colleges and Units
- University Policy 4.2, Transaction Authority and Payment Approval
- University Policy 4.7, Retention of University Records
- University Policy 6.4, Prohibited Bias, Discrimination, Harassment, and Sexual and Related Misconduct
- University Policy 8.8, Protection of Minors and Abuse Reporting
- Equal Education and Employment Opportunity Statement
University Policies and Information Applicable to All Colleges and Units Except WCM
- University Policy 6.5, University Volunteers
- University Policy 6.6.1, Filling Vacancies (Excluding Bargaining Unit Staff)
- University Policy 6.10.9, Staff Transfer (Excluding Academic and Bargaining Unit Staff)
- University Policy 6.12, Separations, Voluntary and Involuntary (Including Layoff)
- Guidelines for Checking References
- Guidelines to Support Filling Vacancies
- Guidelines for Managing and Evaluating an Applicant with Criminal Convictions
- Guidelines for Temporary and Casual Appointments
University Policies and Information Applicable to WCM
- WCM Non-Academic Recruitment
- WCM Contingency Employee Recruitment
- WCM Academic Staff Handbook Appendix B: Key Recruitment and Other Procedures
External Documentation
Federal Fair Employment Practices:
- Age Discrimination in Employment Act
- Americans with Disabilities Act
- Civil Rights Act of 1991
- Drug-Free Workplace Act
- Employee Polygraph Protection Act
- Equal Pay Act
- Executive Orders 11375, 11478 (Affirmative Action for qualified protected veterans and qualified individuals with disabilities)
- Fair Credit Reporting Act
- Fair Labor Standards Act of 1938
- Immigration Reform and Control Act
- Nuclear Regulatory Commission 10 CFR
- Omnibus Transportation Employee Testing Act of 1995
- Public Health Security and Bioterrorism Preparedness and Response Act of 2002
- Pregnancy Discrimination Act
- Title VII of the Civil Rights Act of 1964
- Uniform Guidelines on Employee Selection Procedures
- Vietnam-era Veterans Readjustment Act
- Vocational Rehabilitation Act
Ithaca City, Tompkins County, and New York State Laws and Regulations:
University Resources, Forms, and Systems, All Colleges and Units Except WCM
Contacts – All Colleges and Units Except WCM
Direct any general questions about this policy to your college or unit administrative office. If you have questions about specific issues, contact the following offices.
Contacts, All Colleges and Units Except WCM
| Subject | Contact | Telephone | Email/Web Address |
|---|---|---|---|
| Policy Clarification and Interpretation | College/Unit Human Resource Representative | Find Your HR Rep | |
| Division of Human Resources, Office of Talent Attraction and Recruitment | mycareer@cornell.edu | ||
| Credit Checks, Approval for | Associate Vice President for Human Resources | (607) 255-3621 | Working at Cornell |
| Background Checks with Department of Motor Vehicle Concerns only | Risk Management | (607) 254-1575 | risk_mgmt@cornell.edu |
| Individuals with Access, or Means to Access Select Agents | Environment, Health and Safety | (607) 255-8200 | |
| Drug and Alcohol Testing for positions requiring a Commercial Driver’s License | Environment, Health and Safety | (607) 255-8200 | askehs@cornell.edu |
| Background Check Results of Concern | Associate Vice President for Human Resources | (607) 255-3621 | Working at Cornell |
| Unescorted Access to Selected Radioactive Material or Associated Security Plan | Environment, Health and Safety | (607) 255-8200 |
Contacts-Weill Cornell Medicine
Contacts, Weill Cornell Medicine
| Subject | Contact | Telephone | Email/Web Address |
|---|---|---|---|
| Policy Clarification and Interpretation | WCM HR Solution Center | (646) 962-9247 | hrsc@med.cornell.edu |
Definitions
These definitions apply to terms as they are used in this policy.
| Applicant | Any person who applies (requests review of his or her credentials, experience, or other qualifications) in accordance with the stated directions for a specific and discrete open position. |
|---|---|
| Background Check | The process where, after a contingent offer of employment or volunteer service has been extended, the university’s authorized third-party vendor investigates an applicant’s criminal history and other job-related information. |
| Casual Appointment (All Colleges and Units Except WCM) | Employment in a position of less than 20 hours per week. |
| Casual Employee (WCM only) | An individual called upon to work from time to time without a set schedule (typically no more than 17.5 hours per week), who may remain on the WCM payroll as long as their services are needed, and the individual is available to work. |
| External Applicant | A job candidate who presently does not hold a regular appointment with the university. |
| Hiring Authority | An individual who is responsible for making the hiring decision or has responsibility for some aspect of the search process. For example, a supervisor, unit human resources (HR) representative, or an appropriate designee may serve as the hiring authority at different points of the search process. |
| Information Verification | The process whereby the hiring authority, the college/unit HR representative and/or the university’s authorized third-party vendor verify the education and employment (dates of employment, title, etc.) of an applicant or volunteer. |
| Intern, Paid | See Temporary Appointment. |
| Internal Applicant | A job candidate who currently holds a regular position at the university, or someone in an eligible employment status, such as layoff status or short-term disability leave. |
| Minor | Individual under the age of 18 who is not (a) a student as defined in Policy 8.8, The Protection of Minors and Abuse Reporting, or (b) an employee of the university. |
| Reference Check | The process of obtaining job-related information from prior/current employers regarding the performance and abilities of applicants for open positions. |
| Regular Appointment (All Colleges and Units Except WCM) | Employment in a non-temporary position of at least 20 hours per week with an expected duration of at least six months |
| Regular Employee (WCM only) | An employee who occupies a WCM position budgeted on the regular payroll system and is scheduled to work on a weekly basis. |
| Responsible Official | An individual, required by the federal government and designated by the university, who assumes the authority and responsibility to act on behalf of the university in regard to the Federal Select Agent Program. |
| Temporary Appointment (All Colleges and Units Except WCM) | Employment in a position of at least 20 hours per week with an expected duration of less than six months. Includes Paid Intern. |
| Unit | A college, department, program, research center, business service center, or other operating unit. |
| College/Unit Human Resource (HR) Representative | The primary human resource administrator at the college/unit level. |
| University Volunteer | An individual who performs services for and directly related to the business of the university, without the expectation of compensation. |
Responsibilities – All Colleges and Units Except WCM
The major responsibilities each party has in connection with this policy are as follows:
| Associate Vice President for Human Resources (or designee) | Lead efforts to review results of background checks and guide decisions to ensure adherence to relevant laws and regulations when evaluating applicants with criminal convictions. Support HR representatives in addressing questions resulting from concerns throughout other verification efforts. Review requests to conduct credit checks for positions below band G in the finance/budget/planning job family and for any position in other job families. Coordinate credit check review and approval process with the vice president and chief human resources officer, the executive vice president and chief financial officer (CFO), or their designees. |
|---|---|
| Environment, Health and Safety and Risk Management (EHS) | Initiate required security risk assessments for individuals and maintain a list of individuals that access or have a means to access select agents, as required by federal law and regulation. Maintain a list of individuals with unescorted access to select radioactive material or their associated security plans. Initiate security risk assessments as required by federal regulations, for individuals that have unescorted access to select radioactive material or their associated security plans. Consult with the college/unit HR representative or the hiring authority as to which positions are covered under the pre-employment drug and alcohol testing program and the related responsibility of the unit to arrange for testing of the newly hired staff. Communicate to college/unit HR and/or the hiring authority results of an applicant's negative pre-employment drug and/or alcohol testing. Communicate to Staff and Labor Relations the results of an applicant’s positive pre-employment drug and/or alcohol test. |
| Executive Vice President and Chief Financial Officer (or designee) | Consult with the vice president and chief human resources officer (or a designee) and approve requests to conduct a credit check, as appropriate. |
| Hiring Authority | Review relevant policies. Consult with the college/unit HR representative to:
Coordinate with the college/unit HR representative to retain detailed documentation of information obtained. Contact at least two of an applicant’s references, one of whom should be the current supervisor. After consulting with the college/unit HR representative, arrange for Department of Transportation (DOT) pre-employment drug and alcohol testing for an applicant, for DOT-covered positions. Conduct a specific reference check on an applicant for a DOT-covered position, obtaining information from prior employers about the applicant's testing history. |
| Staff and Labor Relations | Consult with departments on any positive pre-employment drug and alcohol test results. |
| Responsible Official | Act as the university’s liaison to the federal government in regard to the Federal Select Agent Program. |
| College/Unit Human Resource (HR) Representative | Review relevant policies. Maintain general oversight of the search process. Contact the Associate Vice President for Human Resources if a conviction is identified in the background check process. Contact Risk Management when a driving offense (no other conviction) is identified in the background check process. Consult with the hiring authority to:
Receive and review all reports from the university’s third-party vendor. Review and approve or deny requests from the hiring authority to extend contingent or conditional offers of employment before the completion of the information verification and/or background check process. Review and approve or deny requests from the hiring authority to extend a conditional offer of employment to an applicant contingent upon the completion of a medical exam and/or immunization. In coordination with the unit head, review and support requests to conduct a credit check, as appropriate. Note: With the approval of the unit head and the college/unit HR representative, credit checks may be requested for positions above and including band G within the finance/budget/planning job families. Credit checks for all other positions require additional approval in advance from the Associate Vice President for Human Resources, who will consult with the vice president and chief human resources officer and the executive vice president and CFO, or their designees. Note: All NYC-based positions - All requests to perform a credit check on an applicant for any NYC-based position (including positions above and including band G within the finance/budget/planning job families) must be submitted to the Associate Vice President for Human Resources to assure compliance with NYC law. After consulting with the hiring authority, notify EHS in writing that an applicant has been sent for pre-employment drug and alcohol testing. Coordinate with the hiring authority/supervisor to retain all records of the search and selection process appropriately. Contact and/or consult with the Office of Talent Attraction and Recruitment, Division of Human Resources, for general policy guidance. |
| Vice President and Chief Human Resources Officer (or designee) | Consult with the executive vice president and CFO (or a designee) to approve requests to conduct a credit check, as appropriate. |
| Office of Talent Attraction and Recruitment | Provide interpretation and guidance on the policy. |
Procedures - All Colleges and Units Except WCM
Overview
Units are required, through their hiring authorities and/or college/unit HR representatives, to conduct thorough reference checks, and education and employment verifications, on any applicants (internal or external) to whom offers of benefits-eligible employment are to be made.
Background checks are required as outlined in this policy, for those to whom a contingent offer of employment has been extended, for any of the following positions:
- Regular non-academic (staff and union) positions
- Benefits-eligible temporary non-academic (staff and union) positions
- Those positions identified in the Appendix regardless of the duration of appointment (covers all individuals regardless of current university employment/affiliation status)
Where a background check is required, an offer of employment must be contingent upon the satisfactory completion of the background check. The hiring authority must contact the college/unit HR representative before initiating the required reference check, information verification and/or background check process.
Note: In accordance with the university’s philosophy of a fair and unbiased hiring process, Cornell representatives will not ask an applicant to disclose information regarding criminal convictions until they have extended a contingent offer of employment. The reference checking, information verification and background check process is to be completed, with satisfactory results, before the first day of work. In a limited number of cases, and with the prior approval of the college/unit HR representative, Cornell will allow an individual to begin employment, unless working with minors, contingent upon the successful completion of these processes, with satisfactory results, within 30 days of their start date.
Confidentiality
All search-related materials are considered confidential and are to be shared only with those with a business need to know.
Reference Checks
A reference check is required for any applicant (internal or external) to whom an offer of benefits-eligible employment is to be made. The hiring authority or a designee must contact at least two of the applicant’s references (one of whom should be the most recent supervisor, if possible) before making an offer to any applicant. For an internal applicant, the current supervisor must be one of the references contacted.
Hiring authorities must contact the college/unit HR representatives for guidance if they cannot meet these requirements.
Applicants to whom the university intends to extend an offer of employment for a position listed in the Appendix are subject to the same reference check requirements.
Note: Applicants must complete a Cornell employment application, which includes a certification that all information provided (written or verbal) is truthful, complete, and accurate, and authorizes the university to investigate pertinent information about the applicant before information verification efforts (including reference checking) may begin.
Information Verification
Education and employment verification is required when filling benefits-eligible positions. Hiring authorities and/or college/unit HR representatives must complete all information verification efforts before the first day of work except in limited circumstances (see note below).
Applicants for positions listed in the Appendix are subject to the same information verification requirements.
Note: In a limited number of cases and with the prior approval of the college/unit HR representative, Cornell will allow an individual to begin employment contingent upon the successful completion of the information verification, with satisfactory results, within 30 days of the start date.
Background Checks
A background check is required for individuals to whom a contingent offer of employment has been extended for the following positions:
- Regular non-academic (staff and union) positions; external hires only
- Benefits-eligible temporary non-academic (staff and union) positions
- Those positions identified in the Appendix regardless of the duration of appointment (covers all individuals regardless of current university employment/affiliation status)
Hiring authorities and/or college/unit HR representatives must ensure all background check efforts are completed, with satisfactory results, before the first day of work except in limited circumstances (see note below).
Applicants to whom the university has extended a contingent offer of employment for a position listed in the Appendix are subject to the same background check requirements.
Note: In a limited number of cases, and with the prior approval of the college/unit HR representative, Cornell will allow an individual to begin employment contingent upon the successful completion of background check processes, with satisfactory results, within 30 days of their start date.
Cornell employees who work or volunteer with non-matriculated minors may need to meet additional requirements beyond this policy, such as undergoing repeat background checks. See University Policy 8.8, Protection of Minors and Abuse Reporting.
Initiating the Information Verification and/or Background Check Process (Third-Party Vendor)
The college/unit HR representative is responsible for submitting all orders for information verification and background check services to the university’s authorized third-party vendor, and for receiving and reviewing all reports. For additional information, please review the “Reference Checking, Information Verification and Background Check Chart,” below.
Funding the Cost of Information Verification and Background Check Efforts
The university has reserved funds for and will cover the cost and associated fees of information verification and background check efforts, as required by this policy. The requesting unit is responsible for covering the cost and associated fees of information verification and background check efforts for all other positions, and for any checks beyond those required by policy.
Frequency of Background Checks
If the college/unit HR representative has access to the satisfactory results of a background check that Cornell has completed on an applicant within 6 months before the intended date of hire, then the hiring unit may elect not to conduct another background check prior to the hire.
Retaining Records
Refer to the Guidelines to Support Filling Vacancies and “Retaining Records” section of the procedures of University Policy 6.6.1, Filling Vacancies (Excluding Academic and Bargaining Unit Staff) for university policy language on retaining records related to search activities.
Matrix: Reference Checks, Information Verification and Background Checks
The following chart identifies the required checks and verification efforts by position type and responsible party. The university reserves the right to utilize additional checks and verifications, as it deems appropriate, such as when there is a job-specific requirement. In such a circumstance, the university will apply this additional requirement to all positions with similar responsibility in the unit. See the footnotes below the chart for additional information regarding responsible party clarification and job-related checks.
Matrix: Reference Checks, Information Verification and Background Checks
| Position Type | Responsible Party | ||||
|---|---|---|---|---|---|
| Type of Check | All benefits-eligible positions [1] | All regular non-academic benefits-eligible positions, benefits-eligible temporary positions and all appointments to positions listed in the Appendix. [1] | Hiring Authority | Unit Human Resources | Third-Party Vendor |
| Reference Check [2] | X | X | X | ||
| Education Verification (highest degree completed) [2] [3] | X | X | X | ||
| Employment Verification | X | X | X | ||
| Cornell Employment History Review | X | X | X | X | |
| SSN & Identity Check | X | X | |||
| Sex Offender Database Search | X | X | |||
| Complete County and Federal 7 yr. Criminal Records Check for Felony and Misdemeanor Convictions | X | X | |||
Additional Job-Related Checks
| Job-Related | Hiring Authority | Unit Human Resources | Third-Party Vendor | ||
|---|---|---|---|---|---|
| Department of Motor Vehicles | If job related | If job related | X | ||
| Professional License and Certifications | If job related | If job related | X | ||
| Department of Transportation Drug and Alcohol Testing [4] (for positions requiring a CDL) | If job related | If job related | X | ||
| Credit Check [5] [6] (additional approval required; see footnotes for details) | If job related | If job related | X | ||
| Federal Debar List (US Government’s System for Award Management) | If job related | If job related | X | X | |
Offering Employment
For university policy language on offering employment, refer to Offering Employment in the procedures of University Policy 6.6.1, Filling Vacancies (Excluding Bargaining Unit Staff).
Offering Conditional Employment – Medical Examinations and Immunizations
For university policy language on requiring medical examinations and immunizations as a condition of employment, refer to Offering Conditional Employment – Medical Examinations and Immunizations in the procedures of University Policy 6.6.1, Filling Vacancies (Excluding Bargaining Unit Staff).
Appendix
Designated Positions
(Including All Academics, Non-benefits Eligible Temporary or Casual Hires and Internal Transfers, as well as Student and Volunteer Appointments as Indicated, in All Colleges and Units Except WCM [7]
| Appointment Type | Students/ Volunteers | All Other |
|---|---|---|
| Positions which require living in a student residential hall or other buildings where students reside. By extension, this includes any individuals over the age of 18 residing with live-on residential staff (“live-on occupants”). (Individuals in student positions without master key access and live-on occupants under the age of 18 are excluded). | X | X |
| Positions which include outreach work with minors. | X | X |
| Positions which require working with minors and present the possibility of care, supervision, guidance, or control of minors, including, but not limited to providing service as a child care provider or through a camp (as defined by New York State), summer college, internship or other similar situations. For annual or ongoing programs, see additional requirements in University Policy 8.8, The Protection of Minors and Abuse Reporting. | X | X |
| Positions which include the handling of select agents within the university’s Select Agent Program. Select agents are defined by the Federal Select Agent Program[8]. Cornell’s diagnostic laboratories (plant diagnostics in SIPS/CALS and animal diagnostics in AHDC/CVM) are specifically exempt from the requirement to perform background checks under the Select Agent Program. | X | X |
| President and other officers of the corporation, academic deans, vice presidents, and vice provosts | X | |
| Positions with transactional authority as defined in University Policy 4.2, Transaction Authority and Payment Approval, and any position that has been delegated such transactional authority | X | |
| Positions within the Cornell University Police Department | X | |
| Positions in the Health job family | X | |
| Positions with access to human medical records | X | X |
| Positions in the Information Technology job family | X | |
| Positions with responsibility for handling cash, checks or credit cards (excluding academics) | X | |
| Positions in Athletics and Physical Education which include travel with students or providing one on one instruction to students | X | X |
| Positions which allow administrative access to systems and databases containing sensitive data (university, unit, department, project). Examples of such access include installing programs, activating or deactivating databases, creating, changing, or removing user accounts. | X | |
| Positions which provide pass key access (grand master access, access to residence rooms and hotel rooms, housekeeping and custodial staff, service and maintenance staff) | X | |
| Positions which require a commercial driver’s license (CDL) covered under the Omnibus Transportation Act | X | |
| Positions with access to priceless/rare collections of material (i.e., some librarian/museum positions) or highly sensitive information | X | |
| Positions which involve the husbandry of vertebrate animals | X | |
| Positions which have key/card access to animal facilities and/or rooms where animals are housed or animal research is conducted | X | |
| If a conviction is disclosed on the Post Offer Conviction Disclosure form. | X |
Responsible Office and Policy Administration
| Policy Clarification and Interpretation | Email/Web Address |
|---|---|
| Office of Talent Attraction and Recruitment | mycareer@cornell.edu |
Responsible Executive
| Unit | Title |
|---|---|
| Human Resources | Vice President and Chief Human Resources Officer |
Revision History
| Date Issued | Ocotber 1, 2013 |
|---|---|
| Date of Full Review | July 1, 2019 |
| Date Last Updated | June 1, 2026 |
| Revision Notes | Non-substantial revision-Converted to HTML and updated contact information |
[1] Additional applicants/positions may be subject to a reference check, education and employment verification and a background check at the discretion of the Dean/VP or their designee.
[2] The “Responsible Party” may vary by unit. Contact your college/unit HR representative to determine who is responsible for these checks within your unit.
[3] Domestic education verifications may be conducted by the college/unit HR representative through the university’s membership with the National Student Clearinghouse. If no information is available from the clearinghouse, additional verification steps are required. All international education verifications will be conducted through the university’s authorized third-party vendor.
[4] The hiring authority and/or college/unit HR representative should contact EHS to request Department of Transportation Drug and Alcohol Testing.
[5] The college/unit HR representative, with the approval of the unit head, may initiate, through the university’s authorized 3rd party vendor, credit checks for positions above and including band G within the finance/budget/planning job families. Credit checks for all other positions require additional approval in advance from the Associate VP of HR, who will consult with the Vice President and Chief Human Resources Officer and the Executive Vice President and Chief Financial Officer, or their designees.
[6] Note: NYC-based positions -All requests to conduct a credit check on an applicant for any NYC-based position must be submitted to the Associate Vice President for Human Resources to assure compliance with NYC law.
[7] Hires who are under 18 are exempted from these requirements unless in a position requiring handling of select agents or one covered by the NYS Children’s Camp Regulations.
[8] Criminal record checks for applicants for positions working with select agents (Federal Select Agent Program) are conducted by the U.S. Department of Justice. Hiring authorities and/or college/unit HR representatives must contact the university’s Responsible Official at EHS in order to initiate the criminal information verification request to the Department of Justice.