Purpose

To support Kalamazoo College’s commitment to providing a safe, secure campus community and to protecting institutional assets, the College may conduct periodic criminal history and sex offender registry reviews of existing non-student employees. This procedure outlines the process, scope, and follow-up steps associated with those reviews

Scope

This procedure applies to all current non-student employees of Kalamazoo College, including faculty, staff, adjuncts, visiting appointments, temporary employees, and volunteers.
These procedures supplement the Criminal History section of the Background Check Policy and apply when the College initiates a review for existing employees rather than candidates.

1. Review Cycle and Initiation
   • Routine Cyclical Reviews
     Human Resources (HR) may conduct criminal history and sex offender registry reviews on a cyclical basis (e.g., every 5 years or another interval set by HR and senior leadership). HR will establish and communicate the cycle to faculty and staff.
   • Position-Specific or Business-Need Reviews
     HR may initiate a review at any time if:
     • HR or Campus Safety receives information suggesting a review is warranted.
     • Required by law, regulation, licensing rules, insurability, or grant conditions.
   • Narrowly Tailored Searches
     Reviews will consist of criminal history checks and sex offender registry searches appropriate to the employee’s work responsibilities, consistent with the Background Check Policy.
2. Notice and Consent
   • Employee Notification
     Prior to conducting a review, HR will notify the employee in writing that a criminal history and sex offender registry review will be conducted.
   • Consent
     If required by law or by the third-party vendor used, HR will obtain appropriate consent.
     Failure to provide necessary consent may affect continued employment eligibility.
3. Conducting the Review
   • Sources of Information
     Checks may include:
     • County, state and national criminal record databases
     • State and national sex offender registries
     • Third-party agencies providing background screening
   • Fair Credit Reporting Act Compliance
     If a consumer reporting agency is used, the College will comply with the Fair Credit Reporting Act (FCRA), including pre-adverse and adverse action notification requirements.
4. Review of Findings
   • Initial Assessment by Human Resources
     HR will review the results to determine whether any information may reasonably relate to the employee’s position.
   • Criteria for Evaluation
     Consistent with the Background Check Policy, HR will evaluate factors including:
     • Time elapsed since the conviction
     • Evidence of rehabilitation
     • Record of employment at Kalamazoo College
     • Accuracy and disclosure of information
     • Relevance of the crime(s) to job duties
     • Potential risk to individuals, institutional assets, or campus safety
   • No Findings of Concern
     If no relevant items of concern are found, HR will notify the employee that the review has been completed.
5. Findings That May Be of Concern
   • Employee Notification and Opportunity to Respond
     If the review identifies items of potential concern, HR will:
     • Notify the employee of the findings
     • Provide a reasonable opportunity for the employee to review, verify, and respond to the information
     • Provide FCRA-required notices when applicable
   • Internal Review Process
     After receiving the employee’s response (or after the response window has closed), HR will review the matter with:
     • The Division Head (or designee), and
     • The employee’s supervisor, if deemed appropriate
       For faculty members, the review will be conducted by the Provost (or designee) and the Department or Division Chair, in accordance with the Plan of Employment for Faculty.
   • Final Review and Decisions
     If consensus cannot be reached, HR and the Division Head (or designee) will consult with the Vice President for Business and Finance before a final decision is made. The President may be consulted as appropriate.
   • Possible outcomes include (but are not limited to):
     • No action
     • Written guidance or expectations
     • Transfer to another position for which the employee is qualified
     • Written reprimand
     • Disciplinary action
     • Termination of employment
6. Confidentiality and Records Management
   • Secure Handling of Records
     All reports, memoranda, correspondence, and notes related to employee criminal history and sex offender registry reviews will be maintained in confidential HR files, separate from general personnel records.
   • Access Restrictions
     Access to review results will be limited to the employee, HR staff and College officials directly involved in the evaluation and decision-making process.
7. Relationship to Existing Policy
   This procedure supplements Section A (“Criminal History Checks”) of the Background Check Policy. Where inconsistencies exist, the Background Check Policy governs.
   
   Kalamazoo College reserves the right to modify, eliminate, or make exceptions to this procedure at any time.

Process

Provide notice to all faculty and staff of the intent to periodically conduct reviews of criminal background and sex offender database information on existing faculty and staff.

Phase I: 2026 (Position-driven selections)

• President
• Vice-Presidents/Provost
• Direct reports to VPs/Provost
• Human Resources
• Campus Safety
• Residence Life

Phase II: 2027+ (Last digit in employee ID number*)

Last digit in Employee ID#	Review Year
0, 1	2027, and every fifth year
2, 3	2028, and every fifth year
4, 5	2029, and every fifth year
6, 7	2030, and every fifth year
8, 9	2031, and every fifth year

*Excludes those for whom the same procedure was conducted within the previous 60 months.