Policy for Criminal Offender Record Information (CORI)

Emerson College requires Criminal Offender Record Information (CORI) checks as part of a general background check for employment at Emerson College in positions that require unsupervised work with minors or have unmonitored access to dorms. Emerson will follow the practices and procedures set forth in this policy when conducting CORI checks for those identified positions:

I. Authorization

CORI checks will only be conducted as authorized by CHSB (Criminal History Systems Board). All applicants for employment will be notified if a CORI check will be conducted for the position they seek. Similarly, if the College determines that it is necessary to check an existing employee’s CORI record, the College will first notify the employee of the College’s intent to conduct such a CORI check. Applicants for employment and College employees will be provided with a copy of Emerson College’s CORI policy upon request.

II. Training

An informed review of a criminal record requires adequate training. Accordingly, the Office of Human Resources personnel authorized to review applicants’ and employees’ CORI records will be thoroughly familiar with the educational materials made available by CHSB. Applicants’ and employees’ CORI records will only be viewed and considered by College administrators who: a) are involved in assessing the individual’s suitability for employment in a particular position, and b) are specifically authorized by the CHSB to view CORI information.

III. Disqualification

Unless otherwise provided by law, a criminal record will not automatically disqualify an individual from employment at Emerson. Rather, the College will make determinations of suitability based on CORI checks consistent with this policy and any applicable law or regulations.

IV. Confirmation of Identity

When the College requests and receives an applicant’s or employee’s criminal record from CHSB, Emerson College’s Employment Manager will closely compare the record provided by CHSB with the information on the CORI request form and any other identifying information provided by the applicant or employee in question, to ensure the record relates to the applicant or employee.

V. Notification

If Emerson College is inclined to make an adverse employment decision based on the results of a CORI check, the applicant or employee will be notified immediately. The applicant or employee shall be: a)provided with a copy of the criminal record that Emerson received from CHSB; b)advised of the part(s) of the record that make the individual unsuitable for the position, and c) given an opportunity to dispute the accuracy and relevance of the CORI record.

VI. Challenge

Applicants or employees who wish to challenge the accuracy of their CORI record shall be provided a copy of CHSB’s Information Concerning the Process for Correcting a Criminal Record. If an individual’s CORI record does not exactly match his or her identification information, the Associate Vice President for Human Resources will make a determination of the reliability of the CORI record. . The Associate Vice President for Human Resources or the Employment Manager may contact CHSB and request a detailed search consistent with CHSB policy.

VII. Determining Suitability

If the Employment Manager and the Associate Vice President for Human Resources reasonably believe the record belongs to the applicant and is accurate, then they will rely upon the record when determining the individual’s suitability for employment in a given position. Unless otherwise provided by law, factors considered in determining suitability may include, but are not be limited to the following:

(a) Relevance of the crime to the position sought;
(b) The nature of the work to be performed;
(c) Time since the conviction;
(d) Age of the candidate at the time of the offense;
(e) Seriousness and specific circumstances of the offense;
(f) The number of offenses;
(g) Whether the applicant has pending charges;
(h) Any relevant evidence of rehabilitation or lack thereof; and
(i) Any other relevant information, including information submitted by the candidate or requested by the hiring authority

VIII. Timeliness

If the College decides to take an adverse employment action against an applicant or employee because of his or her CORI record, the Employment Manager will notify the applicant of the College’s decision and the basis of the decision in a timely manner.