Employment Background Check and Work Eligibility Policy Statement
US21 is committed to maintaining a safe, secure, and trustworthy workforce that meets federal contracting requirements. Background checks and work eligibility verification are essential tools for ensuring the suitability and legality of individuals in positions involving access to sensitive information, high-value assets, or vulnerable populations. This policy supports the protection of national security, the integrity of government operations, and the reputation of US21 by ensuring only qualified and authorized individuals are employed or contracted.
Compliance with the Fair Chance Act (FCA)
In accordance with the Fair Chance Act (FCA), US21:
- Will not inquire into or consider criminal history information until after a conditional job offer has been extended.
- Prohibits inclusion of criminal history questions on job applications and during initial interviews.
- Ensures that any criminal history considered post-offer will be directly related to the requirements of the position and consistent with government guidelines.
Scope of Background Checks
Background checks will be conducted based on the risk level and responsibilities of the position. Checks may include, but are not limited to:
- Federal Criminal Background Checks – required for all positions with system, facility, or data access.
- National Sex Offender Registry Checks – required for positions involving contact with the public or vulnerable populations.
- Driving Record Checks – required for positions with driving responsibilities.
- Credit History Checks – permitted only where legally permissible and relevant, such as financial management or procurement roles.
- Social Security Number Verification and Address History Checks – required for all positions to confirm identity and work eligibility.
- Specific requirements will be aligned with federal contract risk levels (low, moderate, and high risk) and may include investigations such as NACI, MBI, or full background investigations as required by government regulations.
Fair Credit Reporting Act (FCRA) Compliance
US21 will comply fully with the Fair Credit Reporting Act (FCRA). This includes:
- Obtaining written consent from applicants prior to conducting any background check.
- Providing applicants with a copy of their background check report and the “Summary of Your Rights Under the Fair Credit Reporting Act” before taking any adverse action.
- Allowing applicants a reasonable opportunity to dispute and resolve any inaccuracies before a final decision is made.
Equal Employment Opportunity Commission (EEOC) Guidelines & Non-Discrimination
US21 ensures that all background checks are conducted in compliance with EEOC guidelines. Specifically:
- Background check results will only be considered where job-related and consistent with business necessity.
- Employment decisions will not disproportionately exclude individuals from protected groups.
- Hiring managers and HR personnel will receive training to ensure consistent, fair, and non-discriminatory application of this policy.
E-Verify and Work Eligibility
In compliance with federal contractor requirements, US21 participates in the E-Verify program to confirm employment eligibility for all new hires and certain existing employees as required by law. Specifically:
- All new employees will be verified through E-Verify after completion of the Form I-9.
- Employees who cannot be confirmed as work-eligible through E-Verify will not be permitted to begin or continue work.
- E-Verify results will be maintained in compliance with federal recordkeeping requirements, and applicants will be informed of their rights to contest tentative non-confirmations.
- The company will not use E-Verify for pre-employment screening or to discriminate based on citizenship status or national origin.
Confidentiality and Data Security
All information obtained through background checks and employment eligibility verification is considered confidential. US21 will:
- Restrict access to records to authorized personnel only.
- Store records securely, in compliance with federal data protection requirements.
- Use the information solely for evaluating suitability for employment or contract performance.
Ongoing Monitoring
Where contractually required or operationally necessary, US21 may implement ongoing monitoring for certain high-risk roles. This may include periodic criminal history checks or continuous monitoring programs to detect changes in an employee’s or contractor’s eligibility status.
Policy Statement
US21 adheres to the Fair Chance Act and will not inquire into criminal history until after a conditional job offer has been extended. All background checks and work eligibility verifications for federal contract positions will be conducted in compliance with the Fair Credit Reporting Act (FCRA), Equal Employment Opportunity Commission (EEOC) guidelines, and federal E-Verify requirements. Information collected will remain confidential and secure. This policy ensures a fair, safe, legal, and compliant hiring process that protects the workforce, our federal partners, and the public we serve.