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8.3. SR 03-04-2013C'ry of Elk River REQUEST FOR ACTION TO ITEM NUMBER Mayor and City Council 8.3 AGENDA SECTION MEETING DATE PREPARED BY General Business March 4, 2013 Michael Hecker, Parks and Recreation Director ITEM DESCRIPTION REVIEWED BY Background Screening Policy Cal Portner, City Administrator REVIEWED BY ACTION REQUESTED Approve by motion, the City of Elk River Background Screening Policy. BACKGROUND /DISCUSSION During the development of the Field and Facility Use Allocation Policy, it became apparent that we had the need for a comprehensive background screening policy. National standards, as developed by National Recreation and Park Association and National Alliance for Youth Sports, recommend a policy to protect child safety through employee /volunteer background screenings. The city's current screening policy is limited to Minnesota crimes, leaving substantial gaps in the screening and lacks sufficient procedures to verify the identity of the person screened. The attached policy applies to all Parks and Recreation employees and volunteers who will or may be expected to have contact with children or vulnerable adults, as well as all Field and Facility Users' program participants who will or might have such contact, as a condition of the approval for a field and facility use permit. This applies to any youth sports organizations that use our athletic facilities. A survey of local youth organizations found they annually conduct background screenings for coaches and volunteers at a cost of $8 -19 per person. Our policy allows them be in compliance by conducting their own background screening, if it satisfies all the elements of this policy. Our policy proposes a more thorough screening every two years. City Attorney Mark Mathison assisted with the development of this policy and provided a more detailed analysis and consideration, which is attached for your information. FINANCIAL IMPACT Currently, background screenings for staff and volunteers are completed by the police department through the Bureau of Criminal Apprehension, which has never been a direct cost to the department. The estimated cost for background screenings under the new policy is $7,400, for all full -time, part -time, and seasonal employees, contract employees, coaches and volunteers in the department at $18.50 per person. If approved by City Council, we will budget $7,400 in 2014 for professional services. r P 0 W E R E 0 0 V A"URE ATTACHMENTS • Background Screening Policy • Attorney Memorandum Background Screening Policy POWERED 0Y IN AUE DRAFT FEBRUARY 2013 BACKGROUND SCREENING POLICY Background Screening: An Exercise of Reasonable Care The saying that a "bad volunteer is better than no volunteer" is untrue and dangerous, and should never be considered appropriate when selecting volunteers and employees, especially those who will work with children, youth, and vulnerable adults. While municipal parks and recreation departments and youth organizations across the country depend on volunteerism, failing to take reasonable steps to screen employees and /or volunteers for risk factors related to the roles they will play leaves such organizations, their volunteers and employees, and most importantly, their participants at unacceptable risk. While no background screening process can be absolutely comprehensive, and none can offer a guarantee of safety, the City of Elk River hopes that by implementing a strong policy and procedures will enhance public safety, engender public confidence, and reduce the risk of exposure to liability associated with failing to conduct reasonable background checks. The City believes that a thorough background screening process will assist the City and the community to provide quality programming in which safety is always the top priority. Policy Coverage This Background Screening Policy shall apply to: All volunteers and applicants for volunteer positions with the City of Elk River All applicants, employees and volunteers of City Field & Facility Use Permit holders (referred to throughout this policy as "Permit Holders ") who are18 years of age and above and who will be, or who reasonably may expected to be, working directly with children, youth or vulnerable adults in connection with performing services for the Permit Holder • To the extent permitted under City ordinance, to all applicants for, and employees in, paid positions with the City's Parks and Recreation Department who will or might have such contact. Policy Purpose To protect the safety and well -being of children, youth, and vulnerable adults participating in Parks and Recreation programs of the City of Elk River as well DRAFT as such persons participating in programs administered by Permit Holders, the City of Elk River considers thorough background screening to be an exercise of reasonable care, and has therefore adopted the following policy. Policy Responsibility The Parks and Recreation Director or his /her designee will be responsible for administration of this policy. The responsibilities of the Parks and Recreation Director under this policy shall include establishing all necessary forms and procedures for implementation of the policy, including but not limited to issuing forms for consent and notice to individuals who will be subject to background checks and the maintenance and enforcement of confidentiality standards. Policy Effective Date This policy shall become effective January 1, 2014, and shall be effective thereafter unless and until it is rescinded or otherwise modified by action of the City Council. Policy The City requires particularized background screening for all persons to whom this policy is made applicable in the section "Policy Coverage" above. Before any person covered by this policy may engage in any activity of the City or of the Permit Holder (as the case may be) that individual must pass a background screen as particularly prescribed by the City. As a condition of the City's grant of a Field and Facility Use Permit', all City Permit Holders must agree to certify that each of their employees, members, and volunteers who will work directly with children, youth, or vulnerable adults has passed a particularized screen prescribed by the City for such purposes, as set forth in this policy, before such employee, member, or volunteer may participate in any activity connected with the Field Use Permit of that organization. Each City Permit Holder must enforce the background screening requirements of this policy including the consequences resulting from a failed background screening report. The Permit Holder is responsible for the Background Check 1 A 30 -day grace period shall apply from the date of an individual's 18th birthday in order to allow time for the background screening to be processed. During the 30 -day grace period, the individual must be under the direct supervision by a qualified adult who has passed the background check. It is the responsibility of the individual, group, organization, and association to identify the individuals in this situation and to meet the background screening requirement. Upon the conclusion of the 30 -day grace period, the individual may not participate unless the background screening requirement is met. 2 DRAFT fee, which may be billed directly to the Permit Holder. The Permit Holder may elect to require its participants to pay the Background Check fee. Failure of the Permit Holder to comply with the requirements of this policy will have consequences that may include suspension and revocation of the Field and Facility Use Permit and other privileges. Each City Permit Holder may also in its discretion choose to require other members of their organization to pass the background screening procedure prescribed by this policy. The City's particular background screen prescribed for its volunteers and employees and others to whom this policy applies will in each case be narrowly tailored to the particular position with the City or the Permit Holder held or applied for by the individual. The City will comply, and requires Permit Holders to comply, with all applicable laws regarding background screening. Written (or appropriate electronic) consent must be obtained from each individual who is proposed for a background check by the City or Permit Holder. The City will pay the Background Check fee for its own employment applicants, employees, and volunteers and volunteer applicants, but not for those background checks requested by Permit Holders in compliance with this policy. An appropriate notice of rights must be provided to all such individuals, including notice of his or her right to initiate a dispute with the City's Background Screening Provider over the content of such background check in certain circumstances and to be provided with a copy of any background report relied on by the City or the Permit Holder to disqualify the individual from participation or employment with the City or Permit Holder. Any individual failing a City - prescribed background screening shall not be considered or screened for any position or participation with the City or Permit Holder to which this policy applies for one year from the date of the failed screen's having been conducted. Frequency Each individual required by this policy to be screened shall have a duty to self - report immediately to the City or Permit Holder (as the case may be) any subsequent conviction or other event for which a background screen was conducted at the outset of their employment or participation. In addition, each person to whom this policy applies shall be subject to re- screening every two years, or at such other interval as the City may from time to time determine in its discretion. DRAFT The Screening Process The Parks and Recreation Director shall prescribe procedures for conducting background checks using the City's electronic database and software. The guiding principles and standards for such procedures are set forth below. The Parks and Recreation Director shall prescribe to the Screening Provider the particular background data to be considered for each particular position and the requirements for passing the screening. Background check reports will be delivered by the Provider on a pass -fail basis only into this database and will be secured with access limited as set by the Parks and Recreation Director or his /her designee for each particular context in which backgrounds checks are to be conducted. An individual who does not pass the background screening shall be given required notices relative thereto in accordance with the federal and state Fair Credit Reporting Acts, including but not necessarily limited to a copy of the "Summary of Your Rights under the Fair Credit Reporting Act ", notification that the individual is disqualified from employment or participation, and information on how to dispute the results of the screening. The City of Elk River Parks and Recreation Department is a national affiliate of Operation TLC2 Making Communities Safe, a background screening program of the National Recreation and Park Association (NRPA) administered by Southeastern Security Consultants, Inc. (SSCI). SSCI specializes in conducting background checks for volunteers in accordance with parks and recreation industry standard and best practices. The NRPA has reviewed the resources of the National Association of Professional Background Screeners, and sought the counsel of recognized background screening experts to develop a set of recommended guidelines for volunteer background screening. The procedures in this policy have generally been set in accordance with NRPA agency accreditation standards for parks and recreation agencies and NRPA recommendations for a parks and recreation volunteer background screening policy. Every individual required to submit to a background screening must complete, sign, and date the Consent and Waiver Release Form. Electronic signatures maybe acceptable in accordance with applicable law. All consent forms must be submitted to the Recreation Division of the Elk River Parks and Recreation Department or to the Permit Holder, whichever is the party to whom services will be rendered by the individual, no later than the date designated by such party. Failure to provide a completed consent form by an announced reasonable deadline may disqualify the individual from participation and /or employment. Falsification of information on any application or the consent/release form is grounds for disqualification /revocation /dismissal. 11 DRAFT Upon receipt of the consent form by the City Parks and Recreation Director (or his /her designee) or by the Permit Holder, the party receiving the consent will request that SSCI perform the background check of that individual. What the Screening Will Entail The prescribed background screening to be conducted under this policy shall include a search of at least the following sources for particularized data identified as relevant for the position proposed to be held by the individual presented for screening: Social Security Trace. Verifies that the person is who they claim to be. The social security trace provides a history of past and present addresses and names associated with the applicant's social security number, including maiden names and aliases Address Trace. To confirm jurisdictions in which the person has lived during the period to be searched. The address trace confirms current and past addresses to determine the jurisdiction(s) in which the background check will be conducted. State or County Criminal Record Search. In particular jurisdictions selected based on the address trace, searches will be conducted of appropriate criminal records that are job- or participation - related and consistent with the necessity of protecting the safety of our children, youth, and vulnerable adults. National Database Search. A search shall be conducted of a reputable, regularly updated private national database as a means of supplementing (not replacing) the thorough state and county criminal history search. Sex Offender Registry. A search shall be conducted of all 50 State repositories and the District of Columbia for known, registered sex offenders. Alternative Screening Process and Service Providers Upon application to, and approval by, the Parks and Recreation Director, a Permit Holder may alternatively comply with this policy by conducting background screening that satisfies all the elements of this policy using a background service provider and database and software other than those prescribed by the City under this policy. The Parks and Recreation Director shall provide a form for Permit Holders to seek such approval, which form shall state the criteria for granting the approval sought. Consequences to Field Use Permit Holders for Failure to Comply Failure of a Permit Holder to comply with this policy to the satisfaction of the City shall be cause for the City to impose suspend or revoke a Field Use permit DRAFT and /or to assess fees and /or extended suspensions against responsible individuals and /or the Permit Holder. Confidentiality The City shall prescribe to the Screening Provider the data to be considered for each particular position and the requirements for passing the screening. Background screening results will be reported into a secure restricted - access database on a pass -fail basis. All information received as a result of the screening shall be treated as confidential private data on individuals and used or disclosed only in accordance with the Minnesota Data Practices Act and other applicable law. Generally, for volunteer and employment positions with the City, the screening results will be available only to the Recreation Manager and his /her background screening designee, the Parks and Recreation Director, the Chief of Police and the City Attorney. Permit Holders shall be responsible for maintaining the confidentiality of background check reports and related information as appropriate within their organizations and for identifying those persons who shall have access to the screening results. In all events, such information must be used solely for the purposes of compliance with this policy. Note is made that in limited circumstances, the City may have a legal duty to disclose such information to third parties, including government agencies. Securing and Retaining Screening Results The City of Elk River is responsible for securing the results of criminal background checks conducted pursuant to this Policy that are reported to the City in an electronic database and retaining them for the time period required by law, or seven years, whichever is greater. Disputes In the event an individual who has been subject to a background check under this policy wishes to dispute the information on which a background check report has been based, the individual must initiate such directly with the Background Check Provider (generally, SSCI). The City of Elk River shall not be responsible for conducting or participating in any such dispute. The resolution of any such dispute shall be governed by the federal and Minnesota Fair Credit Reporting Acts and other applicable law. The City of Elk River and its employees are not responsible for errors or omissions that may be contained in any background check report made under this policy. 31 DRAFT Each approved group, organization, and association is required by this policy to accept the findings of the City of Elk River approved background screen vendor and enforce the disqualification. Non - waiver Nothing in this policy shall be construed as a waiver or limitation of the discretion of the City of Elk River to disqualify an individual for a position with the City as an employee or volunteer when, in the sole opinion of the City of Elk River, such disqualification is in the interests of the City of Elk River and not inconsistent with applicable law. GP:3324618 v5 7 MEMORANDUM TO: ELK RIVER CITY COUNCIL FROM: MICHAEL HECKER MARK MATHISON RE: BACKGROUND SCREENING POLICY DATE: FEBRUARY 28, 2013 EXECUTIVE SUMMARY Today we present for consideration and adoption by the Council a new policy on background screening that is proposed to be effective January 1, 2014. As drafted, this policy would apply to all Parks & Recreation Department applicants and employees who will or may be expected to have contact during the course of their performing services for the City with children, youth, or vulnerable adults. In addition, this policy would also apply to require background screening of all Field & Facility Users' program participants who will or might have such contact, as a condition of the grant or continuation of a Field & Facility Use permit. Parks and Recreation would be responsible for administration of this policy as written. The background screening proposed under this policy is broader than the screening the City has done in the past for employees and volunteers under the current City ordinance. The new screening would be conducted by a vendor to the City and be integrated into the current software and secure database in use at Parks & Rec. This will logistically streamline administration of the new screening system. The cost for each background screen is a reasonable $18.50, though this is a significant increase in cost over the City's current practices that will require budget planning. In preparing and proposing this policy, careful attention has been paid to the many competing practical and legal considerations that come into play for a municipality with respect to background screening. We believe that the screening proposed here represents a reasonable effort to enhance the safety of the most vulnerable populations we serve. The policy is designed so that its administration will simultaneously observe the rights of individuals to be screened and related duties of the City. We believe this policy represents the City's best opportunity to balance the variety of competing objectives in this context. BACKGROUND SCREENING CONSIDERATIONS The proposed policy will require thorough background screening of individuals who in connection with City service or facility use will have, or might reasonably be expected to have, contact with children, youth, or vulnerable adults. The current scope of background screening is significantly more limited than the screening proposed here. The motivation to do a more thorough background screening arises from recognition of the fact that not all background screening is created equal, and there are virtually an endless variety of possibilities in terms of what sources a screen actually uses as well as the disqualifiers it applies in any particular circumstance. As we understand it, the scope of the City's current screening is basically limited to Minnesota crimes committed, leaving substantial gaps in the screening effort and potentially lack sufficient procedures to verify the identity of the person screened. The motivation to ensure strong screening is somewhat in tension with competing legal considerations. This complex of issues requires a balancing act by the City of its rights, duties, and motivations. Like other public and private employers, the City could potentially face liability for failing to screen, or for hiring or allowing an ex- offender to be in contact with vulnerable populations in performing services for the City or those who use its facilities on the other hand, the City must balance potential liability for violating the rights of individuals by conducting background screens that may not be directly job - related or that are overbroad in other respects under state or federal law. Including the City's own ordinance, the web of laws applicable to background screening is dense and complex. This memo does not attempt to set out all of these laws and their application to the City or its field users in various circumstances. Some of the most notable applicable laws that must be taken into consideration include the following: • Federal Fair Credit Reporting Act and Minnesota Access to Consumer Reports Act o These statutes require certain notice and disclosure to individuals to be screened and provides avenues for dispute of screen's accuracy • Federal Title VII and related Discrimination Laws & Minnesota Human Rights Act o These laws apply to employment and in that context preclude the City from excluding individuals based on criteria that are not directly job - related or that are too old or too speculative. Consideration of arrests, as opposed to convictions, is especially problematic under these laws. In essence, these laws require targeted screening based on an individualized assessment of the job or role to be performed by the individual in question. Only appropriate disqualifiers will pass legal muster, based on this particularized assessment considering especially the nature of the crime, the nature of the job or role, and the time elapsed since the offense. Minnesota Criminal Offenders Rehabilitation Act. o This statute applies to the City and limits how and when the City may require background screening for employment other than police and fire employment. It also prohibits exclusion from employment based on older crimes and arrests, among other things. 2 • Minnesota Child Protection Background Check Act and Federal Serve America Act o This federal law requires organizations whose employees work with vulnerable individuals (children, the elderly or disabled) to complete a background check on those employees, including state and federal criminal history check and a search of the predatory offender database. Appropriate consent must be provided by the employee. The Minnesota law permits, but does not require, such background screening, and creates a system and procedure for the BCA to conduct such checks. The price of such a BCA check is higher than the price of the TLC /SSCI check proposed under this policy. • Minnesota Government Data Practices Act o This statute governs the confidentiality and potential for disclosure of criminal history information obtained by the City. • Ordinance o To conduct background checks the City must have an ordinance in place; a resolution of the Council will be insufficient under state law beginning in 2015. The current City ordinance states that the police department exclusively conducts background screening for employment purposes. The current ordinance would not need to be changed to permit the background screening contemplated by this policy for volunteers and field users. Change is required, however, before the policy can be applied to Parks and Recreation employment applicants and employees. The policy specifically calls out that no such application will occur unless and until such ordinance change has been effected. NOTABLE POLICY FEATURES Some description and explanation of the proposed policy's most notable features follow here. • The Background Screening policy will become effective January 1, 2014, if approved by the Council. • The Background Screening policy will be tied in with the new Field Use policy such that field and facility use permit holders will be required to comply with the Background Screening policy. The database and software that will be used by the City (which is already in place for other purposes) will be available to the permit holders, and will be the preferred system for handling the screening requirement. Permit holders may also comply, however, by applying to the Parks and GP:3360150 dl Recreation Director for permission to conduct an equivalent background check using a different system and vendor and certifying that the alternative meets the requirements of the policy. • We have determined that the vendor TLC /SSCI provides a thorough screening process at a reasonable price and that the City will be able to customize the screening process with the vendor so that the City can appropriately manage its compliance with Minnesota and federal law according to its own consideration and interpretations. • In order to conduct appropriately customized screens for particular positions and roles with the City and field users, the Parks and Recreation Director will work with legal counsel to develop particularized screening criteria to be used in each case. The disqualifiers for one position may not be the same as those for another position. This analysis will take into consideration factors such as the essential functions of the position, the relevant crimes and duration of disqualification related to each, and will record the analysis and justification for disqualification. Staff who will be responsible for its administration will need training in application of this policy. • The City may not require applicants for its positions to pay the cost of the screen and will need to budget for this expense. Field users may consider and set their own policy on the payment of fees. 11 I - COO* r-- flG O a CO#* t-- O P-N i k- , rte. 5,04- . ., ". L U �0 ru 4— 0 (1) .LA a� x w L V (n �0 cu w ar� C:4. 00 ■ ■ ru zL�U 0-5 V) �V) C:u 00-cu :3 —(1) 010 O (1) C: (L) cl� • • • • ASSOC/ QQ q�i 4 O Z 0 LLI zi J� J Q r 4 �- . 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