Pre-employment screening

Before commencing work with the University there are some pre-employment screening checks that all staff must complete and some that need to be completed depending on the role.

Right to work - proof of right to work
Health checks - pre-employment assessment
DBS - DBS introduction

Employment screening - agenda

Screening protocol for employees working in, or connected to, areas at the University with animal welfare/research facilities/IT Service roles requiring screening

The University undertakes certain pre-employment screening for all appointees as part of the recruitment process including right to work checks, references and health checking. For positions in particularly sensitive areas or in areas that are deemed to be 'higher risk', more detailed pre-employment screening needs to be carried out.

Employees who have direct contact with animals, have unsupervised laboratory use and/or access to secure areas/laboratories associated with animals or employees who may have knowledge of information about animals/animal research (such as personal details of researchers, access codes, licensing information etc.) require additional pre-employment screening. Additionally, employees working in an IT Services role requiring screening, (IT Operating Board, Security, Infrastructure, Networks, Cloud Services and Research IT) will also have additional pre-employment screening. Once a candidate has been successful at interview and offered a post, they will need to undergo pre-employment screening which will be carried out by an external agency (which may determine confirmation of appointment).

Pre-employment screening will be carried out in compliance with the UK Data Protection Act 2018, and all candidates will be advised during the recruitment process that screening is required, what the screening will cover and the reason for it. Any candidates undergoing pre-employment screening will be informed of the outcome of the screening.

The University reserves the right to change the frequency and level of screening and re-screening if it identifies a significant increase in risk, either in individual cases or in the external environment.

Any person who is working in the animal facilities, but is recruited in another way (PhD student, existing staff) will be subject to screening prior to gaining access to the animal facilities.

The screening agency holds the ISO27001 standard (Information Security Management) and its fully screened staff are trained in the handling of personal information ensuring that all information submitted is held and destroyed confidentially.

Aims

The aim of this protocol and guidance is to ensure that the University:

Recruit suitably qualified and experienced staff who are dedicated to provide the highest standard of care for animals they are responsible for and provide opportunities for continual professional development
Highlights potential infiltration of positions by animal rights activists or terrorists - our pre-employment screening process should be sophisticated enough to allow us to spot candidates who may have strong views about the use of animals in research
Safeguards its reputation and is at the forefront of best practice in this area
Complies with Home Office regulations.

The university also aims to ensure that there is fair and equitable treatment of all potential employees working within animal welfare/research facilities at the University.

Principles

There are a number of "types" of staff who have access to the animal welfare/research areas and the 'risk' will determine the level of pre-employment screening.

High

This position/type has direct contact with animals and has unsupervised animal laboratory use or access to secure animal areas/laboratories. High level pre-employment screening is required. Roles may include Technicians and Researchers.

In exceptional circumstances, it may be beneficial for the external agency to carry out the full recruitment process including advertising, interviewing and screening. If this is required then further information can be obtained from the Employee Services Team Leader (Recruitment) in HR.

Medium

There is some contact and access to secure areas but this would always be supervised and/or there is access to sensitive information only. These posts would be recruited for by the University but need to have lower level pre-employment screening carried out by an external agency. Roles may include cleaning staff and research administrators.

Low

Other than the normal pre-employment screening carried out for all staff by HR Services no further screening is required.

The appointing Faculty will need to confirm to HR the level of check required, based on the definitions above and the level of risk.

Procedure

Pre-employment screening

Where pre-employment screening over and above normal recruitment checks is required, then information will be included in the Further Particulars for the job.

The HR contact will act as the contact point with the external agency (Agenda). Pre-employment screening will be carried out by the external agency for the successful candidate only.

All individuals requiring pre-employment screening will be sent an email from HR to inform them of the process with Agenda. Agenda will email them with a link to the online portal where information will need to be submitted in order for the screening to take place. The email will also inform the individual of the opportunity to self-disclose any relevant matter prior to the screening taking place. Any information submitted by the individual will be considered by HR immediately and dealt with in the same way as if the information had been disclosed as a result of pre-employment screening. HR will confirm to the candidate if they are required to continue with the screening process or whether, based on the information provided, the offer of employment/new role will be withdrawn.

The HR contact will receive the screening outcome/results.

If any issues are highlighted from the screening for the successful candidate then these will be discussed with the Chair of the interview panel, the relevant HRBP for the College and the College Pro-Vice-Chancellor. If, as an outcome of the screening, the appointment is not going to be confirmed then HR will confirm this to the candidate. The candidate will be given the opportunity to submit any further information that may be considered to the Director of HR (or his/her designate) and the License Holder. There will be no right to appeal.

Once a decision has been made only the letter confirming or withdrawing the offer of employment will be held on the individuals HR file. The screening information will be confidentially destroyed.

This process will take place every three years for any post graded as a risk during the employment of the candidate or for existing employees moving to work in these areas. Should the screening highlight issues during the course of their employment then this may lead to disciplinary action and potentially the dismissal procedure being evoked.

Other Screening (Students/existing employees/long term visitors etc)

The Biological Services Unit management (BSU) contact will act as the contact point with the external agency.

All individuals requiring security screening will be sent an email from the BSU to inform them of the process with Agenda. Agenda will email them with a link to the online portal where information will need to be submitted in order for the screening to take place. The email will also inform the individual of the opportunity to self-disclose any relevant matter prior to the screening taking place. Any information submitted by the individual will be considered by HR immediately and dealt with in the same way as if the information had been disclosed as a result of security screening. HR will confirm to the candidate if they are required to continue with the screening process or whether, based on the information provided they cannot work in the BSU facilities.

The HR contact will receive the screening outcome/results.

If any issues are highlighted from the screening for the subject then HRBP will be informed. The HRBP will discuss with the Head of Biological Services and the line manager. The candidate will be given the opportunity to submit any further information that may be considered to the Head of Biological Services (or his/her designate) and the Line Manager before a decision is made.

Re-Screening

This process will take place every three years for any individual needing continuing access to the animal facilities. The above process will be followed.

Should the screening highlight issues during the course of their employment then this may lead to further action including suspension of access to animal facilities.

Guidance

Screening requests from the University must be responded to promptly and completely in order for the process to be done efficiently, and for the subject to be informed of the outcome as soon as possible. Any delays may result in the screening process being 'timed-out' which will require a full re-submission, at extra cost to the University and will prevent the confirmation of appointment and/or access to anical facilities until the outcome of the screening is known.

Levels of pre-employment screening

All low risk posts will undergo normal pre-employment screening carried out by HR Services - Employee Services. The table below shows the screening that will be carried out for all successful candidates for high and medium roles and also for existing employees who are changing position to a role where screening is required. Staff categorised as high/medium risk will need to be screened every three years.

	External candidate Screening - High	Internal Candidate Screening - Medium
Identity Confirmation - An essential element, which includes positive identification with verification and validation of identity documents	x
Internet Mining – obtains details of internet activity including social media, publications, associations and comments	x	x
3-year Employment History – Verification of employment history	x
Employment Gap Analysis – Confirmation of gaps	x
Media Search – Extensive check of media sources in relation to the candidate	x	x
Sanctions Search – checks of over 100 lists detailing over 160,000 individuals identified as fraudsters, extremists or carrying significant risk to organisations	x	x
Basic [Criminal Record Check] - DBS	x
Personal Credit History – confirmation of credit history and outstanding judgements	x

Staff Table

Below are a list of positions that may require a level of screening depending on their role and the level of access to facilities or information.

Technicians
Academic Staff
Research Staff
Support staff including: Finance, Research Group Finance, HR, Cleaners (unsupervised access) and Maintenance staff (Unsupervised access).

This list is not exhaustive. There may be other positions within the University where screening is necessary and these will be identified by HR or Biological Servces business needs.

Pre-employment screening - Security clearance

The University undertakes certain basic pre-employment checks for all candidates as part of the recruitment process including right to work checks, references and health checking. For positions in particularly sensitive areas or in areas that are deemed to be 'high risk', more detailed pre-employment screening needs to be carried out.

Candidates or existing employees who will be working on government contracts in areas such as defence, or have an opportunity through their role to damage, lose or compromise government assets require additional screening. Also anyone requiring access to Government 'Official Sensitive' material must hold a minimum Baseline Personnel Security Standard assurance (Basic Check).

Depending on the employee's role, the screening will be at one of these levels:

Basic Check
Counter Terrorist Check
Security Check
Developed Vetting

At the present time, the University of Exeter is not a 'sponsor' organisation and so is only able to process Basic Checks. This protocol outlines what an employee will need to do to obtain a Basic Check and also gives an over view of all checks should an individual be required by an external Sponsor for a higher level check.

Aims

The aim of this protocol is to ensure that the University:

Recruits suitably qualified and experienced staff who understand the importance of confidentiality and discretion required for this work
Meets corporate responsibilities and supports applications for grants and funding
Supports sponsors, where possible, to highlight potential infiltration of positions by terrorists or groups/individuals who wish to subvert or damage the stability of the UK and /or threaten UK interests
Safeguards the University and any Sponsors reputation and is at the forefront of best practice in this area
Ensures that there is fair and equitable treatment of all potential University employees working on government contracts or have roles that could damage, lose or compromise government assets
Complies with Cabinet Office regulations.

Process

All potential employees undergo screening when applying for a position at the university. This comprises of Right to Work checks, reference and health checking. This protocol sets out more detailed screening that will be carried out for employees who will be working with confidential government information at a Basic Check level either at the point of their recruitment or when necessary during their employment i.e. in the event that a grant application required security clearance at a Basic Level. Where a post requires higher level checks then the relevant external sponsor will discuss this with the employees direct.

It is the Faculty/Service’s responsibility to highlight the need for a security check (normally this will be because of a requirement in a grant application). The employee / PI will work closely with the HR contact within Employee Services to organise and complete a Basic Check (PD52 will need to be completed) and if additional level checks are required then the employee will work with the relevant sponsor (research body, government department) to complete the relevant questionnaire from the MOD and submit it.

If any issues are highlighted from the Basic Check, then these will be discussed with the employee and their PI/ line manager, the Head of the Faculty and Sponsor if relevant. The employee will be given the opportunity to submit any further information that may be considered to the Director of HR, to make a final decision in consultation with the Faculty Dean. There will be no right to appeal. If the Basic Check cannot be confirmed then the employee will not be able to state that they have clearance on any grant applications.

A copy of the PD52 form (Basic Check) will be kept on the employees file. The cost of a Basic Check will be covered by the appointing Faculty (this will cover the cost of a Standard DBS check). The Faculty will also have to budget for these posts being screened again, three years after authorisation/issue or sooner, if there is a change to the role/individual’s circumstances.

All clearance checks have an expiry check (except the Basic Check) and the sponsor will contact the individual direct when they need to be reviewed. For Basic Check renewals the University recommends these be rechecked every three years and HR Services will contact the employee for renewal. Should the screening highlight issues during the course of their employment then this may lead to disciplinary action and potentially the dismissal procedure being evoked.

The above process will be the same should a successful applicant need to undergo a security check during the recruitment process in order to carry out their new role.

Transfer

When a person holding a Counter Terrorist Check/Security Check/Developed Vetting clearance transfers or moves to a new employing organisation, there may be a continuing requirement for them to hold a security clearance whether at the same or lower level. Further information on transferring checks can be found at www.gov.uk/security-vetting-and-clearance.

As the University is not a sponsor organisation, we would not be able to request a security clearance to be transferred. A Basic Check cannot be transferred.

Guidance

There are a number of reasons why employees may have access to information that is classed as confidential on the grounds of National Security. The appropriate level of check is therefore crucial.

Levels of Government security clearance

Basic Check	Most basic level of check and although not a formal security clearance check it must be completed before any of the checks below can be carried out. HR will carry out these checks which involve a check of identity documents, nationality and immigration status and employment (minimum past three years)/education referees. It is particularly important that gaps in employment history be questioned. A standard DBS disclosure will also need to be completed. Additionally, employees will also be required to give a reasonable account of any significant periods (six months or more in the past three years) of time spent abroad.
Counter-Terrorist check	This level of clearance is required by employees who may come into contact with information regarding national security, hold posts with long-term, frequent and uncontrolled access to Government protectively marked material, or for posts involving access to individuals, establishments, or information assessed to be at risk from or of value to terrorists. It involves a range of screening checks that build on the Base Check with additional security checks and searches police records. The candidate must complete a Security Check questionnaire. As the University does not currently hold Sponsor status it is unable to apply or process checks at this level.
Security Check	This is required for access to certain Government establishments and for jobs involving access to sensitive information which is classified as ‘Secret’. The vetting process for SC clearance includes: completion of a security clearance questionnaire by the candidate; checking identity documents and employment/education references; checks against UK criminal and security references and a credit reference check. If considered necessary, checks against the criminal and security records of relevant foreign countries should also be carried out. As the University does not currently hold Sponsor status it is unable to apply or process checks at this level.
Developed Vetting	This is the most detailed and comprehensive form of UK vetting. It is required for sensitive jobs and tasks, which involve long-term, frequent or uncontrolled access to Secret material. The vetting process for DV clearance includes: SC clearance, completion of a DV supplementary questionnaire by the candidate; completion of a financial questionnaire by the candidate; a review of the candidates personal finances; interviews with a candidate’s referees conducted by a vetting officer; a detailed interview with a candidate conducted by a vetting officer. The minimum criteria for attaining a valid DV clearance as the candidate must have been resident in the UK for the majority of the past ten years and must have residency information that is verifiable. As the University does not currently hold Sponsor status it is unable to apply or process checks at this level.

In all cases the University will need to carry out a Base Check (including Standard DBS check). Any screening at higher levels will be instigated by the appropriate sponsor.

There are additional levels of security checks that sponsors may require an employee to obtain. These include: 4 levels of NATO classifications – Cosmic Sop Secret, NATO Secret, NATO Confidential and NATO restricted. If employees are going to be working with classified information from other countries such as the USA, then they will also need to obtain the relevant clearance relating to that country. Again, the sponsor will advise on this. Once approval has been given at any of these levels, staff will be briefed on the provision of the Official Secrets Acts (OSA) 1911-1989 by their Sponsor.

Further guidance

Advice can be sought from your Sponsor contact, the Business Development Manager (Research Services) responsible for defence contracts (Michelle Spillar) or from your HR Business Partner.

IT links to ‌
Home Office
HR Services form PD52 - Security Clearance - Basic Check for new and existing employees