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HR August Policy Review | Criminal Background Checks & Form I-9

Posted 2:47 p.m. Friday, Aug. 1, 2025

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Criminal Background Checks & Form I-9 Policy Review

HR will be providing a periodic review of important employment policies and procedures. The following information is a brief synopsis of UWL HR Policy-Background Checks and Positions of Trust or Access to Vulnerable Populations and UW System Administration Policy 1259: I-9 Verification. These policies provide the framework for documentation, and guidelines, all employees are held to when working at UWL. This review will cover the pertinent information as we welcome new staff and employees to campus for the ’25-’26 Academic Year. It is recommended to review the policies in full found here: Criminal background checks & I-9 Verification. 

HR policy - Background checks and positions of trust or access to vulnerable populations 

Criminal background checks shall be conducted on candidates recommended for hire, either prior to the extension of an offer of employment, or as part of an offer of employment that is made contingent upon a successful criminal background check. HR will request a new background check if an employee has a gap in employment from UWL that exceeds 12 months.  

Position of Trust 

A criminal background check shall also be conducted on current employees and volunteers holding a "position of trust with access to vulnerable populations" as defined in paragraph 1. of this policy who have not been previously subject to such a criminal background check by the University within the last four (4) years. "Position of trust" is defined as a paid or volunteer position with one or more of the following responsibilities:  

  1. Access to vulnerable populations -Responsibilities require unsupervised or significant access to vulnerable populations, defined as minors and medical patients. For purposes of this policy, a minor is a person under the age of eighteen (18) who is not enrolled or accepted for enrollment at a UW System institution. 
  2. Property access-Responsibilities require the use of master keys/card access and pertains to employees with key access to offices, facilities, or worksites other than their own worksite, including UW-La Crosse residential housing facilities. 
  3. Financial/fiduciary duty - Principal responsibilities (50% or more) require handling, receiving, or having custody of money, checks or securities, or accounting for supplies or other property; authorizing (or making appropriations for) expenditures; approving, certifying, signing or countersigning checks, drafts, warrants, vouchers, orders or other documents providing for the paying over or delivery of money, securities, supplies or other property, or service of process; maintaining or auditing accounts of money, checks, securities, time records, supplies, or other property, or taking physical inventories of money, checks, securities, supplies, or other property.  
  4. Executive positions - Responsibilities involve top-level management functions throughout the institution including roles as Chancellor, Provost, and Dean. Executive positions are defined as all limited appointments and include any movement from a limited appointment to a different limited appointment. 

Conducting Criminal Background Checks 

Selected candidate for hire must complete and sign a criminal background check authorization form. An applicant or volunteer’s failure to consent to a criminal background check or falsification of any related information is grounds for the withdrawal of the employment offer or volunteer opportunity. A criminal background check on prospective hires, employees and volunteers will include a check of the Wisconsin Department of Justice, Crime Information Bureau electronic database, and a check provided by a criminal background check vendor that includes the following components: 

  • Social Security Number Trace, criminal felony/misdemeanor by county of residence, and sex offender registry. 

Self-Disclosure of Arrests, Charges, or Convictions 

Those who are employed with UWL in a Position of Trust or Position of Trust to Vulnerable Populations must report arrests, charges, or convictions while employed with UWL. Failure to self-disclose these offenses within 24 hours may result in disciplinary action, up to and including dismissal. The same procedures must be implemented for volunteers who hold a position of trust with access to vulnerable populations.  

UW System: I-9 Verification 

The U.S. Department of Homeland Security through U.S. Citizenship and Immigration Services (USCIS) requires state employers to document verification of the identity and employment authorization of each new employee (both citizen and non-citizen) to work in the United States. 

Human Resources acknowledges that due to the Workday implementation, the Form I-9 process will be different from previous years. Employees must complete Section 1 of the I-9 in Workday prior to asking HR to complete Step 2. HR staff are not able to complete your I-9 until you have completed Section 1 in Workday. 

Acceptable Documents: 

This is not a comprehensive list, but instead the most used documents the HR office receives. For the full list, please view the documentation found on page 2. 

*Note: Only one document is needed from List A, OR one document from List B AND List C* 

List A:  

  • U.S Passport or U.S. Passport Card. 

OR 

List B:  

  • Driver’s License  
  • School ID card with photograph 

AND 

List C: 

  • Social Security Card 
  • Original or certified birth certificate 

Additionally, every employee has a responsibility for completing section 1 no later than the first day of employment and must show their documentation to a UWL representative within three business days of the date employment begins to successfully complete section 2. Failure to do so may result in the withdrawal of employment. 

Employee Resources: 

Links to related information:  


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