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Guidelines for PA Enhanced Background Certifications (PEBC)

Direct Contact and Direct Volunteer Contact with Minors

Drexel is committed to protecting the safety, security and health of its students, faculty and professional staff members, volunteers, non-employee associates and all others with whom we interact, including minors in our programs. Background checks are the first and most effective means of protecting minors from abuse by screening out potential abusers before they interact and have contact with minors.

Overview

Employees Exempted from the PEBC

Students Exempted from the PEBC

Process

Provisional Employment of 90 Days

Minors as Employees

Exchange Visitors (J-1 Visa Holders)

Volunteers

Minors as Volunteers

Student Volunteers

Fingerprinting

Results of Background Checks

Written Notice of New Arrest, Conviction or Substantiated Child Abuse

Portability of Certifications

Renewal of PEBC

Costs

Obtaining Copies of Certifications

Definitions

Frequently Asked Questions

Overview

The Pennsylvania Child Protective Services Law (CPSL) now requires institutions of higher education to obtain background checks for any individuals having direct contact or direct volunteer contact with minors. To comply the CPSL all Drexel faculty, professional staff members, including those affiliated with a collective bargaining unit, student workers, temporary staff, non-employee associates, finalist candidates and independent contractors who have direct contact with minors and adult volunteers who have direct volunteer contact with minors must undergo the PA Enhanced Background Certifications (PEBC). The PEBC include: FBI Fingerprint Check, Pennsylvania State Police Criminal Record Check and Pennsylvania Child Abuse History Clearance.

For the purposes of these guidelines, please take note of the following terms:

  • Minor (or Child) is defined as someone under the age of 18.
  • Direct Contact with a Minor is defined as the care, instruction, supervision, guidance or control of a Minor OR routine interaction with a Minor. “Routine interaction” is regular and repeated contact that is integral to a person’s employment or volunteer responsibilities.
  • Direct Volunteer Contact with a minor is defined as the care, instruction, supervision, guidance or control of a Minor AND routine interaction with a Minor. “Routine interaction” is regular and repeated contact that is integral to a person’s employment or volunteer responsibilities.

Compliance with the University’s Background Checks Policy is a condition of employment/volunteer assignment with Drexel University and a critical part of our continued efforts to provide the safest possible environment for all members of the Drexel community.

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Employees Exempted from the PEBC

The law grants an exemption from undergoing the PEBC for:
  • Drexel employees whose direct contact with minors is limited to prospective students visiting a campus operated by Drexel University OR
  • Drexel employees whose direct contact with minors is limited to matriculated students who are enrolled with Drexel (and are not dually-enrolled high school students).

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Students Exempted from the PEBC

If the program, activity or service is an internship, externship, work-study, co-op or similar program sponsored by Drexel, only the following individual is required to undergo the PEBC:

  • The individual who is 18 years or older, who holds or applies for a paid position in that program, activity or service AND
  • The individual is identified by Drexel as the person responsible for a child’s welfare (e.g. as his/her supervisor) while the child participates in the internship, externship, work-study, co-op or similar program AND
  • The individual must be in the immediate vicinity at regular intervals with the minor during the program, activity or service.

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Process

The PEBC can be completed in 15-20 days from the date of submission of the required documents if all of the instructions are followed without delay.

Step 1: Contact the Minors on Campus Coordinator in Public Safety to register your program, activity or service involving minors and for additional instructions regarding required training, best practices, etc.

Step 2: The Minors on Campus Coordinator will forward the program information to your Talent Acquisition Specialist in Human Resources.

Step 3: Your Talent Acquisition Specialist will contact the Program’s Primary Contact to initiate the PEBC.

Step 4: All individuals subject to the PEBC will be given 2 business days to submit the required documents to complete the background checks. The required documents and instructions will be provided via email to each individual.)

Step 5: All individuals subject to the PEBC will be given 7 business days to be fingerprinted.

Step 6: All employees subject to the PEBC will be required to complete the Pennsylvania Child Abuse History Clearance electronically by following the instructions provided in an email sent directly from our vendor, Sterling. All volunteers subject to the PEBC will be required to complete the Pennsylvania State Police Criminal Record Check and the Pennsylvania Child Abuse History Clearance on their own for FREE then send the results to your Talent Acquisition Specialist.

All background checks conducted by or on behalf of Drexel will comply with the Fair Credit Reporting Act and other relevant privacy laws.

A database of individuals who have completed or are in the process of completing the PEBC is maintained by your Talent Acquisition Specialist. Before initiating the PEBC your Talent Acquisition Specialist will search the database to determine if the individual is already in compliance.

The results of the PEBC must be reviewed and cleared by Human Resources prior to the employee/volunteer having contact with minors.

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Provisional Employment of 90 Days

There may be situations in which employment/contact with minors must begin before all of the results of the PEBC background checks are reviewed and cleared by Human Resources. In these situations Drexel allows for “provisional employment” of a single period not to exceed 90 days for full-time Employees only under the following conditions:

  • The individual has applied for the FBI Fingerprint Check, the Pennsylvania State Police Criminal Record Check and the Pennsylvania Child Abuse History Clearance and provides Human Resources with the completed forms within the time frames required.
  • Drexel has no knowledge of information pertaining to the individual which would disqualify the individual from employment based on the offenses stated above.
  • The individual swears or affirms in writing that s/he has not been convicted of an offense similar in nature to those stated in the section entitled “Results of Background Checks – Grounds for Denying Employment or Volunteer Assignment or Participation in Program, Activity or Service – Direct Contact with Minors” under the laws or former laws of the U.S. or one of its territories or possessions, another state, the District of Columbia, Puerto Rico or a foreign nation, or under a former law of Pennsylvania.
  • Drexel requires that the individual not be permitted to work alone with Minors and that s/he work in the immediate vicinity of an Employee whose PEBC have already been reviewed and cleared by Human Resources.
  • If the background check reveals that the individual is disqualified from employment s/he will be immediately terminated.

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Minors as Employees

An individual between 14 and 17 years of age who applies for or holds a paid position as an employee with Direct Contact with Minors through a program, activity or service is required to undergo the FBI Fingerprint Check, Pennsylvania State Police Criminal Record Check and Pennsylvania Child Abuse History Clearance. Individuals between ages 14 and 17 who hold or apply for a paid position as an employee may be exempted from the FBI Fingerprint Check requirement, if the following apply:

  • The individual has been a resident of Pennsylvania continuously during the previous 10-year period OR if not a resident of Pennsylvania during the entirety of the previous 10 year period, has obtained the FBI Fingerprint check at any time since establishing residency in Pennsylvania and provides a copy of the results to the Human Resources department.
  • The individual AND the individual's parent or legal guardian swears or affirms in writing that s/he has not been convicted of an offense similar in nature to those crimes stated in the section entitled “Results of Background Checks – Grounds for Denying Employment or Volunteer Assignment or Participation in Program, Activity or Service – Direct Contact with Minors” under the laws or former laws of the U.S. or one of its territories or possessions, another state, the District of Columbia, Puerto Rico or a foreign nation, or under a former law of Pennsylvania.

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Exchange Visitors (J-1 Visa Holders)

An individual in possession of a non-immigrant J-1 visa who has Direct Contact with Minors is not required to undergo the PEBC if ALL of the following apply:

  • The individual is applying for or holds a paid position with a program, activity or service for a period not exceeding a total of 90 days in a calendar year.
  • The individual has not been employed previously in Pennsylvania or another state, the District of Columbia, or Puerto Rico.
  • The individual swears or affirms in writing that s/he has not been convicted of an offense similar in nature to those crimes stated in the section entitled “Results of Background Checks – Grounds for Denying Employment or Volunteer Assignment or Participation in Program, Activity or Service – Direct Contact with Minors” under the laws or former laws of the U.S. or one of its territories or possessions, another state, the District of Columbia, Puerto Rico or a foreign nation, or under a former law of Pennsylvania.

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Volunteers

Volunteers subject to PEBC are required to undergo the FBI Fingerprint Check, Pennsylvania State Police Criminal Record Check and Pennsylvania Child Abuse History Clearance.  A volunteer may be exempted from the FBI Fingerprint Check requirement, only, under the following conditions:

  • The position is unpaid.
  • The Volunteer has been a resident of Pennsylvania continuously during the previous 10-year period OR if not a resident of Pennsylvania during the entirety of the previous 10 year period, has obtained the FBI Fingerprint check at any time since establishing residency in Pennsylvania and provides a copy of the results to the Human Resources department.
  • The Volunteer swears or affirms in writing that s/he has not been convicted of an offense similar in nature to those crimes stated in the section entitled “Results of Background Checks – Grounds for Denying Employment or Volunteer Assignment or Participation in Program, Activity or Service – Direct Contact with Minors” under the laws or former laws of the U.S. or one of its territories or possessions, another state, the District of Columbia, Puerto Rico or a foreign nation, or under a former law of Pennsylvania.

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Minors as Volunteers

Minor volunteers between 14 and 17 years of age are exempt from the PEBC.

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Student Volunteers

Drexel students who volunteer for the University are not required to obtain the PEBC if ALL of the following apply:

  • The individual is currently enrolled in a school.
  • The individual is not a person responsible for the child's welfare.
  • The individual is volunteering for an event that occurs on school grounds.
  • The event is sponsored by the school in which the individual is enrolled as a student.
  • The event is not for children who are in the care of a child-care service.

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Fingerprinting

All appointments with our fingerprinting vendor, First Contact HR, must be scheduled through your Talent Acquisition Specialist and take place at either of the First Contact HR offices. Drexel is given priority for scheduling appointments. Appointments are in 15-minute increments (e.g. 9:00, 9:15, 9:30, etc.) and fingerprinting takes around 3-4 minutes to complete.

First Contact HR Offices:

  • First Contact HR, The Jefferson Building, 1015 Chestnut Street, Suite 307, Philadelphia, PA 19107 (Monday thru Friday 9:00 a.m. to 3:45 p.m.)
  • First Contact HR, 535 West Pennsylvania Avenue, Suite 101, Fort Washington, PA 19034 (Monday thru Friday 9:00 a.m. to 4:30 p.m.) – LIMITED AVAILABILITY

Other Cogent Fingerprint Locations:

For convenience, individuals may also visit a Cogent Fingerprint Location in Pennsylvania to be fingerprinted.  However, Drexel does NOT manage these fingerprinting appointments and has no control over appointments or service delivery (including wait time) at these locations.  If the individual chooses to visit one of these locations, they must first obtain their Registration ID from their Talent Acquisition Specialist.

Drexel Campus Fingerprinting:

When groups of 25 or more are required to undergo the PEBC your Talent Acquisition Specialist can work with the department to schedule a date for fingerprinting on one of Drexel’s campuses.

Required Identification for Fingerprinting Appointment:

Individuals will be required to show identification before fingerprinting is conducted. Identification documents must be current, valid, unexpired and contain a photo. FBI fingerprinting will not be conducted if an acceptable photo ID is not produced.

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Results of Background Checks - Grounds for Denying Employment or Volunteer Assignment or Participation in Program, Activity or Service - Direct Contact with Minors

Drexel will not approve an individual for employment, or, as applicable, any Volunteer assignment or Program, Activity or Service provided to Drexel by an Independent Contractor, where the Pennsylvania Department of Human Services has verified that the individual is named in the Statewide Child Abuse database as the perpetrator of a Founded Report committed within the five-year period immediately preceding verification (the background check).

Drexel will not approve an individual for employment, or, as applicable, any Volunteer assignment or Program, Activity or Service provided to Drexel by an Independent Contractor, if the criminal history record information indicates the individual has been convicted of a felony offense under the Act of April 14, 1972 (P.L.233, No.64), known as “The Controlled Substance, Drug, Device and Cosmetic Act”, committed within the five-year period immediately preceding verification (the background check).

Drexel will not approve an individual for employment, or, as applicable, any Volunteer assignment or Program, Activity or Service provided to Drexel by an Independent Contractor, if the criminal history record information indicates the individual has been convicted of one or more of the following offenses under Title 18, Pennsylvania Statutes (relating to crimes and offenses) or an equivalent crime under Federal law or the law of another state:

  • Chapter 25 (relating to criminal homicide)
  • Section 2702 (relating to aggravated assault)
  • Section 2709.1 (relating to stalking)
  • Section 2901 (relating to kidnapping)
  • Section 2902 (relating to unlawful restraint)
  • Section 3121 (relating to rape)
  • Section 3122.1 (relating to statutory sexual assault)
  • Section 3123 (relating to involuntary deviate sexual intercourse)
  • Section 3124.1 (relating to sexual assault)
  • Section 3125 (relating to aggravated indecent assault)
  • Section 3126 (relating to indecent assault)
  • Section 3127 (relating to indecent exposure)
  • Section 4302 (relating to incest)
  • Section 4303 (relating to concealing death of child)
  • Section 4304 (relating to endangering welfare of children)
  • Section 4305 (relating to dealing in infant children)
  • A felony offense under section 5902(b) (relating to prostitution and related offenses)
  • Section 5903(c) or (d) (relating to obscene and other sexual materials and performances)
  • Section 6301 (relating to corruption of minors)
  • Section 6312 (relating to sexual abuse of children)
  • The attempt, solicitation or conspiracy to commit any of these offenses

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Written Notice of New Arrest, Conviction or Substantiated Child Abuse

If an Employee or Volunteer or Independent Contractor of Drexel subject to PEBC is arrested for or convicted of an offense outlined in “Results of Background Checks – Grounds for Denying Employment or Volunteer Assignment or Participation in Program, Activity or Service – Direct Contact with Minors that would constitute grounds for denying employment or a Volunteer assignment or participation in a Program, Activity or Service, or is named as a perpetrator in a Founded or Indicated Child Abuse report, the Employee or Volunteer shall provide the Vice President of Public Safety (or designee) with written notice of the changes in his/her certification status not later than 72 hours after the arrest, conviction or receipt of notification that the person has been listed as a perpetrator in the Statewide database.

If Drexel has a reasonable belief that an Employee or Volunteer or Independent Contractor was arrested or convicted for an offense that would constitute grounds for denying employment, or a volunteer assignment or participation in a Program, Activity or Service under Title 18 of the Pennsylvania statutes as listed above or was named as a perpetrator in a Founded or Indicated Child Abuse report, or the Employee or Volunteer or Independent Contractor has provided notice of the changes in his/her certification status as required, Drexel will immediately require the Employee or Volunteer or Independent Contractor to submit current information (results of new background checks with the PEBC).

Any Employee or Volunteer or Independent Contractor who willfully fails to disclose the changes in his/her certification status shall be subject to discipline up to and including denial of employment or volunteer position or termination of any services provided and, in addition, may be charged with a misdemeanor of the third degree as prescribed by the CPSL as amended from time to time.

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Portability of Certifications (Completed PEBC)

Volunteers: Any individual who has obtained the required PEBC volunteer certifications may serve in a volunteer capacity for any program, service or activity at Drexel University during the length of time the certification is valid (60 months from the date of certification). Unexpired PEBC volunteer certifications obtained through other organizations are transferable and, upon approval by Human Resources, will be accepted by Drexel University and will be valid for the duration of the remaining certification period.

Employees: Any employee who has obtained the required PEBC employee certifications may serve in an employment or volunteer assignment for any program, service or activity at Drexel University during the length of time the certification is valid (60 months from the date of certification). Unexpired PEBC employee certifications obtained through other organizations are transferable and, upon approval by Human Resources, will be accepted by Drexel University and will be valid for the duration of the remaining certification period.

  • If an employee presents PEBC employee certifications from a previous organization, they must also swear or affirm in writing that s/he has not been convicted of an offense similar in nature to those crimes stated in the section entitled “Results of Background Checks – Grounds for Denying Employment or Volunteer Assignment or Participation in Program, Activity or Service – Direct Contact with Minors” under the laws or former laws of the U.S. or one of its territories or possessions, another state, the District of Columbia, Puerto Rico or a foreign nation, or under a former law of Pennsylvania.

Exclusions: By law, certifications issued for volunteer work cannot be used for employment. However, certifications issued for employment can be used for volunteer work.

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Renewal of PEBC

Once completed, PEBC will be valid for 60 months (5 years) for any person maintaining direct contact or direct volunteer contact with minors.

  • Every 60 months: FBI Fingerprint Check
  • Every 60 months: Pennsylvania State Police Criminal Record Check
  • Every 60 months: Pennsylvania Child Abuse History Clearance

All background checks conducted by or on behalf of Drexel will comply with the Fair Credit Reporting Act and other relevant privacy laws.

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Costs

All costs for the PEBC will be charged back to the hiring/volunteer assignment department. Please contact your Talent Acquisition Specialist for the current costs to conduct the PEBC.

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Obtaining Copies of Certifications (Completed PEBC)

Individuals may request copies of their completed PEBC by emailing their Talent Acquisition Specialist. Please allow 2 business days to process the request.

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Definitions

Adjunct Faculty Member is defined as an individual employed by Drexel University to provide instruction on a part-time or non-continuing basis.

Applicant is defined as an individual seeking a job at Drexel University, including an existing Faculty or Professional Staff Member who is seeking to transfer positions within the University.

Direct Contact with a Minor is defined as the care, instruction, supervision, guidance or control of a Minor OR routine interaction with a Minor. “Routine interaction” is regular and repeated contact that is integral to a person’s employment or volunteer responsibilities.

Direct Volunteer Contact with minors is defined as the care, instruction, supervision, guidance or control of a Minor AND routine interaction with a Minor. “Routine interaction” is regular and repeated contact that is integral to a person's employment or volunteer responsibilities.

Employee is defined as an individual employed by Drexel University, including a Faculty Member, Professional Staff Member, Student Worker and Temporary Staff.

Faculty Member is defined as an individual employed by Drexel University in a tenured, tenure-track or non-tenured track position who teaches at any college, school, center or institute in the University. A Faculty Member also is deemed to be exempt under the provisions of the Fair Labor Standards Act (FLSA) and/or applicable state law.

Finalist Candidate is defined as an Applicant seeking a job at the University who has received a conditional offer of employment.

Immediate Vicinity is defined as an area in which an individual is physically present with a child (Minor) and can see, hear, direct and assess the activities of the child.

Independent Contractor is defined as an individual who is not an Employee of the University who provides a Program, Activity or Service to the University and who has or will have Direct Contact with a Minor.

Matriculated Student is defined as a student who is enrolled in an institution of higher education and pursuing a program of study that results in a post-secondary credential, such as a certificate, diploma or degree.

Minor (or Child) is defined as someone under the age of 18. Minor and Child will be used interchangeably in these guidelines.

Non-Employee Associate is defined as an individual who is not a Faculty, Professional Staff Member or Student Worker of Drexel University (or otherwise employed by the University) and will not become an Employee of the University in the foreseeable future, and who requires access to the University's resources in connection with services or work that the individual is doing at the University. A Non-Employee Associate may be an employee of an Independent Contractor as defined in this policy.

Person Responsible for the Child's Welfare is defined as a person who provides permanent or temporary care, supervision, mental health diagnosis or treatment, training or control of a child in lieu of parental care, supervision and control.

Professional Staff Member is defined as an individual employed in any non-faculty category by Drexel University, including an individual who is deemed to be either exempt or non-exempt under the provisions of the Fair Labor Standards Act (FLSA) and/or applicable state law.

Program, Activity or Service is defined as any of the following in which children (Minors) participate and which is sponsored by a school or public or private organization: (1) a youth camp or program; (2) a recreational camp or program; (3) a sports or athletic program; (4) a community or social outreach program; (5) an enrichment or educational program; and (6) a troop (e.g., Girl Scout or Boy Scout), club or similar organization.

Routine Interaction is regular and repeated contact that is integral to a person’s employment or volunteer responsibilities.

Student Worker is defined as a matriculated or non-matriculated individual at Drexel University working in any of the following employment categories: co-op, work-study, graduate assistant, graduate research fellow, teaching assistant and resident assistant.

Temporary Staff is defined as full or part-time co-op, casual and per diem Employees working no more than 1000 hours over a 12-month period.

Volunteer is defined as an unpaid individual representing or providing services to Drexel for community service, civic, charitable or humanitarian reasons, without promise, expectation or receipt of compensation for services rendered. Volunteers subject to this policy also include unpaid individuals who are responsible for the welfare of a Minor or who have Direct Volunteer Contact with a Minor as defined in this policy.

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Frequently Asked Questions

Last Updated October 14, 2015