This policy is applicable to CORI screening of prospective and current students, employees, volunteers and interns at Greenfield Community College.

Where Criminal Offender Record Information (CORI) is part of a general background check for employment, volunteer service or participation in academic, community, or clinical program, the following practices and procedures will generally be followed:

I. Conducting CORI Screening

CORI checks will only be conducted as authorized by the Massachusetts Department of Criminal Justice Information Services (DCJIS) and MGL c. 6, §. 172, and only after a CORI Acknowledgement Form has been completed.

If a new CORI check is to be made on a subject, a new CORI Acknowledgement Form must be completed prior to running the check.

II. Access to CORI

All CORI records obtained from the DCJIS are confidential and access is strictly limited to employees who have been authorized by the College and certified by DCJIS to request, review, or handle CORI.

Authorized staff may share CORI records only with other College employees who have a demonstrated “need to know” in order to carry out their job responsibilities connected to the decision. This may include, but is not limited to, staff submitting CORI requests, staff processing job applications, and certain other GCC representatives who have received CORI training and may be involved in reviewing suitability based on the results of CORI checks. Greenfield Community College must maintain and keep a current list of each individual authorized to have access to, or view, CORI. This list is updated every six (6) months and is subject to inspection upon request by the DCJIS at any time.

III. CORI Training

An informed review of a criminal record requires training. Accordingly, all personnel authorized to review or access CORI at GCC will review, and be familiar with, the educational and relevant training materials regarding CORI laws and regulations made available by the DCJIS. These individuals will also review and be familiar with GCC’s CORI Policy.

IV. Use of CORI in Background Screening

Criminal background records used for employment purposes, or for participation in academic, community or clinical program, shall only be accessed for applicants who are otherwise qualified for the position, program or opportunity for which they have applied.

Unless otherwise provided by law, a criminal record will not automatically disqualify an applicant from employment or participation in academic, community or clinical program at GCC. Rather, determinations of suitability based on criminal background checks will be made consistent with this policy, the student handbook, and any applicable law or regulations.

V. Verifying a Subject’s Identity

If a criminal record is received from DCJIS, the authorized individual will closely compare the record provided by DCJIS with the information on the CORI Acknowledgement Form and any other identifying information provided by the applicant, to ensure the record relates to the applicant.

If the information in the CORI record provided does not exactly match the identification information provided by the applicant, a determination of whether the record should be included in the applicant’s criminal history screening will be made by a CORI-authorized individual based on a comparison of the CORI record and documents provided by the individual.

VI. Inquiring About Criminal History

Prior to questioning an individual about their criminal history in connection with an employment or volunteer opportunity, or for academic, community, or clinical participation, GCC will provide the subject with a copy of the criminal history record, whether obtained from the DCJIS or from any other source. The source(s) of the criminal history record will also be disclosed to the subject.

VII. Determining Suitability

If GCC determines, based on the information as provided in section V of this Policy, that the CORI belongs to the subject, and the subject does not dispute the record’s accuracy, then, following the either the CORI Review Procedures for Employment or the CORI Review Procedures for Students, the determination of suitability for the position will be made. Unless otherwise provided by law, factors considered in determining suitability may include, but not be limited to, the following:

1. Relevance of the record to the position sought;
2. The nature of the work to be performed;
3. Time since the conviction;
4. Age of the applicant at the time of the offense;
5. Seriousness and specific circumstances of the offense;
6. The number of offenses;
7. Whether the applicant has pending charges;
8. Any relevant evidence of rehabilitation or lack thereof;
9. Any other relevant information, including information submitted by the applicant or requested by GCC.

GCC will notify the applicant of the decision and the basis for it in a timely manner.

VIII. Adverse Decisions Based on CORI

If an authorized official is inclined to make an adverse decision based on the results of a criminal history background check, the applicant will be notified in accordance with the DCJIS regulation 803 CMR 2.18 and other applicable federal laws.

The applicant shall be provided with a copy of GCC’s CORI Policy and a copy of the criminal history. The record(s) that is/are the basis for the potential adverse action will also be identified. The source(s) of the criminal history will also be revealed. The subject will then be provided with an opportunity to dispute the accuracy of the CORI record. Such applicants shall also be provided a copy of DCJIS’ Information Concerning the Process for Correcting a Criminal Record.

IX. Secondary Dissemination Log

All CORI obtained from DCJIS is confidential and can only be disseminated as authorized by law and regulation. GCC will maintain a central secondary dissemination log to record any dissemination of CORI outside of GCC, including dissemination at the request of the applicant.