All 8 entities need to improve their practices in some way, with none of the entities displaying good policies or practices for verifying employee identity and credentials.
Robust employee screening processes and procedures help entities to recruit appropriate staff and ensure that current staff remain suitable for their roles.
Policies and procedures for verifying employee identity and credentials should require checking of claims made by potential employees including their identity, relevant professional qualifications, memberships or licenses, prior work history, right to work in Australia and, where appropriate, criminal background. If there are any specific requirements for a position, such as qualifications or a working with children check, entities should clearly document these requirements in position description forms and these checks should also be part of the recruitment and monitoring processes.
Only Melville, Subiaco and Dundas had policies for verifying employee identity and credentials. Although the policies for these entities covered most requirements, there is scope for them to be improved by mandating a 100-point identity check and requiring periodic checking of staff for changes in their circumstances which may impact their employment.
It is important that recruitment policies and related documentation provide clear guidance to staff on instances where criminal background or working with children checks are required for the position. As noted in our 2015 report, criminal background checks are important for many positions, but not necessarily every position. Each entity needs to consider the need for criminal background or working with children checks based on the duties and risks of the position and the requirements of legislation.
While the majority of entities did not have specific policies and procedures for verifying employee identity and credentials, several had included the requirement for criminal background checks in position description forms. However, at Boyup Brook, Coolgardie and Williams, there was no requirement to perform criminal background checks for important positions. For certain positions, such as senior officers who approve key transactions and positions involving procurement, finance, human resource management and information system management, there should be some level of criminal background checks for potential employees.
Circumstances of individual employees can change over time, and it is therefore important that policies and procedures include requirements to monitor existing employees. This can include, where appropriate, periodic criminal background checks and requesting evidence that staff have maintained their essential qualifications. It is also good practice to require annual declarations from employees advising of any changes in their circumstances.
For the 3 entities with policies for verifying employee identity, only Melville’s policy required periodic criminal background checks for positions requiring a criminal background check. In addition, none of the policies required employees to make annual declarations about changes to their status.
It is essential to confirm the identity of all new employees. Australian Standard 4811-2006 ‘Employment Screening’ regards this as an essential step in a recruitment process. This should be done prior to their commencement, preferably using a 100-point identity check. It is also important to verify that the potential employee has a right to work in Australia prior to engaging them in paid work.
From our sample of 306 employees, we found 81 instances (26%) where there was no evidence that the entity checked the identity of the staff prior to employment. For a further 198 employees, across all 8 entities, the verification was inadequate because it fell short of the documentation needed for a 100-point check.
Of particular concern was the high percentage (89%) where there was no evidence of checking an applicant’s eligibility to work in Australia. This shortcoming applied to every entity in our sample.
We found that most entities had identified the essential qualifications for positions, such as university degrees, first aid certificates or licenses, and clearly articulated these requirements in position description forms. For the regional entities in our sample, our testing confirmed that the entities were verifying that applicants held these essential qualifications prior to their employment. However, at Melville, Victoria Park and Subiaco, we found 54 instances (45%) where there was no evidence of this checking.
Reference or referee reports are an important tool to verify claims made by potential employees about their employment history and experience, and to clarify any uncertainties. In some instances, the checks may reveal information about a potential employee that was not readily apparent from other checks and documentation. They provide useful information about the integrity of applicants and should be a mandatory step in all recruitment procedures.
Entities can perform reference checks in a number of ways, including phone calls, emails or pro-forma forms. While a minimum two reference checks from appropriate referees is advisable, this may not be necessary for all positions. For more senior positions and roles that have significant financial responsibility, two reference checks are highly recommended.
We sampled 153 employees recruited by the entities in the period between 1 July 2015 and 20 September 2018. For more than half our sample (79 employees across all entities), we found there was no evidence that a reference check was performed as part of the recruitment process.
Most of the entities we reviewed had assessed whether a criminal background check was required for the position. However, entities were not consistently performing criminal background checks in line with their policies or position description forms. In total, we found 63 instances at 5 entities where a criminal background check was required, but there was no evidence that it was performed.
Criminal background checks, before commencement of employment and periodically thereafter, are an important way of identifying employees whose background may represent a risk to the entity, other employees or customers.
Because of the diverse nature of activities and functions performed by entities, there are a number of positions which involve working with vulnerable people in the community, such as children. The Working with Children (Criminal Record Checking) Act 2004 and Working with Children (Criminal Record Checking) Regulations 2005 require people engaged in ‘child-related work’ to have a working with children check card. While the requirements of the act may not apply to every position involving work with children, we believe it is good practice to perform these checks for these positions.
Melville, Claremont, Boyup Brook, Dundas and Williams had assessed the need for working with children checks and, based on our sample testing, were obtaining these checks as required. Subiaco, Coolgardie and Victoria Park had a small number of instances where management considered a working with children check was required, but there was no evidence that it was obtained.
If a position requires an employee to hold a licence, working with children check card, or a professional qualification, entities should regularly monitor whether employees continue to hold the required qualification/clearance. Similarly, if the position requires the employee to have a criminal background check, there should be periodic checks to ensure that there has not been a change in circumstances which could cause a risk to the entity, other employees and customers.
Only Boyup Brook and Melville had procedures in place to regularly monitor employees for all significant changes in their status. Consequently, there is a risk that the other entities may be unaware if there is a change in circumstance, such as a loss of licence, which would affect the employee’s capacity to perform their duties.
 Working with Children (Criminal Record Checking) Act 2004
 City of Melville, City of Subiaco, Shire of Dundas, Town of Claremont, Town of Victoria Park
 City of Melville, City of Subiaco, Shire of Dundas, Town of Claremont and Town of Victoria Park