We rated none of the 10 agencies as good across all our criteria, with all agencies having opportunities for improvement.
The following table is a summary of our findings. We rated the agencies on a three-point scale of ‘Poor’, ‘Fair’ or ‘Good’.
All agencies need to improve their policies and procedures for verifying employee identity and credentials
Sound policies and procedures for verifying employee identity and credentials help agencies to recruit appropriate staff and to ensure that current staff remain suitable for their roles.
Agencies should verify all important claims made by potential employees and regularly check whether job requirements of existing staff are still met. For instance, membership of professional associations can be lost if members fail to undertake required levels of continuing professional development.
As a minimum, agency policies and procedures should require checking of:
- the employee’s identity, using a 100 point identification check
- referee reports to verify claims made by an applicant and their employment history
- the employee’s right to work in Australia
- any mandatory professional qualifications or professional memberships
- criminal backgrounds, based on the risks associated with the position.
Criminal background checks are important for many positions but not every position. Agencies should determine which positions require criminal screening, based on the risks associated with the position. There should also be regular follow-up to ensure that there has not been a change in an employee’s criminal background which may render them unsuitable for the position.
All 10 agencies could improve their policies and procedures for verifying employee identity and credentials. Shortcomings we identified included:
- Only six of the 10 agencies had policies for verifying employee identity and credentials. Of these, only five required criminal background checks for new employees. These were CCYP, LAC, Animal Resources Authority, Great Southern Institute of Technology and the Mental Health Commission.
- None of the five agencies requiring criminal background checks of all new employees could show that this decision was based on assessed risks.
- The policies and procedures of only three agencies required periodic criminal background checks. CCYP required periodic checks of all staff while Great Southern Institute of Technology required periodic checks of those staff needing a working with children check and the LAC required checks of those staff needing a legal practising certificate.
- Only five agencies required employees to advise of any significant change in their circumstances, such as a criminal conviction or a loss of professional membership.
- Policies and procedures at two agencies were inconsistent with state records requirements as they allowed personal information (identification checks and outcomes from criminal record checks) to be destroyed well before the statutory record keeping period was reached.
Agencies are not verifying staff identity and confirming their eligibility to work in Australia
Confirming a potential employee’s identity is regarded by Australian Standard 4811-2006 ‘Employment Screening’ as an essential step in the recruitment process. Using a 100 point identity check is considered a practical method. Agencies should also verify that potential employees have a right to work in Australia before employing them – a requirement of the Public Sector Commission’s Instruction ‘Filling a Public Sector Vacancy’.
Only the CCYP and Regional Development had verified the identity of all staff. Six other agencies had verified the identity of staff who commenced during 2014-15 but not the identity of all staff who were employed in prior years.
In total, we found 89 instances (16 per cent) where the identity and right to work in Australia was not checked for new employees, and a further 55 instances where there was inadequate evidence supporting the employee’s right to work in Australia.
We generally found that agencies were checking that staff held required professional qualifications or memberships to professional organisations. Of the 194 employees we sampled who were required to hold a professional qualification and/or professional membership, evidence for 11 was unavailable to show they met the requirement.
Agencies were generally obtaining referee reports/reference checks to verify claims made by potential employees in their applications. Referee reports for new employees were not obtained in 25 instances (12 per cent) at three agencies from our sample of 200 new employees.
Improvements are needed to checking of criminal records
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 agency, other employees or customers. As previously mentioned, a criminal background check may not be necessary for every job but where it is, it should be done before commencement and periodically thereafter. The policies of five agencies require checks of all new employees of which one agency required subsequent checks of all employees and two required checks of some employees.
Overall, we found that criminal background checks were performed for 263 of the 553 employees in our sample. Two agencies, CCYP and Great Southern Institute of Technology had checked all new employees. By contrast, Regional Development and Tourism did not perform any criminal screening.
The three agencies that required staff to hold working with children checks or legal practising certificates, CCYP, Great Southern Institute of Technology and LAC were regularly monitoring those staff. In all other instances, there was no monitoring of staff for changes in their circumstances. Consequently, these agencies would be unaware if their staff were, subsequent to employment, convicted of an offence which may represent a risk.