Knowledge Base: NLLS Policies

POLICE INFORMATION CHECK

Section: NLLS Employee(s) | Chapter: Conditions of Employment | Page(s): 3

Subject: POLICE INFORMATION CHECK (PIC) | Sec 1, 1V

Reviewed 2025-08-02 | Revised: 2025-09-26 | Effective: 2021/02/26

1. Purpose

This policy outlines Northern Lights Library System’s (NLLS) approach to requesting and managing Police Information Checks (PICs) for prospective or current employees. It ensures legal compliance, fair and respectful treatment of individuals, and protection of organizational integrity.

2. Scope

This policy applies to all NLLS employees and prospective employees, including full-time, part-time, temporary, contract, and remote staff, where the position warrants a PIC.

3. Legal Context

Under Alberta and Canadian law, there is no general requirement for public sector employers to mandate PICs unless the role involves specific duties such as working with vulnerable persons, as defined under the Criminal Records Act or other applicable legislation (e.g., Protection for Persons in Care Act).

At present, NLLS does not have roles legally designated as requiring mandatory Police Information or Vulnerable Sector Checks. However, NLLS reserves the right to request a PIC when the nature of the position may:

• Involve access to sensitive personal or confidential information
• Include financial responsibilities or authority
• Require unsupervised access to NLLS facilities or vehicles
• Represent the organization in high-trust contexts
• For managers or supervisors that regularly have minor workers (students) reporting to them.

4. When a Police Information Check May Be Requested

A PIC may be requested:

• At time of hire, as a condition of employment
• Upon change of role within the organization, if new duties justify it
• As needed, when required by law or emerging operational concerns

Vulnerable Sector Checks will only be requested if the position qualifies under applicable federal or provincial legislation.

5. Evaluation of Results

• NLLS will assess PIC results on a case-by-case basis.
• A record will not automatically disqualify a candidate. The relevance, nature, and timing of any information will be considered in the context of the role.
• The Executive Director (or designate) will make the final decision in consultation with legal counsel and relevant legislation.

6. Privacy and Confidentiality

• All PICs are considered confidential and will be stored securely in accordance with the Privacy and Information Protection Policy (Sec 2-1L) and the Protection of Privacy Act (POPA).
• Results will be accessible only to staff for decision-making purposes.

7. Applicant Rights

• Individuals have the right to clarify or appeal information contained in a PIC.
• NLLS will pause final employment decisions if an individual is actively seeking clarification of a record, provided this process is initiated promptly.

8. Cost and Submission

• Applicants will be informed in advance if a PIC is required as a condition of employment.
• When a PIC is required, it will be specified in the employment agreement.
• Unless otherwise approved by the Executive Director, the cost of obtaining a PIC is the responsibility of the applicant.
• PICs must be dated within 90 days of submission and be the original document or a notarized copy.