Background Checks for Janitorial Staff: What to Require

Reasonable screening expectations for the people who hold your keys after hours.

When you hire a cleaning company, require that every person who will access your building is background-checked before their first visit, that screening is done lawfully under the Fair Credit Reporting Act and EEOC guidance, that the vendor tells you who is assigned and notifies you of changes, and that sensitive sites can add their own requirements. Remember that the vendor, as employer, runs and decides on screening; your role is to set expectations in the contract and verify the process exists.

Why it matters

Janitorial staff often have unsupervised access at night to offices, clinics, banks, schools and homes of businesses' most sensitive information. A background check cannot predict behavior, but it can screen out known, relevant risks before someone receives a key. Combined with access control and supervision, it is a basic layer of protection.

Who should be checked

Everyone with access. That includes cleaners, leads, supervisors, substitutes and anyone covering a shift. Vendors sometimes screen permanent staff but not fill-ins, and fill-ins are exactly who appears when you are least expecting it.

Ask your vendor directly: "Is every person who will enter our building background-checked before their first visit, including substitutes?"

How screening must be done

The vendor is the employer and must follow the law:

  • Fair Credit Reporting Act. When an employer uses a consumer reporting agency for background reports, the FTC explains that the employer must give clear written notice, get written permission, and follow pre-adverse and adverse action steps before acting on a report. The CFPB administers the regulations implementing the FCRA.
  • EEOC guidance. The EEOC expects employers to apply background check policies consistently and avoid discrimination, and it has issued guidance on considering criminal history in a way that is job-related.
  • State and local rules. Some jurisdictions add requirements. Minnesota, for example, has its own rules for when employers may ask about criminal history during hiring.

You do not need to audit the vendor's legal compliance in detail, but you should expect a vendor to describe its process confidently.

What a typical check covers

Commercial cleaning vendors commonly use checks that include:

  • Identity verification
  • Criminal history searches at the county, state and/or national level
  • Sex offender registry checks
  • Employment eligibility verification (separate from background checks, but part of hiring)

Some sites require more.

Sites that may need additional screening

Site typePossible extra requirement
Childcare centersFingerprint-based checks or checks required by licensing rules
Banks and credit unionsInstitution's own vendor screening or fingerprinting
SchoolsDistrict or school policies for adults in the building
Healthcare facilitiesExclusion list checks or facility badging
Government buildingsAgency-specific clearance or badging

Write these into your contract so they are completed before anyone is assigned.

What to put in the contract

  • All personnel with access must be background-checked before first access
  • Screening must comply with applicable law
  • Vendor provides a description of its screening process on request
  • Vendor provides names of assigned personnel and notifies you before changes
  • Client may request removal of any person from its account
  • Additional site-specific requirements, if any

See janitorial contract terms.

What background checks cannot do

  • They only show what is on record
  • They cannot predict future conduct
  • They age; a check done years ago says little about today

That is why screening should sit alongside assigned staff, logged credentials and supervision. See vendor key and access control and bonded vs insured, which covers the bond that responds when prevention fails.

Questions to ask

  1. Is every person with access screened before first visit, including substitutes?
  2. What does the check include?
  3. Who performs it?
  4. Can you complete our additional requirements?
  5. How will we know who is assigned to our building?

More vetting questions are in questions to ask a janitorial company.

Northmark's approach

Every Northmark team member is background-checked before receiving access to any client building, and clients with additional requirements can specify them. See background-checked staff. People interested in working with us can see careers.

Frequently asked questions

Should cleaning company employees be background-checked?

Yes. Every person with access to your building, including substitutes, should be screened before their first visit.

Can I run background checks on my vendor's employees myself?

Generally the vendor, as employer, runs screening under the FCRA. You set requirements in the contract and can ask for a description of the process.

What if my site needs fingerprinting?

Write it into the contract. The vendor should complete it before assigning anyone.

Do background checks replace bonding?

No. Checks are preventive. Bonds respond to losses from dishonest acts.

Sources

Published · Northmark Facility Services.

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