HomeMy WebLinkAboutMINUTES - 09092014 - C.151RECOMMENDATION(S):
ACCEPT report on the implementation of "Ban the Box" in Contra Costa County including the use of revised
application submission process as this approach is consistent with neighboring counties, preparation of a Conviction
Information for Applicants FAQ (frequently asked questions) document that will be made available to employees and
the public on the County’s website and potential requirement for all finalists for County positions be fingerprinted
with the information being used solely to verify conviction information provided by the candidates.
FISCAL IMPACT:
No fiscal impact. This report is informational only.
BACKGROUND:
On June 17, 2014, the Board of Supervisors made a joint referral to the Public Protection Committee and the Internal
Operations Committee to review the County's implementation of Assembly Bill 218 (California Labor Code Sec.
432.9), colloquially referred to as "Ban the Box". The Ban the Box bill was signed by Governor Brown on October
10, 2013 and became operative July 1, 2014. The law prohibits state and local agencies from inquiring about criminal
convictions during the employment application process until the agency has determined that the applicant meets the
minimum employment qualifications as stated in any notice issued for the position. Ban the Box is intended to
encourage the hiring of qualified ex-offenders by ensuring that employers screen applicants based on their work
qualifications, without consideration of their prior criminal history. It also aims to reduce recidivism through the
employment of qualified ex-offenders.
APPROVE OTHER
RECOMMENDATION OF CNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
Action of Board On: 09/09/2014 APPROVED AS RECOMMENDED OTHER
Clerks Notes:
VOTE OF SUPERVISORS
AYE:John Gioia, District I
Supervisor
Candace Andersen, District II
Supervisor
Karen Mitchoff, District IV
Supervisor
Federal D. Glover, District V
Supervisor
ABSENT:Mary N. Piepho, District III
Supervisor
Contact: Kathy Ito (925) 335-1754
I hereby certify that this is a true and correct copy of an action taken and entered on the minutes of the
Board of Supervisors on the date shown.
ATTESTED: September 9, 2014
David Twa, County Administrator and Clerk of the Board of Supervisors
By: June McHuen, Deputy
cc: IOC Staff, PPC Staff, HR Director, Asst CAO
C.151
To:Board of Supervisors
From:INTERNAL OPERATIONS COMMITTEE
Date:September 9, 2014
Contra
Costa
County
Subject:IMPLEMENTATION OF "BAN THE BOX" LEGISLATION IN THE PERSONNEL HIRING PROCESS
BACKGROUND: (CONT'D)
> The law requires that any inquiry about convictions on an employment application must be removed. Under
existing law, California Labor Code Section 432.7, the employer is already prohibited from inquiring into arrests
or into convictions that have been dismissed, with some explicit statutory exceptions. In addition, covered
employers must delay any inquiry into convictions until after the employer has determined the applicant meets the
minimum employment qualifications, as stated in the notice for the position, with some exceptions. Labor Code
Section 432.9 does not apply to a position for which a state or local agency is otherwise required by law to
conduct a conviction history background check (e.g., state laws regulate workers caring for children, the elderly
and other sensitive populations), to any position within a criminal justice agency, as that term is defined in Section
13101 of the Penal Code, or to any individual working on a temporary or permanent basis for a criminal justice
agency on a contract basis or on loan from another governmental entity.
The Human Resources Department took the necessary steps to ensure the criminal conviction question was
removed from the County employment application prior to the July 1, 2014 effective date and is working with
County departments to administer the hiring process under the new conditions.
On June 17, 2014, the Board of Supervisors made a joint referral to the Public Protection Committee and the
Internal Operations Committee to review the County's implementation of the Ban the Box legislation. Both
Committees received the same report prepared by the Human Resources Department. Under the new recruitment
process, disclosure of conviction history information is no longer required at the time of application unless it is for
a position for which the County is otherwise required by law to conduct a conviction history background check.
Information is collected electronically near the end of the recruitment process after the final HR scored
examination step (written exam, panel interview, performance test, etc.) and before the eligible list is established.
Candidates are to provide the conviction history form within three (3) business days of notification. At the end of
three business days, candidates who return the conviction history form are placed on the employment list and the
top ranked candidates (depending on the specific rules) become eligible for department selection interviews. For
recruitments where Ban the Box does not apply, completion of the conviction history form is required as a part of
the job announcement supplemental questionnaire. A conviction history record will not necessarily disqualify an
applicant or employee. Conviction records will be reviewed by Human Resources in conjunction with the
appointing authority for job-relatedness, taking into consideration recency, relevance, and rehabilitation.
Conviction history may result in a request for additional information, removal from an employment list, or release
from employment if warranted. This revised process will ensure the County’s compliance with AB218 while
ensuring County liability is kept at a minimum, candidate experience is not compromised, and barriers to
employment are removed.
The Human Resources Department is preparing a Conviction Information for Applicants FAQs and special
recruitment notices that will be made available to employees and the public on the County’s website. In addition,
staff is exploring the requirement that all finalists for County positions be fingerprinted, with the information
being used, as is done by several other counties, to verify conviction information provided by the candidates. Staff
continue to review job classes to determine what process is appropriate for each class depending on the hiring
department, and will conduct staff training on new procedures and responsibilities.
The approach recommended by the Human Resources Department was considered and approved by the Public
Protection Committee on July 28 and the Internal Operations Committee on August 4. The Internal Operations
Committee acknowledged that the criminal conviction history may be understated because the criminal record
expungement process permitted under Penal Code section 1203.4 may cause felony convictions to be reduced to
misdemeanors under certain circumstances.
ATTACHMENTS
Attachment A - Ban the Box Presentation to BOS 6-3-14
Attachment B - Ban the Box FAQ
Attachment C - Revised Contra Costa County Employment Application
Attachment D - DRAFT Criminal Conviction History Form
Attachment E - DRAFT Conviction Information FAQ for Applicants
“BAN THE BOX”
Implementation
1
What is “Ban the Box”?
“Ban the Box”, officially Assembly Bill 218
(California Labor Code Section 432.9),
prohibits state and local agencies from
inquiring about criminal convictions during the
employment application process until the
agency has determined that the applicant
meets the minimum employment qualifications
as stated in any notice issued for the position.
2
What is the intended purpose of
“Ban the Box”?
“Ban the Box” is intended to encourage the
hiring of qualified formerly incarcerated
individuals by ensuring that employers
screen applicants based on their work
qualifications, without consideration of their
prior criminal history. It also aims to
reduce recidivism through the employment
of qualified ex-offenders.
3
What does “Ban the Box” Require?
“Ban the Box” requires the removal of self-
reporting questions about conviction history
from employment applications.
This expands current law which precludes local and state
agencies from inquiring into arrests or convictions that have
been dismissed, with some statutory exceptions.
4
What does “Ban the Box” Require?
In addition, “Ban the Box” requires that an
employer must delay any inquiry into
convictions until after the employer has
determined that the applicants meet the
minimum employment qualifications, as
stated in the notice for the position, with
some exceptions.
5
Which employers are subject to
“Ban the Box”?
“Ban the Box” applies to state agencies,
cities, counties, chartered cities and
counties and special districts (e.g., fire
protection districts, water districts).
6
Exemptions from “Ban the Box”
The law does not apply to:
a position for which a state or local agency is otherwise required by law to conduct a conviction history background check (e.g., state laws regulate workers caring for children, the elderly and other sensitive populations);
any position within a criminal justice agency (defined
by Section 13101 of the Penal Code); or
any individual working on a temporary or permanent basis for a criminal justice agency, on a contract basis or on loan from another governmental agency.
7
When is “Ban the Box” effective?
“Ban the Box” was signed by Governor
Brown October 10, 2013, became law
January 1, 2014, and is operative July 1,
2014.
8
What steps has the County taken
to implement “Ban the Box”?
Revised employment application to remove
the check “box” and associated question
regarding criminal convictions.
New application will “go live” Monday, June
30th.
Created FAQ which explains law to job
applicants and County departments.
Providing training and implementation
assistance to County department personnel.
9
BAN THE BOX FAQ
What is Ban the Box?
Ban the Box, officially Assembly Bill 218 (California Labor Code Sec. 432.9), was signed by Governor
Brown on October 10, 2013 and is operative July 1, 2014. The law prohibits state and local agencies
from inquiring about criminal convictions during the employment application process for most positions
until the agency has determined that the applicant meets the minimum employment qualifications as
stated in any notice issued for the position.
What does Ban the Box (California Labor Code Section 432.9) require?
• Any inquiry about convictions on an employment application must be removed. Under existing law,
California Labor Code Section 432.7, the employer is already prohibited from inquiring into arrests or
into convictions that have been dismissed, with some explicit statutory exceptions.
• The employer must delay any inquiry into convictions until after the employer has determined the
applicant meets the minimum employment qualifications, as stated in the notice for the position, with
some exceptions.
What is the intended purpose of Ban the Box?
Ban the Box is intended to encourage the hiring of qualified ex‐offenders by ensuring that employers
screen applicants based on their work qualifications, without consideration of their prior criminal
history. It also aims to reduce recidivism through the employment of qualified ex-offenders.
Which employers are subject to Ban the Box?
State agencies, cities, counties, chartered cities and counties and special districts (e.g., fire protection
districts, water districts).
When does Ban the Box go into effect?
AB 218 (California Labor Code Section 432.9) will be operative July 1, 2014.
Are there any other exemptions from the law?
This section shall not apply to a position for which a state or local agency is otherwise required by law to
conduct a conviction history background check (e.g., state laws regulate workers caring for children, the
elderly and other sensitive populations), to any position within a criminal justice agency, as that term is
defined in Section 13101 of the Penal Code, or to any individual working on a temporary or permanent
basis for a criminal justice agency on a contract basis or on loan from another governmental entity.
Contra Costa County
DATE RECEIVED For Human Resources Use Only
Accepted Rejected
EMPLOYMENT APPLICATION
AN EQUAL OPPORTUNITY EMPLOYER
Contra Costa County Human Resources
651 Pine Street – 2nd Floor
Martinez, California 94553-1292
www.cccounty.us/hr
Analyst Date
Reason: Educ. License/Cert.
Exp. Incomplete
Other
POSITION APPLYING FOR:
PRINT EXACT JOB CLASSIFICATION TITLE
PLEASE TYPE OR PRINT IN INK
1. Social Security Number – for Applicant/Employee Record Control (Voluntary)
2. Name:
Last Name First Name Middle Name
3. Address:
No. Street Apt. No. City State/Zip Code
4. Phones:
( )( )( )
Home/CRS/TTY Work Cell Phone
5. E-mail Address:Driver’s License:
State Number Expiration Date
6. After employment, can you submit verification of your legal right to work in the U.S.? Yes No
7. Yes
No
_____________________________________________________________________________________________________________________________________
_____________________________________________________________________________________________________________________________________
_____________________________________________________________________________________________________________________________________
8. Are you fluent in any language other than English? If so, please specify:
9.
Verify (v)
OFFICE USE ONLY
10. Are you currently a Contra Costa County employee? Yes No If yes, enter Employee Number ____________
AK-1 (6/14)
EQUAL EMPLOYMENT OPPORTUNITY
To assist Contra Costa County in its commitment to Equal Employment Opportunity, applicants are asked to voluntarily provide the following information. To demonstrate that we meet equal
employment opportunity requirements, periodically we must report statistical information about applicants and employees to the State and Federal Governments. When reported, data will not identify
a specific individual. This questionnaire will be detached from the application prior to the examination, will be kept separate and confidential and will not be used in employment decisions.
Please answer all questions by placing an “X” in the appropriate box. (see reverse for definitions)
RACE/ETHNICITY: Only one box may be marked. Person of mixed races should classify according to the ethnic group with which they identify.
1 American Indian or Alaska Native (Not Hispanic or Latino) EMAN
2 Asian (Not Hispanic or Latino)
3 Black or African American (Not Hispanic or Latino)POSITION APPLYING FOR
4 Filipino (Not Hispanic or Latino)
GENDER:MALE FEMALE
Bid/Transfer
Deep Class Reassignment
Flexibly Staffed Promotion
Student Worker
Temporary
Temporary Upgrade
Have you ever been rejected during a probationary period, forced to resign in lieu of termination, dismissed,
fired, terminated, or had an employment contract terminated from any position for performance or for
disciplinary reasons within the last ten (10) years?
Veterans’ Points – In open examinations, Contra Costa County will add five percent (5%) to your earned examination
score if you pass the examination AND meet one of the following qualifications:
(1) You have served continuously on active duty for more than 180 days and received an honorable discharge by
the final filing deadline for the examination; or
(2) You are a disabled veteran.
To apply for points you MUST submit a copy of Form DD214 that indicates an honorable discharge or a general discharge
under honorable conditions before the final filing deadline. Written verification of disability from the Veteran’s Administration
is required for disabled veterans. Veterans’ points do not apply to promotional examinations.
Please mark (X) in the box if you are applying for Veterans’ Credit and have attached the proper documentation.
5 Hispanic or Latino
6 Native Hawaiian or Other Pacific Islander (Not Hispanic or Latino)
7 White (Not Hispanic or Latino)
8 Two or More Races (Not Hispanic or Latino)
AGE:UNDER 40 40 OR OVER
Administrative Intern
Merit System Title ___________
PRINT EXACT JOB CLASSIFICATION TITLE
11.EDUCATION: Check appropriate box if you possess one of the following:
High School Diploma G.E.D. Certificate California High School Proficiency Certificate
Highest Grade or Education Level Achieved?___________________________________________________________________________
Names of colleges / universities attended Course of Study / Major Degree Awarded Units Completed Degree
Type
Date Degree
Awarded Semester Quarter
A) Yes No
B) Yes No
C) Yes No
Other schools / training completed:
D)
Course Studied Hours Completed Certificate Awarded
E)
Title Issue Date Expiration Date Number
Licenses, certificates or registration required for this job ________________________
________________________
_____________________
_____________________
____________________
____________________
___________
___________
12.THE FOLLOWING SECTION MUST BE FILLED OUT COMPLETELY. List experience that relates to the qualifications as required on the job
announcement. Begin with your most recent experience. List each promotion separately. Use additional sheets if necessary. Voluntary non-paid experience
will be accepted if job related. A resume or other supporting documentation may be attached but it may not be used as a substitute for completing this section.
A) Dates (Month, Day, Year) Employer’s Name and Address Duties Performed
From
To
Total
.soM .srY Title
Salary $ _________ Hrs. per week_____ Reason for Leaving
Volunteer
B) Dates (Month, Day, Year) Employer’s Name and Address Duties Performed
From
To
Total
.soM .srY Title
Salary $ _________ Hrs. per week_____ Reason for Leaving
Volunteer
C) Dates (Month, Day, Year) Employer’s Name and Address Duties Performed
From
To
Total
.soM .srY Title
Salary $ _________ Hrs. per week_____ Reason for Leaving
Volunteer
D) Dates (Month, Day, Year) Employer’s Name and Address Duties Performed
From
To
Total
.soM .srY Title
Salary $ _________ Hrs. per week_____ Reason for Leaving
reetnuloV
E) Dates (Month, Day, Year) Employer’s Name and Address Duties Performed
From
To
Total
.soM .srY Title
Salary $ _________ Hrs. per week_____ Reason for Leaving
Volunteer
F) Dates (Month, Day, Year) Employer’s Name and Address Duties Performed
From
To
Total
.soM .srY Title
Salary $ _________ Hrs. per week_____ Reason for Leaving
reetnuloV
13.How did you hear of this position? CCC Website Walk-In Advertisement CCC Job Hotline Other
___________________________
14.I authorize the employers and educational institutions identified in this employment application to release any information they have concerning my employment or education
to Contra Costa County Yes No May we contact your present employer? Yes No
15.I certify that the information I have entered on this application is true and complete to the best of my knowledge. I further understand that any false, incomplete, or incorrect
statements, regardless of when they are discovered, may result in my disqualification from the examination process or dismissal from employment with Contra Costa County.
______________________________________ _____________________________________
DATE SIGNATURE OF APPLICANT
DEFINITIONS:
1. American Indian or Alaska Native (Not Hispanic or Latino) - A person having origins in any of the original peoples of North and South America (including Central America), and
who maintain tribal affiliation or community attachment.
2. Asian (Not Hispanic or Latino) - A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian Subcontinent, including, for example,
Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, Thailand, and Vietnam.
3. Black or African American (Not Hispanic or Latino) - A person having origins in any of the black racial groups of Africa.
4. Filipino (Not Hispanic or Latino) – A person having origins in any of the original peoples of the Philippine Islands.
5. Hispanic or Latino - A person of Cuban, Mexican, Puerto Rican, South or Central American, or other Spanish culture or origin regardless of race.
6. Native Hawaiian or Other Pacific Islander (Not Hispanic or Latino) - A person having origins in any of the peoples of Hawaii, Guam, Samoa, or other Pacific Islands.
7. White (Not Hispanic or Latino) - A person having origins in any of the original peoples of Europe, the Middle East, or North Africa.
8. Two or More Races (Not Hispanic or Latino) - All persons who identify with more than one of the above five races.
Contra Costa County
Conviction History Form
(Return to Human Resources within 3 Business Days)
Complete and return this form to: Human Resources Department, 651 Pine Street, 2nd Floor, Martinez, CA 94553
Position Applying for (Exact Title):
Last Name First Name Middle Initial
Other Name(s) Used
Street Address Apt.
No.
Primary Telephone
Number
( )
City State Zip Code Alternate Telephone
Number
( )
Email Address
Social Security Number:
Drivers License Number:
Important Reminder: You will be asked to submit a copy of this form each time you are being considered for a position. Please keep a copy for
your records.
CONVICTIONS
Have you ever been convicted of any crime by any court, including a military court, except as provided below? ☐YES ☐NO
A conviction includes a plea, verdict or other finding of guilt. This question includes any conviction for which you
have received a pardon. However, unless you are applying for a position as a Peace Officer or with a Criminal
Justice Agency, you do not need to disclose any conviction that falls within one of the categories identified below. If
you have more than one conviction, and they all fall within one of the categories identified below, you should check
“no” to this question.
i) any record regarding a referral to or participation in any pretrial or post trial diversion program;
ii) any conviction where you have successfully completed a deferred entry of judgment program. If you are
currently participating in a deferred entry of judgment program, you must disclose that conviction;
iii) a conviction where the Court has ordered the record sealed, expunged or statutorily eradicated;
iv) a conviction for a traffic offense where the fine was less than $400;
v) a misdemeanor conviction for which probation was successfully completed or otherwise discharged and the
case has been judicially dismissed under Penal Code Section 1203.4;
vi) a conviction that is more than two years old and is for one of the following violations: (i) Health & Safety Code
Section 11357(b) or (c), or any statutory predecessor to that section; (ii) Health & Safety Code Section 11360(c),
or any statutory predecessor to that section; or (iii) Health & Safety Code Sections 11364, 11365, and 11550 as
they relate to marijuana prior to January 1, 1976, or any statutory predecessors to those sections; or
vii) any conviction while a juvenile (under 18 years old), unless the job announcement identifies particular
convictions that must be disclosed for that particular classification or position, regardless of age when convicted.
If you answered “YES,” please provide the following information for each arrest or conviction. You may voluntarily provide any explanation that you wish to
have considered as part of your application, including any evidence of rehabilitation. If you need more space, please use an additional piece of paper and
attach to this form.
Violation:
Court:
Date and place of
conviction:
Penalty (fine, sentence,
dates of probation):
Name under which
convicted
Explanation (optional):
CERTIFICATION OF APPLICANT (please read carefully): I hereby certify that all statements made in this Conviction History Form are true and complete to the best
of my knowledge. I understand that any false, incomplete or incorrect statement, regardless of when discovered, may result in my disqualification or dismissal from
employment with Contra Costa County.
Date: Signature of Applicant:
Conviction Information for Applicants ~ FAQ’s
1
Effective July 1, 2014, Contra Costa County modified its application process to comply with
Assembly Bill 218 (Ban the Box). AB 218 prohibits all state and local agencies from asking an
applicant to disclose information regarding criminal convictions until the agency has determined
the applicant meets the minimum employment qualifications for the position. Applicants who
successfully complete and pass all of the recruitment’s examination phases described in the job
announcement will be required to submit a conviction history questionnaire. Positions in criminal
justice agencies or currently required by law to pass background checks are exempted from this
bill and applicants may be required to submit conviction information at the time of application.
(1) Does AB 218 prohibit the County from considering a job applicant’s criminal
convictions at all in the hiring process?
No, a public agency can still take into account the same considerations regarding a job
applicant’s criminal convictions as before AB 218. The only difference is when in the
recruitment process such conviction information can be considered.
(2) Will the conviction question still be asked?
Yes, the conviction question will still be asked, but will not be part of the initial application
form.
If you successfully complete and pass all of the recruitment’s examination phases, as
described in the job announcement, you will be instructed by the Human Resources
Department to submit a conviction history questionnaire.
You will have three (3) business days from when the instructions are sent to you by e-
mail to complete and submit the questionnaire online. Failure to do so within this
timeframe will disqualify you from the rest of the recruitment process.
(3) What do I need to prepare to provide a complete conviction history?
When requested, you will need to provide information regarding any felony or
misdemeanor conviction(s) since your 18th birthday, unless the conviction(s) falls under
one of the exceptions listed on the Conviction History Form.
Click here to view a sample Conviction History Form.
(4) Who reviews and has access to my conviction history?
Review of conviction information is limited to designated Human Resources and
Appointing Authority staff for the purpose of determining whether the conviction(s) is
related to the position for which you have applied.
Conviction information is not provided to members of the examination committees or
panels.
(5) Will I be disqualified if I have been convicted of a misdemeanor or felony?
Conviction information is reviewed on a case-by-case basis. Answering “YES” to having
a conviction(s) does not automatically disqualify you from employment. However, failure
to disclose convictions may result in termination or denial of employment.
(6) What kinds of convictions do I need to include?
Generally, you must disclose any felony or misdemeanor conviction(s) since your 18th
birthday, unless that conviction(s) falls under one of the exceptions listed on the
Conviction History Form.
(7) What should I do if I have more than one conviction?
If you have more than one conviction, you should list the following information for each
conviction:
Violation (what was the offense [name the offense; not the penal code]
Court
Date of conviction (on or about)
Place of conviction (City, County, State)
Penalty (e.g. fine, sentence [time served, community service], court
probation, etc.)
Name under which convicted
Explanation (optional)
(8) I do not remember the specifics of my conviction history. What should I do?
If you do not know the specifics of a conviction, include all requested information as
accurately as possible.
In addition, if you do not remember specifics about your conviction(s), you may obtain
that information from the municipality in which you received the conviction(s).
You may also contact the Department of Justice at 916-227-3832 for information.
You may be disqualified from the rest of the recruitment process if the conviction
information is either not provided or not complete.
(9) Can I attach or submit a printout instead of filling out the Conviction History
form/questions on the supplemental application?
No, court and/or DMV print outs, police reports or rap sheets are not accepted in lieu of
you providing information regarding your conviction(s).
(10) I prefer to discuss my conviction history with someone in person. What should I do?
The conviction information you provide is confidential and review is limited to designated
Human Resources and Appointing Authority staff.
A complete conviction history must be submitted in the format requested within the
established submission period. Failure to do so may disqualify you from the rest of the
recruitment process.
You should be forthcoming with all conviction information. If you include information
indicating one conviction, and either fingerprints or background check results report
multiple convictions that could be considered dishonesty. Not providing conviction
information may result in the denial or termination of employment.
(11) I have already submitted my conviction history with a previous application or I’m
currently a County employee. Do I have to submit the information again?
Yes, you will need to submit conviction information for each recruitment process, when
requested.
You may be disqualified from the rest of the recruitment process if the conviction
information is not provided within the deadline or is incomplete.
(12) What happens if I do not submit the information by the deadline or it is incomplete?
You may be disqualified from the rest of the recruitment process if th e conviction
information is not provided within the deadline or is incomplete.
(13) How will I know if I do not successfully complete the conviction review process?
You will be notified of your status by the County.
(14) I have reviewed all of the information in the FAQ’s, but I still have questions. Who
should I contact?
If you have any further questions about conviction information, you may contact the
Human Resources Department at (925) 335-1701.