Employment Probity Checking Procedure

Intent

This Procedure provides guidance for the undertaking of employment probity checks required during the recruitment (talent acquisition) process and throughout the employment lifecycle to ensure James Cook University (JCU; the University) effectively mitigates risk and discharges its duty of care to students and staff.

Scope

This Procedure applies to all staff involved in the recruitment of Academic and Professional and Technical roles at JCU Australia.

This Procedure does not apply to volunteers, visiting or honorary appointments, or to the Singapore campus, JCU Brisbane, or any JCU controlled entities.

Definitions

Except as otherwise specified in this Procedure, the meaning of terms used are as per the Human Resources Policy Glossary.

Procedure

1. General

1.1 All positions require identification verification, right to work, gender-based violence declaration and qualification checks as part of JCU’s standard screening process. These checks are undertaken during offer of employment negotiations.

1.2 The requirement to conduct additional checks such as professional registrations, police checks, Working with Children (Blue Card), drivers license, medical, functional/physical, audiometry and/or immunisation checks is stipulated in the role profile or academic duty descriptor for identified positions. These checks are undertaken prior to an offer of employment being made.

1.3 If a position, because of its inherent requirements, (including, but not limited to, exercise of significant financial delegations, cybersecurity, cash handling, security-related responsibilities or access to drugs, chemicals or plant that is scheduled as either restricted or of chemical concern), requires consideration of a police check as a matter of probity, a satisfactory national police certificate, or Defence security clearance will be a condition of employment.

1.4 The requirement for candidates or staff to undergo probity checks is communicated in vacancy information or during selection processes.

1.5 Positions requiring checks are determined based on risk, seniority or impact of duties, in accordance with Appendix A Probity check requirements by position.

1.6 Where a position involves participation in research, projects or activities that are subject to Australian defence trade controls, export controls, autonomous sanctions, United Nations Security Council sanctions, or other legislated security or contractual restrictions, additional probity, eligibility or clearance requirements may apply as a condition of employment. Any such requirements will be determined by reference to the inherent requirements of the role and applicable law, and will be communicated in vacancy information or during the selection process.

2. Conducting Checks

2.1 Probity checks are administered by the Human Resources directorate through preferred suppliers during the appropriate stage of the selection or on-boarding processes, in accordance with Appendix A.

2.2 Where checks require the review of sensitive personal information such as medical details, these will be managed in accordance with privacy requirements and will not be disclosed to the University.

2.3 Where an existing staff member is considered for a position requiring checks, they are required to undergo these checks prior to being offered the position. Where this staff member has previously undergone the required checks prior to commencing their current role, and these checks are relevant to the vacant position, additional checks will not be required unless the original checks have expired.

2.4 Where a candidate chooses not to participate in the required checks, an offer of employment will not proceed.

2.5 Staff members offered employment under the direct appointment provisions are required to undergo checks prior to an offer being made.

2.6 Where an existing staff member chooses not to participate in checks prior to being offered a new position within the University, the offer will not proceed and their existing employment arrangements will stand.

2.7 Where probity checks identify issues requiring further investigation, the Director, Human Resources, or their delegate will determine whether an offer of employment will proceed, in consultation with the hiring manager and the Work Health and Safety (WHS) Unit as appropriate.

3. Change of Employment Status

3.1 Where a staff member’s probity status changes during their employment, they must notify their supervisor and/or Human Resources immediately. Examples of such changes include the cancellation of a Working with Children (Blue Card), declaring bankruptcy, clinical (AHPRA) deregistration, inability to complete inherent requirements due to non-work related injury or illness or similar.

3.2 Should this change of probity status impact their ability to fulfil the requirements of their role, it may prompt a misconduct/serious misconduct process that may result in termination of employment.

4. Administering Probity Checks

4.1 Human Resources is responsible for procuring the probity service provider, undertaking the checks and filing reports in accordance with appropriate document retention and privacy legislation during the selection or appointment processes.

4.2 Employment probity checking records are confidentially managed, stored and archived in accordance with the University’s Records Management Policy and Information Privacy Policy. Records are kept strictly confidential except in exceptional and very limited circumstances, where there is an immediate and serious risk to any individual’s health or safety, or where disclosure is required by legislation.

4.3 The costs for pre-employment probity checks which are performed by an external provider are the responsibility of the hiring work unit. Checks performed by Human Resources directly will not incur any costs to the hiring work unit.

4.4 Ongoing checks throughout the course of employment, for example annual professional registration checks or bi-annual audiometry assessments, are to be managed by the work unit and/or WHS Unit in accordance with document retention and privacy processes.

4.5 The costs for ongoing checks throughout the course of employment are the responsibility of the work unit.

Related policy instruments

Recruitment, Selection and Appointment Policy

Child Safety Policy

Working with Children Check (Blue Card) Procedure

Staff Code of Conduct

James Cook University Enterprise Agreement

Defence Industry Security Program Security Procedure

Related documents and legislation

Child Protection Act 1999 (Qld)

Universities Accord (National Higher Education Code to Prevent and Respond to Gender-based Violence) Act 2025

Working with Children (Risk Management and Screening) Act 2000 (Qld)

Working with Children (Risk Management and Screening) Regulation 2020 (Qld)

Schedules/Appendices

Appendix A Probity check requirements by position

Administration

NOTE: Printed copies of this procedure are uncontrolled, and currency can only be assured at the time of printing.

Approval Details

Revision History