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Sample report · IT Sales, remote · Cincinnati, Ohio

Sample Background Check Policy Report for a Remote IT Sales Position in Ohio

This page shows a complete sample background check policy report from our policy builder for a very small employer. A fictional IT company with eight employees entered one fully remote position. The information technology sales representative lives in Cincinnati. In return, the builder applied 31 federal, Ohio, and Cincinnati rules and wrote the draft policy language below. Read the guide first, then scroll through the full report exactly as the company received it.

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31
cited recommendations: 7 required by law, 11 recommended, 3 best practices, and 10 reminders
3
layers of law applied: federal, Ohio, and the City of Cincinnati, following the remote worker’s home
13
sections, from FCRA basics to lookback limits, driving records, social media, and a numbered draft policy

The scenario behind this sample background check policy

Every report starts with a short questionnaire. For this sample, a fictional employer, Tom’s Mobile IT Solutions, described a full-time, fully remote IT sales representative. The applicant lives in Cincinnati, Ohio, and will occasionally drive a personal vehicle to client sites. Moreover, the company employs eight people, is headquartered in Ohio, and uses a background screening company. It plans a criminal check, an employment verification, and a social media review. It also plans to ask about prior pay.

Three answers reveal gaps. The company is not sure it sends both adverse action notices. It also has no written screening policy and no written individualized assessment. Consequently, the report flags all three in its change list. This is the lightest of our three samples. Ohio has no fair-chance law for private employers, and an eight-person company sits below Title VII. Nevertheless, the FCRA applies in full, and the report shows exactly where the risk remains. Compare it with the registered nurse and shipping clerk samples.

Input What the company entered Why it changes the report
Position Information Technology Sales, full-time, remote, salaried at $128,500 a year Pay of $75,000 or more lifts the FCRA seven-year limit on non-conviction records. The report explains what may still be reported.
Employer Private company, no regulated industry, 8 employees Below 15 employees, Title VII does not apply, so uniform criteria become a recommendation rather than a requirement.
Work location Fully remote; applicant lives in Cincinnati (Hamilton County), Ohio; headquarters in Ohio Screening law follows where the work is performed, so Ohio and Cincinnati apply. Ohio has no private-employer fair-chance law.
Duties Occasional driving in a personal vehicle; no cash, patients, or vulnerable populations Adds a recommended motor vehicle record under the Driver’s Privacy Protection Act.
Checks planned Criminal search (“recommend for me”), ten-year lookback, diversions and convictions older than seven years, employment verification, social media review, prior-pay question The report recommends the search package, a seven-year scope, caution on non-convictions, and password-free social media review.
Gaps Adverse action “not sure”; no written policy; no written individualized assessment The two-step adverse action becomes a required change; the other two become recommendations, and the draft policy fills them.

How to read the report

Each recommendation is a card with a colored label and a plain-English instruction. A source line cites the statute, regulation, or guidance behind it. Therefore, your employment counsel can verify every item without re-researching it. The four labels tell you how much weight each card carries.

Required

A law that applies to this position requires or prohibits the step. Where two laws conflict, the report shows the strictest one as required.

Best practice

A step that well-run screening programs take everywhere. This sample has three, because Ohio leaves timing, lookback, and salary questions to the employer.

Reminder

Context the company needs: which laws apply and why, record-keeping periods, and the draft policy language itself.

The strictest rule wins

This position is covered by federal law, Ohio law, and a Cincinnati ordinance at the same time. Where they overlap, the report picks the most protective one. Here, however, the state and city add little. Ohio’s ban-the-box law covers public employers only, and Cincinnati’s salary-history ban starts at 15 employees. As a result, the FCRA carries most of the required items, and the report says so plainly.

Gaps become a change list

Near the end, the section “Your process: what to change” repeats only the cards where current practice falls short. Here it lists three items. Put the two-step adverse action sequence in place, adopt a written screening policy, and use a written individualized assessment. Additionally, the numbered draft policy folds every required item into language the company can adopt.

What the sections cover

The report has 13 sections in a fixed order. It opens with the FCRA steps every employer must follow. Then it explains which laws apply and when the company may ask about criminal history. Next, it covers which records count and how far back to look. After that come notices, the search package, credit reports, drug testing, salary history, and other checks. Finally, it lists the process changes and the draft policy.

The sample report: Information Technology Sales, remote in Cincinnati

Below is the full report, rendered as HTML. The cards match what the company saw on screen and in its 10-page PDF. The employer and contact are fictional. However, every rule, citation, and date is real and current as of September 28, 2026. Use the chips to jump to a section.

Start hereLaws applied to this positionWhen you may ask about criminal historyWhich records you may considerHow far back you may lookIndividualized assessment and required noticesRecommended searches for this positionEmployment credit reportsDrug and marijuana testingSalary historyOther checks and verificationsYour process: what to changeDraft policy language for this positionYour answers

Background Screening Policy Recommendations

Information Technology Sales

Generated September 29, 2026 for Tom’s Mobile IT Solutions (Thomas McNeill). This report applies the federal, state, and local employment-screening laws that govern the position described below. Where rules conflict, the strictest rule is shown as required. Rules current as of September 28, 2026.

Required or prohibited by law 7Strongly recommended to reduce legal risk 11Best practice 3Informational reminder 10

Start here: the foundation of every screening policy

These items apply to every position you screen. Put them in place before anything else.

Required

Stand-alone disclosure and signed authorization before every report

Before you order any report from a background screening company, give the applicant a written disclosure that consists solely of the statement that a consumer report may be obtained for employment purposes, and get a signed (or e-signed) authorization. Keep waivers, extra terms, and state notices off the disclosure page; put state-required language on a separate page. Certify to the screening company that you have done this and will follow the adverse-action rules.

Source: 15 U.S.C. § 1681b(b)(2) Read the law page →

Required

Two-step adverse action before any rejection based on a report

If a report may lead you to reject an applicant, first send a pre-adverse action notice with a copy of the report and the CFPB Summary of Rights, then wait at least five business days for the applicant to respond, and only then send the final adverse action notice naming the screening company, stating that it did not make the decision, and explaining the right to dispute and to a free copy within 60 days. Your answers show the two-step sequence is not in place today.

Source: 15 U.S.C. §§ 1681b(b)(3), 1681m Read the law page →

Reminder

When rules conflict, the strictest one wins

This position is subject to 3 layers of law (federal, state, and local). Where they differ, follow the most protective rule for the applicant; that is the rule shown as “required” below. Recommendations are current as of September 28, 2026.

Reminder

Keep the file

Keep the disclosure, authorization, report, assessment notes, and notices for at least one year after the decision (two years for federal contractors); several laws require longer (Maryland four years, Los Angeles and San Francisco three years, Massachusetts CORI acknowledgments one year with a dissemination log). Store reports separately from the personnel file and dispose of them securely.

Source: 29 C.F.R. § 1602.14; FTC Disposal Rule

Laws applied to this position

Reminder

Federal law

The Fair Credit Reporting Act governs every report prepared by a screening company; Title VII and the EEOC’s 2012 guidance govern how criminal history may be used (15 or more employees); the ADA governs the timing of medical examinations.

Source: 15 U.S.C. § 1681 et seq.; 42 U.S.C. § 2000e Read the law page →

Reminder

Ohio state law

Applied because work is performed in Cincinnati, Hamilton County, Ohio. State agencies, counties, cities, and townships may not include criminal-history questions on application forms. No rule covers private employers; many Ohio cities and counties apply fair-chance rules to their own hiring.

Source: Ohio Rev. Code § 9.73 (HB 56, Mar. 23, 2016 — public employers) Read the law page →

Reminder

City of Cincinnati ordinance

Employers with 15 or more employees in the city may not ask about or rely on salary history and must provide a pay scale on request after a conditional offer.

Source: Cincinnati Mun. Code ch. 804 (Mar. 13, 2020) Read the law page →

When you may ask about criminal history

Best practice

Consider waiting until after a conditional offer anyway

No fair-chance timing law covers this position, so you may ask about convictions on the application. Waiting until after a conditional offer is still the better practice: it removes the question from the application (which the EEOC recommends), keeps one process for all your locations, and lets you show that the record was the only reason for a change in decision.

Source: EEOC Enforcement Guidance (2012)

Which records you may consider

Required

Never consider sealed, expunged, set-aside, or pardoned records

Every jurisdiction that applies bars their use. Applicants may lawfully deny that these records exist, and screening companies may not report them. Clean-slate laws now seal eligible records automatically in many states, so a record that appeared on a report last year may be off-limits this year. Employers may ask only about convictions that remain unsealed, unless the question bears a direct and substantial relationship to the position (Ohio Rev. Code § 2953.34(N)(2)); applicants may answer as if a sealed case never happened, and may not be questioned about expunged convictions at all. An employer that hires a person holding a certificate of qualification for employment is immune from negligent-hiring liability if it knew of the certificate at the time of the alleged negligence (§ 2953.25(G)).

Source: State sealing and expungement statutes Read the law page →

Required

Never consider juvenile records

Juvenile adjudications are confidential in every state that applies to this position and may not be requested or used.

Source: State juvenile-records statutes; FCRA § 605

Required

Convictions: consider only those that relate to this job

Felony and misdemeanor convictions may be considered, but only through the individualized assessment described below and only where the offense relates to the duties of a Information Technology Sales. Blanket exclusions (“no felonies”) are unlawful in the fair-chance jurisdictions that apply here and are treated as presumptively discriminatory by the EEOC everywhere.

Source: EEOC Enforcement Guidance (2012); state fair-chance laws

How far back you may look

Best practice

Recommended lookback: seven years

No state seven-year cap covers this position. Under the federal FCRA, convictions may be reported at any age, and because the position pays $75,000 or more, non-convictions may also be reported beyond seven years. Recommended scope: seven years. The EEOC treats older records as weaker evidence of risk, and a fixed written limit is easier to defend than open-ended review.

Source: 15 U.S.C. § 1681c; EEOC Enforcement Guidance (2012)

Individualized assessment and required notices

Recommended searches for this position

Required

Database results must be verified at the source before you act on them

A national multi-jurisdictional database is a locator tool. Before any adverse decision, the record must be confirmed against the court of record (the FCRA requires screening companies to keep public-record information complete and current, and several states bar reliance on unverified database hits). Never reject on a database-only result.

Source: 15 U.S.C. § 1681k Read the law page →

Employment credit reports

Reminder

No credit report planned

No credit-check restriction applies here. If you add one later, limit it to roles with financial responsibility and document the job-related reason.

Drug and marijuana testing

Reminder

No drug testing planned

You indicated no drug testing for this position. If you add it later, re-run the builder: several of the jurisdictions here restrict marijuana testing and require written policies.

Salary history

Best practice

Salary-history questions are permitted here, but not recommended

No salary-history ban applies to this position. Roughly half the states and many cities prohibit the question, so a single nationwide practice of not asking is simpler, and pay-equity claims are easier to defend when offers are based on the budgeted range rather than prior pay. The City of Cincinnati ban applies to employers with 15 or more employees and does not reach you at your current size. If you grow past that threshold, the ban applies.

Source: Pay-equity best practice

Other checks and verifications

Reminder

Employment verification

Confirm dates, titles, and eligibility for rehire. Do not ask prior employers for pay history where a salary-history ban applies (and Massachusetts and Washington extend the ban to screening vendors).

Reminder

E-Verify is voluntary for this position

E-Verify is voluntary under federal law except for federal contractors with the FAR E-Verify clause (48 C.F.R. 52.222-54: enroll within 30 days of award, verify new hires within three business days of hire, and verify existing employees assigned to the contract). Every employer must still complete Form I-9 for each new hire: Section 1 by the first day of work and Section 2 within three business days of the first day of work (8 C.F.R. § 274a.2). The current Form I-9 is the 01/20/25 edition (expires 05/31/2027); USCIS also accepts the 08/01/23 edition through 05/31/2027. Several states mandate E-Verify for private employers above a size threshold; the state rule is shown where it applies. Industry-limited mandates in your states do not reach this employer: Ohio: Mandate limited to construction: nonresidential construction contractors, subcontractors, and labor brokers must verify each employee hired for a nonresidential construction project (buildings, highways, bridges, utilities and related infrastructure, excluding residential and agricultural buildings) through E-Verify and keep the verification for three years after hire or one year after separation, whichever is later; they may not keep an employee after a final nonconfirmation (§§ 4151.02–4151.03). The attorney general enforces with civil penalties, and state agencies must require compliance in nonresidential construction contracts (§ 4151.07). No mandate for other private employers.

Your process: what to change

Required

Two-step adverse action before any rejection based on a report

See “Start here: the foundation of every screening policy” above. If a report may lead you to reject an applicant, first send a pre-adverse action notice with a copy of the report and the CFPB Summary of Rights, then wait at least five business days for the applicant to respond,…

Source: 15 U.S.C. §§ 1681b(b)(3), 1681m Read the law page →

Draft policy language for this position

Reminder

Background Screening Policy — Information Technology Sales

1. Purpose and scope. [Company Name] conducts background screening for the position of Information Technology Sales to verify qualifications, protect employees, customers, and property, and comply with applicable law. This policy applies to all applicants for the position. The same searches and criteria apply to every candidate for the position.

2. Consent. Before any report is obtained from a consumer reporting agency, the candidate receives a stand-alone written disclosure and provides written authorization. State-required notices are provided on a separate page. [Company Name] certifies its compliance to the screening company.

3. Timing. Criminal history is not requested on the application or in job advertisements. [Company Name] asks about, searches for, and considers criminal history only on the application. Non-criminal checks (identity, employment, education, license) are completed first.

4. Searches. The screening package for this position consists of: county criminal court search in each county of residence and employment during the lookback period; statewide criminal search where available; national criminal database and sex-offender registry search, with all results verified at the source; employment verification; motor vehicle record. The lookback period is seven years. Records older than the lookback period, sealed, expunged, set-aside, or pardoned records, juvenile records, and arrests or charges that did not result in a conviction (other than pending charges whose alleged conduct relates to the position) are not considered.

5. Decision criteria. A conviction is considered only if it relates to the duties of the position. For a Information Technology Sales, the offense categories with a documented relationship to the job are listed in the position screening matrix. No candidate is rejected automatically because of a record.

6. Individualized assessment. Before withdrawing an offer because of a record, the hiring manager and Human Resources document the nature and gravity of the offense, the time elapsed since the offense or completion of the sentence, and the nature of the position; provide the candidate with the record and the preliminary reasons; allow at least 5 business days for the candidate to respond with evidence of inaccuracy, rehabilitation, or mitigating circumstances; consider the response; and issue a final written decision.

7. Adverse action. If a report may lead to an adverse decision, [Company Name] sends a pre-adverse action notice with a copy of the report and the Summary of Rights, waits the period in section 6, and then sends a final adverse action notice that names the screening company, states that the screening company did not make the decision, and explains the candidate’s dispute rights and right to a free copy of the report.

8. Salary history. [Company Name] does not ask candidates or prior employers about compensation history. Offers are based on the budgeted range for the position.

9. Records and confidentiality. Screening reports and assessment records are stored separately from personnel files, accessible only to those involved in the decision, retained for [one / two / four] years after the decision, and then securely destroyed.

10. Review. This policy and the position screening matrix are reviewed at least annually and whenever the position, its work locations, or applicable law changes. Rules current as of September 28, 2026.

Source: Draft for review by counsel

Your answers

The questionnaire answers that produced this report, exactly as the company entered them.

Job title Information Technology Sales
What type of employer are you? Private company
How many employees do you have across all locations? 8
Is your organization in any of these regulated industries? None of these
Will the background check be obtained from a background screening company (a consumer reporting agency) or run in-house by your staff? Screening company
Where will this position perform its work? Fully remote
Where does the applicant live? Cincinnati, Hamilton County, Ohio
Where is your company headquartered? Ohio
Who is being screened? New applicant
Employment status Full-time
Is this a managerial or executive position, or exempt from overtime under the FLSA? No
Does the position involve any of the following? None of these
Will the applicant drive as part of the job? Occasionally, in their own vehicle
Is this a safety-sensitive position under federal law, state law, or your own written policy? No
Is a background check for this position required by a federal or state law, a licensing board, a government contract, or a bonding or insurance requirement? No
Does the position require a security clearance or work on a federal contract? No
Does the position require a professional license or certification? No
How is this position paid? Annual salary
Expected annual compensation $128,500
Will you ask the applicant about their prior salary or wage history? Yes
Will you run a criminal history check? Yes
Which criminal searches do you plan to run? Not sure, recommend for me
Which record types do you want to consider? Felony convictions; Misdemeanor convictions; Pending charges; Diversion or deferred adjudication; Convictions older than 7 years
How far back do you want to look? 10 years
When do you currently ask about criminal history? Only after a conditional offer
Will you use a written individualized assessment (nature of the offense, time elapsed, relation to the job) before rejecting an applicant because of a record? No
Will you apply the same criteria to every applicant for this position? Yes
Will you request an employment credit report? No
Will you drug test? No
Which verifications will you run? Employment history
Will you pull a motor vehicle record (MVR)? No
Will you review the applicant’s social media or other public internet content? Yes
Will any automated, algorithmic, or AI-based tool be used to score, rank, or screen applicants or background reports? No
Will you rescreen employees or use continuous monitoring after hire? No
Will you check federal exclusion lists (OIG, SAM)? No
Has the applicant lived, worked, or studied outside the U.S. in the past 7 years? No
At what stage do you currently run the background check? After a conditional offer
Do you give applicants a stand-alone FCRA disclosure and get written authorization before ordering the report? Yes
When a report leads you to reject someone, do you send a pre-adverse action notice, wait, and then send a final adverse action notice? Not sure
What would you like the builder to produce? Both

Important

This report is general compliance information prepared from the laws in effect on the date shown. It is not legal advice and does not create an attorney-client relationship. Laws change frequently and local rules may add requirements; confirm the recommendations with your employment counsel before adopting a policy. screeningpolicy.com and Langley Porter AG LLC do not make hiring decisions and are not a law firm.

What an eight-person company does with this background check policy report

An eight-person company has no HR department, so the report is built to be finished in a week. The owner generates it and a lawyer reviews it. Then the screening vendor configures it and the owner follows it for every hire. Each step below takes less time than the research it replaces.

1

Send it to counsel

Forward the PDF to your employment lawyer. Every card cites its source, so review takes minutes rather than billable days.

2

Fix the change list

Work through “Your process: what to change.” Here that means the two FCRA letters, the draft policy, and a written assessment.

3

Brief your screening vendor

Order the recommended package: county and statewide searches with source-verified database results, an employment verification, and a motor vehicle record. Set the scope to seven years.

4

Adopt the draft policy

Fill in the bracketed fields and attach the screening matrix. Then calendar an annual review, or a new report when the law changes.

Why a remote hire in Ohio still needs a position-specific policy

The law follows the worker

A remote employee is screened under the law of the place where the work is done, not the headquarters. Here both are Ohio, so the stack is simple. However, hire the next remote seller in Illinois or California, and the same position needs a different report.

The FCRA never shrinks

Small size exempts the company from Title VII, and Ohio adds no fair-chance rule for private employers. In contrast, the FCRA applies to every employer that orders a report. The company was unsure about adverse action letters, so that item leads the change list.

High pay changes the lookback

Because the position pays $75,000 or more, the FCRA lets screening companies report non-convictions older than seven years. The report explains the exception and still recommends a seven-year written limit. Older records are weak evidence and easy to attack.

Build the report for your positionSee how the builder works

Sample background check policy report: frequently asked questions

What is a sample background check policy report?

It is a real output of our policy builder for one job position, shown here as an example. The report lists every federal, state, and local screening rule that applies to the position. It labels each one by weight, cites its source, and ends with draft policy language. This sample covers a fully remote IT sales position at an eight-person Ohio company, with the employee living in Cincinnati.

Is Tom’s Mobile IT Solutions a real employer?

No. The company and the contact name are fictional, and the answers were chosen to show a typical very-small-business remote hire. However, every rule, citation, penalty amount, and effective date is real. All of them are current as of the date printed on the report.

Why does an eight-person company still get required items?

The FCRA applies to every employer that orders a report from a screening company, regardless of size. It requires the stand-alone disclosure, the signed authorization, and the two-step adverse action sequence. Federal and state sealing and juvenile-record rules also bind every employer. Title VII and most fair-chance laws start at a size threshold, so those items appear as recommendations instead.

What do the red, amber, green, and blue labels mean?

Red means a law requires or prohibits the step. Amber means the step is strongly recommended to reduce legal risk, usually under EEOC guidance or negligent-hiring case law. Green marks a best practice with no legal driver. Blue marks a reminder that gives context, such as which laws apply or how long to keep records.

Why does the report mention the $75,000 salary threshold?

The FCRA bars screening companies from reporting arrests and other non-conviction items older than seven years. That limit is lifted for positions expected to pay $75,000 or more. This position pays $128,500, so older non-convictions may be reported. The report still recommends a seven-year written limit, because the EEOC treats older records as weak evidence.

Does Ohio have a ban-the-box law for private employers?

No. Ohio Revised Code section 9.73 removes the conviction question from public-employer applications only. Several Ohio cities apply fair-chance rules to their own workforces. Therefore, a private employer may ask on the application. The report still labels waiting until after a conditional offer as a best practice. The EEOC recommends it, and it keeps one process for every location.

Why is the two-step adverse action the first item in the change list?

The company answered “not sure” about its adverse action letters. The FCRA sequence is a pre-adverse notice, a waiting period, and a final notice. The FCRA requires both letters whenever a report may lead to rejection. Skipping them is the most common FCRA class-action claim against employers. Therefore, the report marks the sequence as a required change and spells out each step.

Can this company ask about salary history?

Yes, for now. Cincinnati bans salary-history questions for employers with 15 or more employees in the city, and Ohio has no statewide ban. With eight employees, the company is below the threshold. However, the report recommends not asking anyway. A single practice of not asking is simpler, and the ban applies as soon as the company grows past 15.

Can I use the draft policy language as written?

Treat it as a draft for counsel, not a finished policy. Fill in the bracketed fields, such as the company name and the retention period. Then attach the screening matrix and have your employment lawyer confirm the language. The report is general compliance information and not legal advice.

How do I get a report for my own position?

Open the policy builder, answer the questionnaire for one position and its work locations, and pay $25. The report appears on screen instantly and arrives by email as a PDF. Nothing you enter is stored on our servers. A remote position takes the same ten minutes; enter the place where the employee will actually work.

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Enter the position, the pay, and every place the person will work. Our engine compiles the applicable federal, state, and local screening laws and returns a color-coded report with draft policy language. Then your counsel reviews it and signs off.

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screeningpolicy.com is operated by Langley Porter AG LLC. Reports are general compliance information, not legal advice, and do not create an attorney-client relationship. Confirm every recommendation with your employment counsel before adopting a policy.