HRPA Survey Report
The Use of Police Record
Checks in Ontario Workplaces
November 2023
Introduction
When hiring for new roles, organizations often want
to be as thorough as possible, ensuring that the
candidate they select is truly the best person for the
job. One way in which employers choose to
evaluate prospective employees is by using
criminal background checks, a common practice
that can have far reaching impacts on potential job
candidates. This report contains key highlights from
a 2023 survey of HRPA members examining the use
of police record checks in the workplace.
In Ontario, there are three types of police record
checks that an employer can request under the
Police Record Checks Reform Act, 2015 (PRCRA):
criminal record check, vulnerable sector check and
criminal record and judicial matters check. While
some roles legally require a police record check,
and there are further guidelines set out by the OHRC
detailing when the use of these checks is
acceptable, it can often be difficult for employers to
determine when a police record check is
appropriate. When overused, police checks can
have a disproportionate impact on racialized,
Indigenous and marginalized groups that are
overrepresented by the criminal justice system in
Canada, making it a counterproductive practice for
organizations that value diversity, equity and
inclusion.
The survey results offer a picture of how common
the use of police record checks are in hiring, the
types of policies and practices organizations have
in place to safeguard against discrimination, and
the impacts record checks may have on the ability
to hire and retain employees. The survey also found
that while awareness of the benefits and best
practices for fair chance hiring is low, there is an
appetite among HR professionals to learn more.
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HRPA Survey Report: Police Record Checks
Reading the Survey Report
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HRPA Survey Report: Police Record Checks
The survey was conducted between
September 21 – 27, 2023, with 445
HRPA members providing insights
into their organization’s criminal
background check policies and
processes.
Survey responses are presented as
a percentage, rounded to the
nearest whole number. Responses
to some questions may not total
100% due to rounding.
MAN = Manufacturing
NFP = Not for Profit
WR = Wholesale/Retail Distribution
BFPI = Banking, Finance, Pension Funds & Insurance
GPC = Government / Public Commissions
HSS = Health & Social Services
APREE = Agriculture, Primary Resources, Engineering & Energy
IT = Information Technology
EDU = Educational Institutions & Services
BPS = Business & Professional Services
The following map provides the full titles
for industry abbreviations used in the
report:
Survey Demographics
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HRPA Survey Report: Police Record Checks
2%
3%
4%
18%
23%
50%
Allied Professional
Student
CHRE
Practitioner
CHRP
CHRL
HRPA Registration Class (n=422)
2%
2%
24%
37%
11%
15%
10%
I am self-employed
Fewer than 10 employees
10 - 99
100 - 499
500 - 999
1000 - 4999
5000+
Organization Size by Number of
Employees (n=422)
39%
61%
Sector (n=419)
Public
Private
7%
91%
1%
Provincially or Federally
Regulated (n=417)
Federal
Provincial
Self-employed
3%
5%
5%
6%
7%
7%
11%
11%
13%
14%
IT
APREE
BFPI
WR
Edu
BPS
MAN
GPC
NFP
HSS
Top Industries
Represented (n=420)
Registration Class Percentage
Number of Employees Percentage
Industry Percentage
6
The survey results suggest that police record checks are a
very common screening tool used by Ontario workplaces
when hiring, with eight in ten (80%) respondents saying
that they do require police checks for employees and job
candidates at least some of the time.
When asked what level of police record checks their
workplace performs under the Police Record Checks
Reform Act, 2015 (PRCRA), over two-thirds of respondents
said criminal record checks (68%), followed by vulnerable
sector checks (50%). Only 14% said they conduct criminal
record and judicial matters checks, which is the most
robust of the three.
Using Police Record
Checks in Hiring
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HRPA Survey Report: Police Record Checks
Sectors with above average rates of
conducting police checks:
97% HSS
96% GPC
90% Public sector
80%
18%
2%
Does your organization ever require police record
checks for employees or job candidates? (n=445)
Yes
No
I don’t know
68%
14%
50%
3%
What level(s) of police record check does your
organization require? (n=357)
Criminal record check
Criminal record and judicial
matters check
Vulnerable sector check
My workplace is federally
regulated and the PRCRA
does not apply
One fifth (20%) of respondents say that their workplace
does not use police record checks in hiring. Responses
indicate that the practice does not provide relevant
information for hiring and adds too much red tape to
the process. Only 10% said record checks go against
their DEI policy, suggesting that the choice to not
require checks is based more in operational reasons.
Not Requiring Police
Record Checks in Hiring
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HRPA Survey Report: Police Record Checks
58%
45%
38%
23%
10%
10%
8%
There is no legislative requirement
for any roles we hire for
The information provided is not
relevant to the roles we hire for
We do not require this level of
bureaucracy when hiring
They are not a useful tool for
evaluating candidates
They go against our diversity, equity
and inclusion policy
Other
I don’t know
Why does your organization not require
police record checks? (n=78)
There is no legislative requirement for
any roles they hire for
Do not require this level of
bureaucracy when hiring
The information provided is not
relevant to the roles they hire for
58%
45%
38%
Response Percentage
Police Record Check Policies
Implementing a policy that outlines when and how police record
checks are required is one way in which organizations can ensure
that unnecessary checks are not requested of job candidates and
that the process is fair and applied evenly to everyone.
The survey found that the use of policies is widespread among
respondents who conduct police record checks, however responses
also indicate that policies are broad, with three-quarters (75%)
saying they require a record check regardless of the role.
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HRPA Survey Report: Police Record Checks
79%
67%
81%
Have policy/criteria
to determine when a
record check is
needed (n=357)
Have policy/criteria
to determine what
level of check is
required (n=356)
Have policy/best
practices to ensure
data privacy &
integrity when record
check is disclosed
(n=343)
75%
17%
13%
10%
3%
1%
It's a standard requirement for most/all
positions when hiring
It's requested if there is a legislative
requirement for the specific role
It's requested if no criminal record is a
bona fide requirement for the role
Other
It's at the discretion of the hiring
manager
I don’t know
How does your organization determine when a
police record check is required for a role?
(n=357)
55%
26%
15%
11%
3%
2%
We request the most basic check unless a
more robust check is required by law
A specific level of record check is required by
law for the position
Other
We request the highest level of check possible,
even if it is not necessarily required by law
I don’t know
It is at the discretion of the hiring manager
When requiring a police record check, how do you
determine what level of check to request? (n=351)
Response Percentage
Response Percentage
Hiring Impacts
Despite the high percentage of respondents who
conduct police record checks, 68% said they would
hire a candidate with a record depending on the
position, while 19% said they require a “clean” record.
Additional comments noted that the date the offense
occurred is also considered by employers.
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HRPA Survey Report: Police Record Checks
68%
19%
5%
8%
Will your company hire a qualified job candidate
who has a criminal record? (n=357)
Yes, depending on the
record/position
No, we require a
“clean” record
Other
I don’t know
Nearly one fifth (19%) of respondents say they believe
requiring a police record check has impacted their
organization’s ability to attract and/or retain
employees in the past while 68% said they do not
believe it has.
19%
68%
13%
Do you believe requiring a police record check
has ever impacted your organization’s ability to
attract and/or retain employees? (n=343)
Yes
No
I don’t know
They believe potential candidates did not apply at all
due to a criminal record check requirement being listed
in the job post.
Police checks took too long to complete and were too
costly for candidates
Qualified candidates withdrew their applications
Those who were impacted in hiring cited some of
the following issues:
Awareness of Fair
Chance Hiring
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HRPA Survey Report: Police Record Checks
Fair chance hiring, a term used to describe offering fair
and equal job opportunities to candidates, regardless of
their background, can have widespread positive impacts
on employees, workplaces and the economy. The
practice is an important facet of a well-rounded
diversity, equity and inclusion strategy, as racialized,
Indigenous and marginalized people are
overrepresented in Canada’s legal justice system and
are therefore more likely to be hindered by a criminal
record when searching for employment.
1
The survey results show that while police record checks
are an ingrained part of the hiring process at many
organizations, few respondents are familiar with the
evidence and benefits of fair chance hiring, with nearly
three quarters (74%) saying they are not at all familiar or
only somewhat familiar. While awareness is low, interest
in the practice is high with 61% saying they would like to
learn more if resources were offered to them.
1
Fair Chances Coalition. The Case for Fair Chance Employment.
41%
32%
19%
6%
2%
Not at all familiar
Somewhat familiar
Moderately familiar
Very familiar
Extremely familiar
How familiar are you with the evidence and
benefits of hiring people with criminal
records (also called “fair chance” hiring)?
(n=428)
61%
15%
24%
If there were free training/resources available on the
advantages & best practices for hiring people with
criminal records, would you like to learn more? (n=427)
Yes
No
I don't know
Response Percentage
