EXHIBIT C _ Third Party Supplier Background.pdf

Version 1: June 5, 2026

EXHIBIT C

DeKalb County Government Third-Party Supplier Background Screening Policy

I. Purpose and Scope

This policy establishes minimum background screening standards for third-party suppliers, which includes vendors, contractors, and/or subcontractors assigned to perform work under a DeKalb County contract who, as part of their scope of work, interface with the general public and who will:

1. Have direct or unsupervised contact with citizens, employees, other stakeholders, with a careful focus on minors, seniors, or other vulnerable populations;

2. Require access to secure County-owned or County-leased facilities; and/or

3. Have access to systems, financial information, money, critical infrastructure/assets, and confidential or sensitive data related to the County, its employees, and/or citizens; or

4. As otherwise determined by the Purchasing Director or designee.

Background screening requirements for these contractors shall align with the screening standards applicable to DeKalb County employees.

Exceptions and Waivers

The County may, at its sole discretion, waive background screening requirements on a case-by-case basis when the County determines that the scope of work does not warrant their use or the County determines it is not necessary/appropriate. However, the County reserves the right to reinstate any or all screening requirements at any time following an initial waiver.

II. Required Screenings

A. Criminal History Checks

Criminal history checks shall include, as applicable:

Federal/National and Multi-State Criminal Database Check — Provides information on criminal activity prosecuted at the federal district court level outside the county or state jurisdiction.

Multi-Jurisdictional Criminal History Records Check — Federal district and county criminal record searches for all jurisdictions in which the individual has lived or worked.

Statewide Criminal History Check — Data reflecting disposition information obtained by police departments, county cases forwarded from local courts, or other criminal data maintained by the State of Georgia.

County Criminal History Check — Criminal history courthouse searches

Third-Party Supplier Background Screening Policy

International Criminal History Check — Completed on an as-requested basis as determined by the Purchasing and Contracting Department.

Sex Offender Registry Check (National Registry) — Provides information regarding felony and misdemeanor convictions for sexual assault, aggravated sexual assault, aggravated criminal sexual contact, and/or kidnapping. Reports shall include offense date, charge, offense classification, and additional identifiers where available.

Patriot Act Scan (Terrorist Watch List) — Identifies individuals designated as terrorists by the Office of Foreign Asset Control (OFAC) through a comprehensive search of U.S. agencies and international sources.

Compliance Check (OIG/GSA) — Screens for exclusions related to Medicare/Medicaid fraud, as applicable to the scope of services.

B. Motor Vehicle Records and Drug Screening

Motor Vehicle Record (MVR) Check — Provides motor vehicle driving record covering, at minimum, the previous three (3) years, including any available Commercial Driver License (CDL) information where applicable.

Federal Motor Carrier Safety Administration (FMCSA) Drug and Alcohol Clearinghouse —Determines whether individuals who possess a CDL are prohibited from performing safety-sensitive functions, including operating commercial motor vehicles (CMVs), due to an unresolved drug and alcohol program violation.

Drug Screening —Conducted as required by applicable law, the scope of services, or otherwise directed by the Purchasing and Contracting Department.

III. Responsibilities

A. Purchasing and Contracting

Purchasing and Contracting is responsible for the administration and oversight of this policy.

The department shall review all submitted scopes of work to determine whether background checks are required for the requested services in accordance with this policy. Prior to the commencement of any contracted services, Purchasing and Contracting shall provide contractors with information regarding the County’s designated background screening party.

All inquiries from Contractors concerning the County’s designated background screening party shall be directed to the Human Resources Department.

B. User Departments

User departments are responsible for identifying and communicating to the Purchasing and Contracting Department, the nature and scope of work to be performed by third-party suppliers, and whether such work warrants the application of the minimum background screening standards established by this policy.

C. Contractor Responsibilities

Contractors shall bear all costs associated with required background screenings. Prior to assigning any covered individual to County work, the Contractor shall submit written certification to the Purchasing and Contracting Department confirming that all required screenings have been completed and that no disqualifying results were found.

As a condition of assignment to County work, all contractor personnel shall be required to notify their employer (the Contractor) immediately, and no later than twenty-four (24) hours of a conviction or anything that may negatively impact the public’s trust in the County occurring during the term of their assignment, regardless of the nature or severity of the offense. Prior to commencing work, the Contractor shall obtain a signed written acknowledgment from each covered individual affirming their understanding of and obligation to comply with this self-reporting requirement. Such acknowledgments shall be retained by the Contractor for the duration of the contract and at least two (2) years after the completion/termination of the contract and made available to the County upon request.

Upon becoming aware of any conviction or conflict of interest involving an individual assigned to County work, whether through employee self-report or other means, the Contractor shall notify the Purchasing and Contracting Department in writing within twenty-four (24) hours of receipt of such notice and shall immediately remove the individual from all County work assignments pending review and determination by the County.

D. County’s Background Screening Responsibilities

The County's designated background screening party shall perform background checks for contractors in alignment with the County's established screening process for employees.

Completed screening results shall be made accessible to the Purchasing and Contracting Department and Human Resources upon request.

IV. County’s Right To Deny Or Revoke Access

The County reserves the right to deny or revoke site or system access for any Contractor whose background screening and any other activity presents a safety or security risk to the County in the County’s sole discretion, its employees, or the public, subject to an individualized assessment conducted in a non-discriminatory manner consistent with applicable federal and state law.

V. Compliance with Applicable Law

All background screenings conducted pursuant to this Section shall comply with the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq., applicable Georgia law, and all other federal and state regulations governing employment screening. Contractor assumes full responsibility for obtaining required candidate authorizations and for the lawful use of all screening results.

VI. Material Breach

Failure to comply with any requirement within this policy shall constitute a material breach of contract and may result in termination for cause, and/or recommendation for placement on the County's Ineligible Source List.