Policy

  1. This policy assists South Australian Government agencies to recruit eligible and suitable employees by undertaking appropriate and consistent pre-employment screening and vetting processes for all employees.
  2. Consistency in recruitment processes ensures a high-level of assurance that employees are fit to occupy their roles and undertake the responsibilities of their positions, including the protection of government information and resources.

Ensure the suitability of all new employees

  1. To ensure the suitability of all new employees, agencies [1] must:
    1. ensure all pre-employment checks are conducted in accordance with the South Australian Information Privacy Principles (IPPS) Instruction
    2. undertake all mandatory pre-employment screening checks, including:
      1. Pre-Employment Declaration consistent with the minimum standard issues by the Commissioner for Public Sector Employment
      2. identity and eligibility checks
      3. reference checks
      4. National Police Certificate or other appropriate background screening where required for the role
    3. any other checks that assist in determining an applicant’s suitability to hold the position and access South Australian Government information and resources
    4. identify and record all positions requiring a security clearance and the level of clearance required
    5. ensure people occupying identified positions hold valid security clearances issued by the Australian Government Security Vetting Agency (AGSVA), or another authorised vetting agency

[1] This policy applies to all South Australian public sector agencies (as defined in section 3(1) of the Public Sector Act 2009) and to any other person or organisation that is generally subject to the direction of a Minister of the Crown; all of which are referred to in this policy as “Agencies”.

Guidance

  1. Agencies must ensure all pre-employment screening checks are conducted in line with the South Australian Information Privacy Principles (IPPS) Instruction (PC012). [2]
  2. Agencies must obtain informed consent from all prospective employees to collect, use and disclose personal information (including sensitive information) for the purposes of reviewing their eligibility and suitability for employment. This must be completed in order for a prospective employee to progress for further consideration.
  3. Agencies may also request applicants complete a statutory declaration confirming the information they provide is truthful and complete.

[2] Under Schedule: Clause 2 (3), the IPPS does not apply to the following agencies: Independent Commissioner Against Corruption, Motor Accident Commission (formerly State Government Insurance Corporation), Compulsory Third Party Regulator, Office for Public Integrity, South Australian Asset Management Corporation, WorkCover Corporation of South Australia, Judicial Conduct Commissioner.

  1. Agencies have a responsibility to identify and manage any personnel security risks associated with each role within their agency. These risks must be addressed when recruiting people into new or existing positions, including any identified requirement for the employee to hold a security clearance [3].
  2. Pre-employment screening is the main method agencies can use to reduce their personnel security risks, safeguard their information, and maintain the continuous delivery of government services.
  3. All agencies must undertake pre-employment screening which achieves the minimum standards of the Premier’s Direction: Recruitment [4] and must have regard to apply the Guideline of the Commissioner for Public Sector Employment: Recruitment.
  4. The following outlines the pre-employment screening checks all agencies must undertake for all employees.

Positions of trust

  1. Recruiting people into a defined position of trust may require additional screening or other pre-employment measures according to the specific duties that the role is required to perform. Such duties may include :
    1. sensitive or priority negotiations or policy work
    2. responsibility for controlling access to valuable or attractive assets (including information)
    3. working in remote, dangerous or sensitive locations
    4. being required to liaise or share information with foreign officials
  2. Identifying a position of trust is a matter determined by the responsible agency, any whole-of-government security policies, and (if relevant) the regulatory body of the relevant profession.

Pre-employment declaration

  1. Agencies must obtain a completed Pre-Employment Declaration [5] from each applicant which is consistent with the Pre-Employment Declaration form issued by the Commissioner of Public Sector Employment.
  2. Agencies may expand this Declaration in order to meet any specific agency requirements and may be recreated within agency online recruitment systems. The information contained in the Declaration is designed to assist the assessment of the applicant to undertake the functions of the role and their suitability for employment in the South Australian Public Sector.

Identity and eligibility checks

  1. An identity check establishes confidence that an individual is who they say they are. Agencies must verify a person’s identity using the Document Verification Service [6] (DVS) for Australian issued primary identification documents [7].
  2. Access to the DVS can be arranged via the Department of the Premier and Cabinet (DPC) as an Across Government Service. It is recommended that agencies sight the original identity document.  
  3. An eligibility check ensures that an individual is eligible to work in Australia by establishing either the individual’s Australian citizenship, or valid work visa [8]. The DVS can verify both visas and ImmiCards for non-Australian citizens.[9]
  4. It is recommended that agencies undertake identity checks to at least Level of Assurance 3 of the National Identity Proofing Guidelines which includes verifying:
    1. the uniqueness of the identity in the intended context [10]
    2. the legitimacy of the claimed identity
    3. the operation of the identity in the community over time
    4. the linkage between the identity and person claiming the identity
    5. the identity not being used fraudulently

Reference checks

  1. Reference checks help agencies to determine a person’s quality, integrity and suitability by verifying past performance in employment, including conduct and behaviour. Checks must obtain information from someone who has direct knowledge of the applicant’s experience.
  2. Referee checks should cover a period of at least the previous 3 months. Where appropriate, information relating to the following may be sought:
    1. any substantiated complaints about the person’s behaviour
    2. information about any action, investigation or inquiry concerning the person’s character, competence or conduct
    3. any security related factors that might reflect on the person’s integrity and reliability

National Police Checks

  1. National Police Checks (NPC), also known as a criminal history check, involve processing a person’s identity to determine any matches to previous criminal convictions. Undertaking a National Police Check enables agencies to assess the person’s criminal history, where applicable, against the requirements of the role being undertaken or applied for.
  2. There are many Australian Criminal Intelligence Commission approved entities that can undertake national police checks, including South Australia Police and the Australian Federal Police, on a fee-for-service basis.
  3. It is strongly recommended that agencies require applicants to provide a copy of a valid NPC as part of their pre-employment screening processes.

Legislated screening checks

  1. Some employees may require additional screening checks as mandated by legislation in South Australia. These checks are:
    1. child-related employment and working with children checks
    2. disability services employment
    3. aged-care sector employment
  2. Agencies must determine if any positions of employment are subject to any of these checks and ensure these screening requirements are met prior to any offer of employment. The Department of Human Services Screening Unit undertakes each of the above checks on a fee-for-service basis.

Verifying suitability

  1. In addition to the mandatory checks outlined above, agencies may use any or all of the following screening checks to assist in determining a person’s suitability to occupy the role and have access to South Australian Government information and resources.
  2. Table 1 outlines additional pre-employment screening checks which may be considered.

Table 1 – Suggested pre-employment screening checks

Screening checkRationale
Employment history check

This check should identify unexplained gaps or anomalies in a person’s employment.

A person may not disclose periods of employment if they have been terminated or anticipate an adverse referee report. A history of short periods of employment may also indicate poor reliability.

Employment history information should be sought from human resources areas of former employers, where available. Where not available, referee checks or other previous employers may provide corroborating advice.

It is recommended that employment history checks for new employees cover a period of at least 5 years.

Residential history check

A residential history check helps substantiate a person’s identity in the community (see Identity checks).  Supporting evidence of a person’s current permanent residential address should be sought.

It is recommended that residential history checks for new employees cover a period of at least 5 years. Where applicable, agencies should consider whether a person’s explanation of any periods of residency that cannot be substantiated is reasonable.

Some other screening checks may require residential history checks be undertaken. It is recommended agencies identify which checks may already be undertaken to reduce any duplication.

Credit history check

Credit history checks assist to determine any concerns about a person’s finances, including financial defaults.

Credit history checks can be obtained from an accredited financial check organisation on a fee-for-service basis.

Qualification check

Qualification checks verify a person’s qualifications with the issuing authority.

Agencies may undertake qualifications checks with the issuing authorities, including universities, technical colleges or schools, as well as any professional associations or memberships that are required.

Conflict-of-interest declarations

Conflict-of-interest declarations identify conflicts, both real and perceived, between a person’s employment and their private, professional or business interests that could improperly influence the performance of their official duties, including the ability to protect South Australian Government information and resources.

Conflicts-of-interest could pertain to, but are not limited to, financial arrangements, secondary or additional employment and/or professional and private associations.

Under the Code of Ethics for the South Australian Public Sector, all employees are required to disclose to their Chief Executive or agency head in writing any actual or potential conflict-of-interest.  It is recommended that all agencies implement a conflict-of-interest policy which guides employees on what could be, or perceived to be, a conflict-of-interest, and when and how to report a conflict, consistent with the Public Sector (Honest and Accountability Act) 1995.

Digital footprint checks

Digital footprint checks include conducting an open internet search on a person, as well as identifying and reviewing their publicly accessible social media.

A digital footprint check can provide insight into a person’s life, interactions and personal views which may assist to identify issues of security concern and/or provide greater assurance that a person has provided a full and truthful account of themselves relevant to their integrity.

The PSPF provides guidance for establishing a digital footprint check framework under Annex E of Eligibility and suitability of personnel.

Entity specific checksAgencies may implement additional checks to those listed above in line with the individual requirements and function of the agency where the personnel security risks identified are not mitigated by the mandatory and recommended pre-employment screening checks listed above, giving consideration to any potential legislative restrictions or requirements.
Other legislated screening requirements

There are types of employment in South Australia which are subject to specific screening requirements, as mandated by legislation. These checks are:

  • - child-related employment and working with children checks
  • - disability services employment
  • - aged-care sector employment

Agencies must identify all positions subject to these legislative requirements and ensure the appropriate screening requirements are met prior to any offer of employment. The Department of Human Services Screening Unit undertakes each of the above checks on a fee-for-service basis.

[3] Where a security clearance is required, agencies must list this in the role/duty statement under ‘essential qualifications’.

[4] With the exception of Courts Administration Authority, the Legal Services Commission, the Independent Commissioner Against Corruption and Office for Public Integrity.

[5] The Pre-Employment Declaration includes a privacy statement outlining how personal information will be collected, used and disclosed, consistent with PC012.

[6] The DVS checks whether the personal information on an identity document matches the original record, making it harder for people to use fake identity documents.

[7] See Primary Identification Documents for more information

[8] See Migration Act 1958 (Cth)

[9] Agencies may also register for Visa Entitlement Verification Online (VEVO) to check visa details and conditions.

[10] This ensures that individuals can be distinguished from one another (e.g. people with the same name) and that the service is being provided to the correct individual.

Identifying positions requiring security clearances

  1. From time to time, there may be a need to share highly sensitive, or even security classified information of relevance to security with other agencies or entities. In such cases, the accountable authority is responsible for ensuring they have employees who hold the appropriate level of clearance to assess security classified information, including themselves.
  2. It is strongly recommended that the accountable authority of each agency obtain a security clearance to at least the level of Negative Vetting 1 (NV1). Any employees who might also be involved in a workflow involving security classified information (including handling of documents, system administration, access privileges etc.) must also obtain a security clearance to the same level as the accountable authority.
  3. It is also strongly recommended that all agency security personnel (ASE, ASAs, ITSAs, etc) also obtain security clearances to a level deemed appropriate by the accountable authority.
  4. Some employees in an agency may require a security clearance to access particular information or assets relevant to their position. Depending on the agency’s physical and information security risk profile, this may include access to specific information, physical locations within an agency, and/or specific information and communication technology (ICT) systems.
  5. Table 2 indicates the level of security clearance required for each security classification.
ClassificationSecurity Clearance Level
OFFICIAL: SensitiveNot required. Effective pre-employment screening is a sufficient security control
PROTECTEDBaseline  (BV)
SECRETNegative Vetting Level 1 (NV1)
TOP SECRETNegative Vetting Level 2 (NV2)
TOP SECRET (codeword) Positive Vetting [11]  (PV)
  1. Agencies may also identify positions for which a security clearance is required, in addition to pre-employment screening and entity specific checks, to provide a higher level of assurance about an individual’s integrity. This may be appropriate for positions where:
    1. the position will have access to aggregations of information or assets
    2. the nature of the role requires greater assurance about the person’s integrity (e.g. fraud mitigation or anti-corruption measure)
  2. Agencies must identify and record any positions that require a security clearance, and what level of clearance is required. It is recommended that agencies maintain a register which identifies:
    1. positions that require ongoing access to security classified information (PROTECTED or above)
    2. positions that require a higher-level of assurance of a person’s suitability than can be obtained through pre-employment and entity-specific screening checks
    3. when the requirement for a security clearance will be reassessed [12]
  3. All Negative Vetting 1 level security clearances and above are subject to an ASIO security assessment. Authorised vetting agencies may request an ASIO security assessment for Baseline security clearances if there are any concerns that may impact the national interest.

Security clearance exemptions

  1. Some Australian office holders are not required to hold a security clearance to access security classified information while exercising the duties of the office. The list can be found in PSPF policy Access to information. The exemptions referenced above do not apply to employees of named office holders.

Security clearance sponsorship

  1. All security clearances must be sponsored by an appropriate agency. In South Australia, all security clearances are sponsored by DPC. [13]
  2. The accountable authority/Agency Security Executive (ASE) of an agency must provide authorisation to DPC to commence a security clearance application. For information on how to apply for a security clearance see Security Clearances or email SASecurityClearances@sa.gov.au

Security clearance eligibility

  1. It is a requirement that to be eligible for an Australian Government security clearance, the individual must be an Australian citizen and have a checkable background. [14]
  2. The citizenship or checkable background requirements may be waived where the accountable authority of an agency can demonstrate there is an exceptional business requirement and has conducted an appropriate risk assessment. The vetting agency may still deny a security clearance if there are significant concerns about the individual’s suitability that cannot be mitigated, including concerns relating to the eligibility condition that was waived.
  3. The risk assessment for eligibility waivers must be based upon a specific position, individual and agency. Security clearances granted where a waiver has been issued cannot be transferred to a new position or agency, except where the exceptional business requirement and risk assessment are undertaken and accepted for the new position and agency.
  4. Details regarding exceptional business requirements and risk assessments can be found under PSPF policy Eligibility and suitability of personnel.

Recognising existing security clearance

  1. If an individual holds, or has previously held, a valid security clearance issued by an authorised vetting agency [15], sponsorship of that clearance may be transferred to a new agency. Agencies should identify if a prospective employee has or has ever held a security clearance prior to seeking a new one.
  2. Further details about recognition of existing security clearances can be found under Commonwealth PSPF policy Eligibility and suitability of personnel.

Authorised vetting agencies

  1. South Australian agencies must use AGSVA to conduct vetting, or where authorised14, conduct security vetting in a manner consistent with the personnel security vetting standards as outlined under PSPF policy Eligibility and suitability of personnel.
  2. State and territory governments may request AGSVA to conduct security vetting up to and including Negative Vetting 2. AGSVA will only issue security clearances where the vetting assessment is sponsored by an appropriate government authority.
  3. South Australian agencies must obtain informed consent from the clearance subject to collect, use and disclose their personal information for the purpose of assessing and managing their eligibility and suitability to hold a security clearance. These practices must be consistent with all privacy requirements of this policy.

Minimum personnel security checks for a security clearance

  1. PSPF policy Eligibility and suitability of personnel outlines the minimum security checks required, and any additional checks that may be required, for each level of security clearance.

Conditional security clearances

  1. If information of security concern is identified during the vetting process, but which is not sufficient to deny a clearance, those risks may be managed by applying conditions to a clearance. The accountable authority of the sponsoring agency and the clearance holder must agree to manage any conditions imposed. Non-compliance with any conditions in such circumstances may result in a review.

Sharing information of security concern

  1. If any information of security concern is identified during the vetting process, the sponsoring agency will be notified of any vulnerabilities or risk factors and mitigations that may have been applied to assist in understanding and managing any risks relating to the clearance holder’s ongoing access to South Australian Government resources.

Additional information

  1. Further information, including requirements for authorised vetting agencies can be found under the annexes of PSPF policy Eligibility and suitability of personnel.

[11]  State and Territory personnel require Commonwealth Government sponsorship to obtain a PV security clearance

[12] At least every time the position becomes vacant and before it is advertised

[13] South Australia Police (SAPOL) is an authorised vetting agency and clearance sponsor of SAPOL employees.

[14] A checkable background is where the vetting agency can complete the minimum checks and inquiries for the required period of time and is able to provide adequate assurances about the individual’s life or background for level of security clearance required.

[15] This includes a security clearance issued by a state or territory government in accordance with the Memorandum of Understanding for the Protection of National Security Information between the Commonwealth, states and territories, where the personal security file is transferred to an authorised vetting agency.

  1. Volunteers are people performing functions in an agency on a voluntary basis, and all agencies are required to implement a consistent approach to the management and support of volunteers.
  2. Under the Guideline of the Commissioner for Public Sector Employment Volunteers, it is recommended that agencies ensure they implement screening processes that identify any persons who may be unsuitable to act as volunteers, including any checks as mandated by legislation (see 24. Legislated screening checks). Agencies should develop volunteering policies specific to their needs and update them regularly, consistent with the policies of the South Australian Protective Security Framework and the Volunteer Guideline.

Approved by: Chief Executive, Department of the Premier and CabinetDate of first approval: 20 April 2020
Revision number: 2.0Date of review: 26 October 2022
Next review date: December 2024Contact: sapsf@sa.gov.au

Change log

VersionDateChanges
1.020/04/2020First issue of policy
1.121/08/2020Definition of ‘personnel’ updated
2.026/10/2022

Definition of ‘position of trust’ added

Position of Trust section added