Procedures for Verifying and Documenting Background Checks
Jukka 14.9.2026
Overview
While the legal obligation to require a criminal background extract (utdrag ur belastningsregistret) is well established under Swedish law, the practical administration of this requirement is equally critical. Schools must not only request the extract but also verify its authenticity, document the review process, and store records in compliance with data protection law. This topic provides educational institutions with a structured, procedural framework for managing background checks in a legally defensible and operationally efficient manner.
Step 1: Identifying Positions Subject to Background Checks
Before initiating any verification process, administrative staff must confirm whether the position in question falls under the scope of mandatory background checks. This obligation generally applies to:
- Teachers, teaching assistants, and pedagogical staff
- School leaders and administrators with regular student contact
- Support staff, including counselors, health personnel, and librarians
- Temporary, substitute, and practicum-placed personnel who will have direct, unsupervised contact with students
Practical Note: Even short-term or part-time engagements typically trigger this requirement if the role involves direct contact with minors. Schools should maintain a written policy clarifying which roles require checks to avoid inconsistent application.
Step 2: Requesting the Extract from the Applicant
The background check extract is issued directly to the individual by the Swedish Police Authority (Polismyndigheten), not to the employer. Schools must therefore:
- Inform the applicant in writing that a background check extract is a mandatory condition of employment.
- Direct the applicant to request the appropriate extract type (school-specific extract, utdrag för arbete inom skola eller förskola) from the Swedish Police Authority.
- Set a clear deadline for submission of the extract, typically prior to the first day of employment or the signing of a formal contract.
Important Compliance Point: The employer must never accept a general-purpose extract as a substitute; only the extract specifically designated for school or preschool employment purposes satisfies the legal requirement, as it is calibrated to disclose relevant offense categories.
Step 3: Verifying Authenticity of the Extract
Given the sensitivity of the document and potential for falsification, schools should implement a verification protocol:
- Physical Document Review: The extract must be presented in its original, sealed, or officially issued form. Photocopies or digital scans without proper certification should not be accepted as the sole basis for verification.
- Issue Date Check: Confirm the extract was issued within a reasonable timeframe (commonly interpreted as no older than one year) to ensure currency of information.
- Cross-Reference Applicant Identity: Verify that the name, date of birth, and other identifying details on the extract match the applicant’s official identification documents (e.g., passport, national ID card).
- Designated Reviewer: Assign a specific, trained staff member—typically a school leader, HR representative, or principal—to conduct the review, ensuring consistency and accountability.
Step 4: Documenting the Review Process
Proper documentation protects the institution in the event of future disputes, audits, or investigations. Schools should maintain records that include:
- Date of Review: When the extract was physically examined.
- Reviewer Identity: Name and role of the staff member who conducted the verification.
- Outcome of Review: A brief notation confirming the extract was clear, or describing any disclosed offenses and the subsequent decision-making process.
- Decision Rationale: If an applicant’s extract disclosed a criminal record, documentation should reflect the institution’s risk assessment and the justification for either proceeding with or declining employment.
Recommended Practice: Use a standardized internal form or checklist for this purpose, ensuring uniform documentation across all hiring decisions.
Step 5: Storage and Retention of Records
Given that background check extracts contain highly sensitive personal data, schools must handle storage in strict accordance with the General Data Protection Regulation (GDPR) and Swedish data protection principles:
- Do Not Retain the Original Extract: Swedish practice strongly discourages schools from photocopying or retaining the actual extract document. Once reviewed, the extract should typically be returned to the applicant or securely destroyed.
- Retain Only the Confirmation Record: Instead of storing the sensitive document itself, schools should retain only the internal documentation confirming that the review occurred (i.e., the record created in Step 4).
- Secure Storage of Confirmation Records: These internal records should be stored in a secure, access-controlled personnel file—whether physical or digital—accessible only to authorized HR or administrative personnel.
- Retention Period: Retain confirmation records for the duration of the individual’s employment, plus any additional period required under the institution’s internal records retention policy or municipal archival requirements.
Step 6: Handling Disclosed Offenses
If an extract reveals a criminal record, the school must undertake a structured evaluation rather than an automatic exclusion or automatic approval:
- Assess Relevance: Determine whether the disclosed offense bears a reasonable relationship to the risks associated with working with children (e.g., offenses involving violence, sexual crimes, or child endangerment).
- Consult Legal or HR Guidance: Complex cases should be escalated to municipal legal counsel or HR specialists familiar with employment law and child protection standards.
- Document the Decision: Regardless of outcome, the rationale for the final hiring decision must be documented thoroughly to demonstrate due diligence.
Step 7: Establishing Recurring Review Cycles
Because background checks reflect a point-in-time status, schools should consider institutional policies for periodic re-verification, particularly for long-tenured staff, to ensure continued compliance and safeguarding integrity. While Swedish law does not universally mandate periodic re-checks for existing employees, many municipalities and school boards adopt internal policies requiring renewed extracts every several years or upon role changes involving increased student contact.
Summary Checklist for Administrative Staff
| Step | Action | Responsible Party |
|---|---|---|
| 1 | Confirm position requires background check | HR/Administration |
| 2 | Request applicant obtain school-specific extract | HR/Administration |
| 3 | Verify authenticity and applicant identity | Designated Reviewer |
| 4 | Document review outcome and decision | Designated Reviewer |
| 5 | Securely store confirmation record; return/destroy original | HR/Administration |
| 6 | Evaluate any disclosed offenses with documented rationale | School Leadership/Legal Counsel |
| 7 | Schedule periodic re-verification per institutional policy | HR/Administration |
By adhering to this structured procedure, educational institutions ensure full compliance with Swedish legal requirements while maintaining respect for applicant privacy and safeguarding the integrity of the hiring process.
