Nonprofits screen a population that is not employed, often unpaid, frequently working with children or vulnerable adults, and usually recruited through relationships rather than applications. Every one of those makes screening harder to run and more important to get right. The legal framework still applies, and the most common failure is assuming that because nobody is being paid, none of it does.
The FCRA does not care whether you pay them
If you obtain a consumer report about a volunteer through a consumer reporting agency, the FCRA applies. That means a standalone written disclosure, written authorisation before the report is ordered, and if you decline somebody because of what it says, a pre-adverse action notice with a copy of the report and the Summary of Your Rights, a reasonable period to respond, and a final notice. Organisations recruiting volunteers informally skip these steps more often than any other group, usually with entirely good intentions.
Screen by role, not by status
The useful distinction is not employee versus volunteer but what the role gives the person access to. A volunteer with unsupervised access to children needs more scrutiny than a paid administrator who never meets one. Write your policy around access categories: unsupervised contact with minors or vulnerable adults, handling of money, driving, and everything else. Then apply the same standard to everybody in a category regardless of whether they are staff, volunteer or contractor, which is both fairer and much easier to defend.
What to actually run
For roles with unsupervised access to minors: an identity and address trace, county criminal searches across that history, a national database sweep as a pointer, and a sex offender registry search. Add a driving record where the person transports anybody. Some states operate dedicated volunteer or childcare screening channels, sometimes fingerprint-based and sometimes at reduced cost, and a nonprofit should check whether its state does before buying commercially, because those channels can be both cheaper and more authoritative.
Writing a policy that survives contact with reality
Say which roles require screening and which do not, and why. Say what disqualifies, in terms of the relationship between an offence and the role rather than as a blanket rule. Say who decides, and make sure it is not the person who recruited the volunteer. Say how often screening is repeated, because a check done at recruitment says nothing five years later. And say how records are stored and who may see them, since a small organisation with a shared drive is the most common route to a confidentiality problem.
Questions people ask about background checks for nonprofits
Do FCRA rules apply to volunteers?
Yes, where you obtain a consumer report about them through a consumer reporting agency. The standalone disclosure, the written authorisation and the adverse action sequence all apply regardless of whether anybody is paid.
Should we screen every volunteer?
Screen by role rather than by status. Unsupervised access to minors or vulnerable adults, handling money and driving are the categories that justify it, and the same standard should apply to staff and volunteers in the same category.
Is there a cheaper route for nonprofits?
Some states operate dedicated volunteer or childcare screening channels, sometimes fingerprint-based and sometimes discounted. Check whether yours does before buying commercially, because those channels can be more authoritative as well as cheaper.
How often should volunteers be rescreened?
Set an interval in the policy rather than leaving it open. A check at recruitment says nothing years later, and for roles with access to children a periodic recheck is the norm.