STSWR is committed to taking every reasonable step to protect the safety of the pupils transported.

The expectations of Student Transportation Services of Waterloo Region for the implementation of the Criminal Record Check (CRC) legislation, as identified in Ontario Regulation 521/01 – Collection of Personal Information for Service Providers, are outlined in this document.


1. Criminal Background Check (CBC) is the generic term covering both Criminal Record Checks and Police Record Checks (including Vulnerable Sector Screening).

2. Criminal Record Check means a document concerning an individual that was prepared by a police force or service using data on the Canadian Police Information Centre (CPIC) database not older than three (3) months before the day the Service Provider collects the document that contains information concerning the individual’s personal criminal history.

3. Offence Declaration means written declaration signed (includes electronic signature) by an individual listing all of the individual’s convictions for offences under the Criminal Code of Canada up to the date of the declaration:

  • That is not included in the Criminal Record Check collected by the employer, or in previous offence declarations, for which a pardon under Section 4.1 of the Criminal Records Act has not been issued or granted.

4. Personal Criminal History means information on criminal offences of which the individual has been convicted under the Criminal Records Act and for which a pardon under Section 4.1 of the Criminal Records Act has not been issued or granted to the individual.

5. Police Record Check for Service with the Vulnerable Sector means a complete check of police records. It includes a Criminal Record Check, including convictions for which a pardon has been granted involving vulnerable persons. It also includes a check of local police records.

6. Service Provider means an individual who is not an employee of STSWR or the School Boards and who comes into direct contact with students on a regular basis while transporting or at a school site of the Board Members in the normal course of:

  1. providing goods or services under contract with STSWR or the Board Members;
  2. a person who provides goods or services under contract with STSWR or the Board Members, or;
  3. providing services to a person who provides goods or services under contract with STSWR or the Board Members.

Collection of Criminal Reference Checks

Service Providers:

New Employees: Within 2 weeks of commencing duties, all new employees must submit a recent (not older than 3 months) Police Record Check, including a vulnerable sector screening, to their Manager. The submission of this CRC is a condition of to provide service to STSWR. A CRC that indicates outstanding charges or convictions may be ground for ineligibility to provide service to STSWR.

If, due to a backlog by the CBC provider, employees are unable to meet the 2-week deadline, they will be required to provide a receipt from the CBC provider indicating that they have started the process.

Failure to provide a CBC that includes a vulnerable sector screen, or a receipt, within the 2-week time limit will result in ineligibility to provide service to STSWR.

The specific requirements for this check will be outlined in the Service Agreement with the Service Providers.

If the CBC indicates outstanding charges or prior convictions which indicate the applicant poses a threat to students or jeopardizes the reputation of STSWR or Board Members, the General Manager is authorized to restrict or prohibit the person from providing a service to STSWR.

Adjudication Process

A Criminal Background Check may show a criminal conviction. When this situation arises, it will be adjudicated by the General Manager, STSWR. Any situation that may require action by STSWR will be dealt with by the General Manager. Possible consequences may include withdrawal from providing services to STSWR.

The following factors will be considered in the adjudication process:

a. length of time since the offence(s) occurred;
b. the nature of the offence(s);
c. did the offence(s) involve children;
d. employment history;
e. employee’s attitude towards the offence(s);
f. treatment, counseling, or other services received since the conviction(s);
g. likelihood offence(s) will be repeated;
h. relevance of the offence to the employment duties of the employee.

Yearly Offence Declarations

By September 1 of each year, every Service Provider must collect from their employees an Offence Declaration. This requirement is in addition to STSWR’s on-going expectation that if an employee of a Service Provider is convicted of an offence involving children, or any other offence relevant to the employment duties of the employee, then the Service Provider will immediately advise the General Manager.

The Offence Declaration is to be completed by each employee who comes in direct contact with students. The adjudication of the Offence Declaration will be done in a manner consistent with the process outlined for CBC Adjudication.

An employee who fails to provide an Offence Declaration will be ineligible to provide service to STSWR.

Storage of Criminal Record Checks and Offence Declarations

The information collected pursuant to this procedure shall be maintained and secured in accordance with established procedures, but must be available for review by STSWR.