Ontario’s Police Record Checks Reform Act, 2015 (PRCRA), S.O. 2015, c. 30, prescribes three police record check types for all Ontario police services: the Criminal Record Check (CRC), the Criminal Record and Judicial Matters Check (CRJMC), and the Vulnerable Sector Check (VSC).
The Act came into force on November 1, 2018, standardizing what police services across the province can disclose and requiring the individual’s knowledge and consent before any check can be requested. This post explains what each check type discloses, who may request it, how Ontario’s legal framework governs employer use of results, and where a licensed private investigator background check fits alongside — not in place of — a PRCRA-governed police record check.
What is a police record check in Ontario
A police record check in Ontario is a consent-based disclosure of an individual’s criminal history, judicial matters, or vulnerability-related records, conducted by a local police service or authorized third-party provider under the Police Record Checks Reform Act, 2015, S.O. 2015, c. 30. The Act defines three check types — Criminal Record Check, Criminal Record and Judicial Matters Check, and Vulnerable Sector Check — each disclosing a progressively broader set of information depending on the nature of the position or purpose.
The scope of each check is set by statute. Only a local police service or an authorized third-party provider may conduct a police record check. The individual being checked has the right to receive results directly from the police service before those results are released to any employer or organization — giving the subject an opportunity to verify factual accuracy before permitting onward disclosure. Youth criminal records, even when released to the individual, are issued as a separate record and are not for sharing with a potential employer.
What law governs police record checks in Ontario
The Police Record Checks Reform Act, 2015 (PRCRA), S.O. 2015, c. 30, is the sole provincial statute governing all three prescribed check types in Ontario. It came into force November 1, 2018, after a three-year gap from Royal Assent, and standardized what police services across the province could disclose — ending a pre-2018 practice where individual services disclosed inconsistent information, including non-criminal mental health contacts.
The PRCRA expressly bars disclosure of information about whether someone was a victim or witness of a crime, or had non-criminal contact with police during a mental health crisis. This prohibition applies in Criminal Record Checks and Criminal Record and Judicial Matters Checks. Only a Vulnerable Sector Check may disclose certain non-conviction information, and only in narrowly defined circumstances governed by the Act.
A federal layer also applies to the VSC. The Criminal Records Act, R.S.C. 1985, c. C-47 governs the RCMP’s administration of the pardoned-sexual-offence notation system that distinguishes the VSC from the other two check types. Ontario and federal law work in concert: the PRCRA defines disclosure limits; the Criminal Records Act defines who may request a VSC and what the RCMP must maintain in CPIC.
The three PRCRA check types at a glance
| Check type | Abbreviation | What it discloses |
|---|---|---|
| Criminal Record Check | CRC | Applicable criminal convictions; certain Youth Criminal Justice Act findings of guilt |
| Criminal Record and Judicial Matters Check | CRJMC | Everything in a CRC, plus: absolute and conditional discharges, outstanding charges, arrest warrants, and certain judicial orders |
| Vulnerable Sector Check | VSC | Everything in a CRJMC, plus: findings of not criminally responsible on account of mental disorder; record suspensions (pardons) for sexual offences (RCMP CPIC Schedule 2 notation); non-conviction information in limited circumstances |
Source: Ontario.ca — Police Record Checks (PRCRA, S.O. 2015, c. 30)
What a Criminal Record Check discloses — and what it does not
The CRC is the baseline PRCRA check type, suitable for general employment screening where the role does not involve financial authority, fiduciary responsibility, or work with vulnerable persons. A CRC discloses the following:
- Applicable criminal convictions under the Criminal Code of Canada
- Certain findings of guilt under the Youth Criminal Justice Act, where applicable
A CRC does not disclose any of the following categories of information:
- Outstanding charges or arrest warrants
- Absolute or conditional discharges
- Findings of not criminally responsible on account of mental disorder
- Record suspensions (pardons) for sexual offences
- Non-conviction police contacts
- Any information about whether the person was a victim or witness of a crime
The Criminal Record and Judicial Matters Check (CRJMC) adds the categories a CRC omits. A CRJMC discloses everything a CRC does, plus absolute and conditional discharges, outstanding charges, arrest warrants, and certain judicial orders. The CRJMC is appropriate for roles involving financial authority, fiduciary responsibility, or access to sensitive records — where pending matters or recent discharges are directly relevant to the hiring decision.
Neither a CRC nor a CRJMC can disclose pardoned sexual offences or non-conviction information. Those categories are available only through a Vulnerable Sector Check, and only for qualifying positions.
What the Vulnerable Sector Check discloses — and who must complete it
A Vulnerable Sector Check (VSC) is the most comprehensive PRCRA check type. It discloses everything a CRJMC contains, plus three additional categories:
- Findings of not criminally responsible on account of mental disorder
- Record suspensions (pardons) for sexual offences — accessed through an RCMP CPIC notation maintained for Schedule 2 offences under the Criminal Records Act, s. 6.3(2)
- Non-conviction information in narrowly defined circumstances under the PRCRA
The pardoned-sexual-offence search is the VSC’s defining feature. Under s. 2.3 of the Criminal Records Act, a granted record suspension separates a conviction from the CPIC database — it will not appear on a CRC or CRJMC. However, for Schedule 2 sexual offences, the RCMP maintains a separate CPIC notation accessible only on a VSC requested for a qualifying position. This mechanism ensures that a granted pardon does not remove a relevant disclosure where a position of trust over children or vulnerable persons is involved.
The VSC is legally restricted to persons working or volunteering in a position of trust or authority over children or other vulnerable persons. Under Criminal Records Act, s. 6.3(3), a VSC can be requested only by an organization responsible for the well-being of a child or vulnerable person in respect of a position of trust or authority, and the person being checked must provide written consent.
The hiring organization — not the individual applicant — must initiate the VSC request. Conducting a Vulnerable Sector Check for a position that does not meet the requirements of the Criminal Records Act is an offence: s. 6.3(4) specifically prohibits unauthorized access to the VSC notation system, and s. 10 of the Act makes contraventions punishable on summary conviction.
A Vulnerable Sector Check must also be completed by the local police service directly. Authorized third-party providers cannot conduct VSCs — only the local police service holds the authority to access and disclose the CPIC notation for qualifying positions.
How Ontario police record checks are initiated and processed
An individual requesting a police record check in Ontario follows these steps through the local police service or an authorized provider:
- Determine the check type: confirm with the requesting organization which of the three PRCRA types is required for the position. An employer or organization typically specifies the check type in writing.
- Apply through the appropriate channel: most police services accept applications online, in person, or by mail. For name-based CRC and CRJMC requests, identity documents are required at submission.
- Provide consent in writing: the PRCRA’s consent model requires that the individual acknowledge and consent to the check before it is processed. A check cannot be initiated without consent.
- Receive results directly: under the PRCRA, results are released to the individual first before any result is forwarded to the requesting employer or organization. The individual then decides whether to authorize onward disclosure.
- Authorize disclosure to the requesting organization: if the individual consents to sharing the results, the police service or provider releases them to the employer or organization.
For fingerprint-based certified criminal record checks routed through the RCMP’s Canadian Criminal Real Time Identification Services (CCRTIS), the RCMP confirms that the use of fingerprints is the most accurate way to confirm a person’s identity. Name-based checks rely on self-reported identifying information and may miss records held under different name spellings or in other jurisdictions. The RCMP reports processing times of three business days or less when there is no match to a criminal record, and up to 120 business days when a possible match requires manual review.
Vulnerable Sector Checks require in-person processing by the local police service; third-party providers cannot conduct them.
When a licensed PI background check supplements a police record check
A police record check searches only police databases — it reveals what those databases contain and nothing more. A licensed private investigator background check accesses sources a police record check cannot reach: civil litigation history, corporate registry filings, professional credential verification with issuing bodies, court record reviews, and structured reference interviews.
As licensed investigators operating under Ontario’s Private Security and Investigative Services Act, 2005 (PSISA), S.O. 2005, c. 34, Discreet Investigations conducts background investigations by gathering information on a person’s character, actions, business, occupation, and corporate affiliations — drawing on publicly available court records, Ontario Business Registry filings, professional licensing databases, and structured reference interviews. These sources are beyond what a PRCRA police record check searches and complement what a police database can confirm about criminal history alone.
Licensed PIs cannot access CPIC (the Canadian Police Information Centre) directly; only police services and specifically authorized agencies hold CPIC access. For criminal record history, a licensed PI background check supplements — but does not replace — a PRCRA-governed police record check. Employers conducting senior hires, fiduciary appointments, or due diligence on positions where civil litigation history, corporate-registry associations, or credential authenticity matter should consider both in sequence. For employers deciding when a criminal background check is warranted and how to scope it, the related guide on when to run criminal background checks covers timing and decision criteria in detail.
What this means for employers and applicants in Ontario
Ontario’s Human Rights Code, R.S.O. 1990, c. H.19, s. 10(1), defines “record of offences” as covering convictions for a federal offence for which a pardon has been granted and not revoked, and convictions under any provincial enactment. Employment decisions cannot be based on a pardoned federal conviction or any provincial conviction under this ground. Unpardoned Criminal Code convictions fall outside the protected “record of offences” ground — Ontario employers may ask about and consider them, provided any refusal to hire meets a bona fide occupational requirement standard.
The Ontario Human Rights Commission recommends that background checks be requested only after a conditional offer of employment has been made, rather than at the application or interview stage. Where a check reveals adverse information, the employer must demonstrate using the Supreme Court’s three-part bona fide occupational requirement test that the criminal record has a rational connection to job performance, that the requirement is necessary, and that no accommodation can address the concern without undue hardship. Blanket policies refusing all applicants with any criminal record risk a Human Rights Code complaint.
Ontario’s background check legal framework — how the PRCRA’s three check types interact with Human Rights Code limits and federal PIPEDA consent obligations across all provinces — is covered in depth in the research post on background check laws by province in Canada, which documents when Ontario’s provincial rules govern and when federal law applies.
At Discreet Investigations, our licensed investigators are regularly engaged to supplement a police record check with a broader background investigation — particularly for senior hires, fiduciary roles, or positions where civil litigation history, corporate-registry associations, or credential authenticity matter beyond what a CPIC search reveals. We operate under PSISA 2005 and the PRCRA’s consent framework: we do not access police databases and we work in parallel with, not in place of, the police record check the employer initiates. To discuss whether a supplemental background investigation fits your hiring process, call +1 (888) 680-0036 or visit our pre-employment screening service page.
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Frequently asked questions
What are the three types of police record checks in Ontario?
What does a vulnerable sector check show in Ontario?
How long does a police record check take in Ontario?
What is the difference between a criminal record check and a judicial matters check?
Do I need a vulnerable sector check to volunteer in Ontario?
Sources
- Police Record Checks — ontario.ca
- Criminal Records Act, R.S.C. 1985, c. C-47 — laws-lois.justice.gc.ca
- Criminal Record Checks — rcmp.ca
- Processing times and fees — rcmp.ca
- Vulnerable Sector Checks — rcmp.ca
- Record of offences — OHRC
- Requesting job-related sensitive information — OHRC
- Private Security and Investigative Services Act, 2005 — ontario.ca