and educational histories, checking references and conducting a background check on all applicants who have accepted an offer of conditional hire, and if an adverse assessment is found, to deny employment to such an applicant. Note that simply conducting a criminal background check on an applicant may not be a sufficient investigation. In Minnesota, for example, such a check was determined to be insufficient by the court in Ponticas v. K.M.S. Investments, 331 N.W.2d 907 (Minn. 1983). This will not guarantee the employer will not be held liable, but it will show that the employer used a diligent search to screen potential harassers from the workplace, and will assist the employer in demonstrating that it took reasonable care in hiring. It is important to also note that, in the United States, background checks for job applicants are subject to the Fair Credit Reporting Act (2003). If an adverse assessment is found in an employment screen, the applicant has the right to dispute the report. The majority of credible empirical research indicates that, likely due to employer concerns regarding negligent hiring liability, a criminal record has a significant negative effect on the hiring outcomes of ex-offenders. Negligent retention, supervision, and training Negligent retention occurs where a party failed to remove an employee from a position of authority or responsibility after it became apparent that the employee was in fact misusing that authority or responsibility in a way that posed a danger to others. Negligent supervision is closely related, as it occurs where a party fails to reasonably monitor or control the actions of an employee. A variation of negligent retention or supervision is negligent training, which arises where the employer's training of the employee fails to prevent the employee from engaging in the acts that injure the claimant, or fails to remediate a pattern of behaviour which leads to an injury. Suits for negligent retention often plead negligent supervision or training as an alternate theory, as the employer who knows of an employee's improper conduct should either terminate that employee, or take steps to penalise that conduct and/or train the employee not to engage in that conduct. Related doctrines Negligent entrustment Negligent entrustment arises where the entrustor is held liable for negligence because they negligently provided the entrustee with a dangerous instrument, and the entrusted party caused injury to a third party with that instrument. Where such a claim is brought