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2019 is to David Boies as 2017 is to Louis CK
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Depends on the type of background check being run
Generally speaking, most checks will only find current and previous employment, because your employment “status” is employed, and HIPAA prevents further release of details
As a rule of thumb you really don’t want an employer to find out anything material they don’t know. But usually gardening leave is when you’re between two jobs, so have you accepted a new job already and are applying for a third one?
While you’re on garden leave (or notice period if your company doesn’t make you work it), you are technically still employed by your first employer. Assuming you’re going to another similar industry/finance shop, your new employer will expect you to be on garden leave as it’s fairly standard legal practise in the industry. The background check is just to make sure you were employed when you said you were but won’t distinguish garden leave. Though in theory you really shouldn’t quit your job until you’ve signed and passed all the checks at your new employer so you wouldn’t start garden leave until after the background check is complete anyway……