Even in the US, convictions can be expunged or sealed. The requirements vary by jurisdiction. (I think it's especially common for young offenders.)
For instance, it's common for local news companies to report arrests & mugshots on their websites. I'm assuming there are similar aggregators for arrests and convictions that span larger areas than a single news company, and these are the same people that service background checks.
What obligation(if any) do they have to respect the fact that a conviction has been expunged or sealed by the courts?