DBS & Update Service Policy
1. Purpose
This policy sets out Class People's approach to Disclosure and Barring Service (DBS) checks and the DBS Update Service. It is designed to support safer recruitment, safeguard children and vulnerable adults, comply with applicable legislation and satisfy REC education audit requirements.
2. Scope
This policy applies to all recruitment consultants, compliance staff, managers and directors involved in the recruitment, vetting and placement of work-seekers into education settings.
3. Legal Framework
This policy is informed by the Police Act 1997, Safeguarding Vulnerable Groups Act 2006, Rehabilitation of Offenders Act 1974 (Exceptions), UK GDPR, Data Protection Act 2018 and Keeping Children Safe in Education (as updated).
4. DBS Checks
An Enhanced DBS check is required for workers placed into regulated activity or where required by law or client requirements. Class People undertakes and accepts child workforce Barred List checks only. DBS checks are normally initiated during the registration and compliance process before a worker is made available for placement.
5. Existing DBS Certificates
Where a work-seeker presents an Enhanced DBS certificate and is subscribed to the DBS Update Service, Class People will inspect the original physical certificate before carrying out an online Status Check. Video inspection of the certificate is not acceptable. Where the worker is not subscribed to the DBS Update Service, a new Enhanced DBS check will ordinarily be obtained before placement.
6. DBS Update Service
Written consent will be obtained from the worker before conducting a Status Check and retained on the worker's Salesforce candidate record. The consultant will inspect the original physical certificate and conduct the initial online Status Check. Status Checks will be carried out at least annually or more frequently where required by legislation, safeguarding guidance or client requirements. Each check and its outcome will be recorded in the Notes and Attachments section of the worker's candidate card in Salesforce.
7. Repeat Checks During Long-Term Placements
DBS certificates do not have a formal expiry date. Class People may nevertheless require a new Enhanced DBS check or repeat check in accordance with its safeguarding standards, client requirements or internal compliance arrangements.
Where a repeat check becomes due while a worker is already in a long-term placement, the worker may continue in that existing placement only where the setting has been notified; a new Enhanced DBS application has been submitted and is being processed; the setting has completed and returned a written risk assessment; continuation has been approved by Class People; and no information suggests an increased safeguarding risk. This exception will not apply where an Update Service check indicates that new information exists, a safeguarding concern has arisen, the worker is or may be barred, or the setting does not agree to the worker continuing.
8. Positive Disclosures
Where an Enhanced DBS certificate contains disclosures, the matter will be referred to the Compliance Team and relevant manager for risk assessment. Where appropriate and lawful, and where required by the client or safeguarding obligations, a copy of the DBS certificate will be securely provided to the school before placement. Decisions will take account of the nature of the disclosure, its relevance to the role, safeguarding guidance and client requirements.
9. Worker Becomes Unsuitable
If information is received during an assignment indicating that a worker may be unsuitable, the consultant must immediately notify their manager and the Compliance Team. Placement may be suspended or terminated pending investigation. Relevant clients will be informed where appropriate and safeguarding obligations will take priority.
10. Record Keeping
DBS certificates and related documentation, Update Service checks, worker consent and compliance decisions will be retained in the Notes and Attachments section of the relevant candidate card in Salesforce, which is Class People's approved secure storage location for candidate documentation. Consultants, compliance staff and managers with individual Salesforce accounts are authorised to access candidate records where reasonably required for their recruitment, safeguarding, placement, compliance or management duties. Information must not be accessed, copied, downloaded, disclosed or used except where reasonably necessary and authorised for those legitimate purposes. Records will be handled and retained in accordance with the Data Protection Policy, Data Retention Policy and DBS Code of Practice.
11. Responsibilities
Consultants are responsible for identifying DBS requirements, inspecting original DBS certificates, obtaining worker consent, conducting initial Update Service checks and recording the relevant documentation and outcomes on the worker's Salesforce candidate record. Consultants must ensure that workers are not placed until compliance is complete, subject only to the limited long-term placement process in section 7. The Compliance Team is responsible for oversight, monitoring records, coordinating repeat checks and dealing with matters requiring escalation. Managers are responsible for oversight and ensuring this policy is followed.
12. Monitoring and Audit
Compliance with this policy will be monitored through periodic file reviews and internal audits. Any non-compliance will be investigated and corrective action taken.
13. Review
This policy will be reviewed annually or sooner if legislation, DBS guidance, REC guidance or business practices change.