Catch22 uses the Disclosure and Barring Service (DBS) to assess the suitability of individuals to work with children and vulnerable adults within the Catch22 Group. We are required by the DBS Code of Practice to have a written policy that is supported by a procedure for the use of disclosures. This policy must be made available to all applicants subject to the DBS checks process.
All those involved in the recruitment process, either as recruiting manager, interviewer or administrative support are affected by this policy.
It is the responsibility of Line Managers to ensure that they and their staff understand the policy, their accountability and supporting procedures and are able to work with them in practice.
Catch22 uses the DBS checks service to assess the suitability of individuals to work with children and vulnerable adults within the Catch22 Group. In doing so, we undertake to comply with the DBS Code of Practice.
In using DBS checks, we undertake not to discriminate unfairly against any person who is the subject of a DBS check on the basis of a conviction or any other information revealed. However, the safety of our young people, and vulnerable adults will always be paramount.
Catch22 is committed to the fair treatment of its staff, potential staff, sessional workers, volunteers, young people and vulnerable adults, regardless of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, sexual orientation, responsibilities for dependants, or offending background. We have a written policy on the recruitment of ex-offenders which is made available to all DBS check applicants at the outset of the recruitment process.
We actively promote equality of opportunity based on talent, skills and potential, and welcome applications from a wide range of candidates, including those with criminal records. As an organisation working largely with under supported and often vulnerable young people or vulnerable adults, we have a special responsibility to ensure that our staff, sessional workers and volunteers are safe to work with our young people or vulnerable adults.
Types of DBS check
There are four types of Disclosure and Barring Service (DBS) check:
- Basic disclosure: Shows details of unspent convictions only.
- Standard disclosure: Shows details of spent convictions, unspent convictions and cautions that have not been filtered.
- Enhanced disclosure: Shows details of spent convictions, unspent convictions and cautions that have not been filtered. Includes a check of local police records.
- Enhanced disclosure with barred lists check: Shows details of spent convictions, unspent convictions and cautions that have not been filtered. Includes a check of local police records and the barred lists held by the DBS.
Which posts require a DBS check?
Front line workers
The majority of our people who work in our Operations Hubs are likely to require an enhanced disclosure check. In addition those working in regulated activity will require a barred list check.
The requirement to carry out DBS checks applies to all posts in these areas, whether permanent, fixed term or temporary, sessional or volunteer, manager or practitioner.
Catch22 further requires that workers in our Schools and Colleges, Young People and Family Services, Lighthouse and Justice services register with the Government Update Service and consent to us performing regular status checks.
Corporate and administrative staff
Administrative and support workers (including volunteers) based at service locations will be subject to a standard disclosure check unless, in view of the level of contact with young people or vulnerable adults, they meet the requirement for an enhanced disclosure check.
Other support staff, based in Corporate Services will not normally require a DBS Check, except where contact with young people or vulnerable adults is part of their role, in which case either a standard disclosure check or an enhanced disclosure check will be required.
Agency staff and student placements
Where agency staff or student on placements are engaged by services, the Hiring / Service Manager is responsible for ensuring that the agency or university has obtained a satisfactory DBS Check certificate at the appropriate level. DBS clearances for agency staff or student placements are only acceptable where the supplying organisation confirms in writing that:
- The person concerned has a current (less than three years old) DBS check via the agency or university acting as a Registered Body or applying via a Registered Umbrella Body; and
- the person has worked continuously for them since the time of the original check (aside from short periods for planned annual leave); and
- the check indicated they were suitable for the work proposed and that the level of clearance (e.g. standard, enhanced), and its currency (i.e. less than 3 years old), is in accordance with that required by this policy.
If the agency worker or student has a conviction, then the agency or university must supply the risk assessment completed at the time of engagement. This will be reviewed by the Hiring / Service Manager in consultation with their People Partner and the Head of Safeguarding and signed off by the Hub Director and the Head of Safeguarding. A copy should be forwarded to People Services for our records.
Where this is not supplied, the Hiring / Service Manager must seek a satisfactory response as to why there is not a risk assessment in place. If the agency worker / student placement is to continue, then the Hiring / Service Manager should complete a risk assessment in consultation with their People Partner and the Head of Safeguarding. The risk assessment should be signed off by the Hub Director and the Head of Safeguarding and forwarded to People Services for our records.
Where evidence of a satisfactory and current DBS check cannot be obtained then the agency worker / student placement cannot proceed.
It is the responsibility of the Hiring / Service Manager to ensure that agency staff and students with DBS checks nearing the end of their three-year currency, are re-checked in line with Catch22’s policy at the appropriate time.
Offer of employment
An offer of employment for a post involving work with children or vulnerable adults which is exempt from the Rehabilitation of Offenders Act 1974 will be conditional on the job applicant satisfying the organisation’s usual requirements for employment (see Catch22’s Recruitment Policy for further details).
In addition, the offer of employment will be conditional on satisfactory completion of a DBS check at the appropriate level. Where the job applicant refuses to agree to an application to the DBS or a DBS check is completed but the job applicant refuses to allow the organisation to see the DBS certificate, they will be treated as not having satisfactorily completed the DBS check and the conditional offer of employment will be withdrawn.
No job applicant will be permitted to commence employment with Catch22 until all specified conditions are satisfied.
In very exceptional circumstances, the Hub Director may authorise a worker taking up their role in advance of a satisfactory DBS Check, providing the following conditions are met:
- all other pre-employment checks have been completed to a satisfactory level;
- a properly completed DBS application has been submitted through the online system;
- arrangements are put in place to ensure that the worker is not given or able to arrange unsupervised access to young people or vulnerable adults; and
- it is made clear to the prospective worker that their appointment is subject to a satisfactory outcome to the DBS process and will be terminated if this is not met.
The Hiring / Service Manager should complete a risk assessment in consultation with their People Partner and the Head of Safeguarding. The risk assessment should be signed off by the Hub Director and the Head of Safeguarding and forwarded to People Services for our records.
Existence of a Criminal Record
Where a criminal record is disclosed, Catch22 will decide whether it represents a risk to young people or vulnerable adults and will make a decision on the applicant’s potential for employment accordingly. The applicant must show the recruiting manager the original version of the DBS certificate when requested to do so.
Having a criminal record will not necessarily bar applicants from working with us. This will depend on the nature of the position and the circumstances and background of the offences. A risk assessment should be completed by the Hiring / Service Manager in consultation with their People Partner and the Head of Safeguarding. The risk assessment should be signed off by the Hub Director and the Head of Safeguarding and forwarded to People Services for our records.
The Hub Director has the ultimate responsibility of deciding whether the recruitment / appointment process should be halted at this point and the conditional offer of employment withdrawn.
Where a service works with a partner organisation whose DBS policy carries greater restrictions, Catch22 will meet the requirements of that policy. It is the responsibility of the Hiring / Service Manager to ensure that staff employed by partner organisations, but working under Catch22 management, have a current DBS Check certificate that is consistent with Catch22 policy for the nature of work being undertaken.
Changes to Status
It is the responsibility of employees and volunteers to notify their Line Manager immediately, or as soon as is reasonably practicable if they are subject to any police enquires, prosecutions or pending prosecutions, convictions, charged with, or cautioned in relation to, any criminal offence during their work with Catch22. We will then apply for a new DBS check.
Employees and volunteers must also supply a copy of their DBS certificate when requested to do so.
Failure to disclose such information or to supply on request an original DBS certificate may result in action being taken against the employee under Catch22’s Disciplinary Policy, which could lead to dismissal or in the case of volunteers, termination of their engagement.
Renewal and Update Service
Catch22 requires that workers in our Schools and Colleges, Young People and Family Services, Lighthouse and Justice services register with the Government Update Service and consent to us performing regular status checks.
The employee must register with the Government Update Service within 30 days of the ‘date of issue’ displayed on the certificate, otherwise a new DBS check will have to be completed. Failure to register within 30 days may result in action being taken against the employee under Catch22’s Disciplinary Policy, which could lead to dismissal or in the case of volunteers, termination of their engagement.
There is a fee payable which the candidate can then claim back through expenses once they have started their role.
The subscription must be renewed annually. Failure to renew the annual subscription may result in action being taken against the employee under Catch22’s Disciplinary Policy, which could lead to dismissal or in the case of volunteers, termination of their engagement.
We will re-check all other DBS checks every three years.
Portability of DBS Checks
In most cases Catch22 will not accept DBS checks carried out by previous employers and will carry out a brand new check.
However, if the individual is registered on the Government Update Service, we may consider using their existing DBS certificate only if:
- The applicant’s identity matches the details on the certificate; and
- the certificate is the right level and type for the role applied for.
In these cases, we will seek the applicant’s consent to check their status on the Government Update Service before taking a decision regarding their employment.
Accountabilities
Applicants / Employees / Volunteers are responsible for:
- Consenting to Catch22 applying for a DBS check at the appropriate level.
- Suppling on request an original DBS certificate.
- Notifying their Line Manager immediately, or as soon as is reasonably practicable, if they are subject to any police enquires, prosecutions or pending prosecutions, convictions, charged with, or cautioned in relation to, any criminal offence during their work with Catch22.
- Registering with the Government Update Service within 30 days of the ‘date of issue’ displayed on the certificate (where applicable).
- Consenting to Catch22 performing regular status checks where the employee has registered with the Government Update Service.
- Renewing their annual subscription with the Government Update Service before it expires (where applicable).
Hiring / Service Managers and Volunteer Co-ordinators are responsible for ensuring that:
- All applicants, employees and volunteers are aware of and understand this policy.
- No member of staff or volunteer takes up appointment prior to a satisfactory outcome of a DBS Check process saving only where the relevant Director has authorised such an appointment.
- Verifying an applicant’s identity and scanning a copy of the evidence to People Services to support the new starter’s DBS application.
- Viewing an applicant’s original DBS certificate and scanning a copy of the top third (details part) to People Services for our records.
- Confirming an applicant’s registration with the Government Update Service (where required) and scanning a copy of the evidence to People Services for our records.
- Requesting to see an employee’s or volunteer’s original DBS certificate where required.
- Undertaking a risk assessment where a criminal record is disclosed in consultation with their People Partner and the Head of safeguarding, which should be signed off by the Hub Director and the Head of Safeguarding, and sent to People Services for our records.
- Regularly reviewing risk assessments at prescribed intervals (or more frequently if there is a significant change in risks / activities).
- Monitoring the disclosure check renewal times for existing staff and volunteers (including those on the Government Update Service).
Hub Directors are ultimately responsible for:
- Reviewing the DBS status of all workers in their departments, reviewing and signing off risk assessments and taking such action as may be necessary to ensure that young people and vulnerable adults remain safe.
- Reviewing the DBS certificates of all current and prospective workers and volunteers where this includes criminal convictions and/or other information regarding the potential suitability of an applicant/employee or volunteer.
- In the case of applicants, signing off the Hiring / Service Manager’s risk assessment and making a determination as to whether the recruitment/appointment process should halt at that point.
- In the case of existing employees or volunteers, signing off the Line Manager / Service Manager’s risk assessment and making a recommendation whether the matter should be referred to a hearing under Catch22’s Disciplinary Policy.
Communication of the policy to potential workers
Where a DBS check is required, job descriptions and adverts (including volunteers) and any recruitment briefs will contain a statement that a DBS check will be requested in the event of an individual being offered the post/volunteering opportunity.
Catch22 are signed up to the Ban the Box initiative. As a Ban the Box employer, we have committed to fairly assessing criminal convictions; so candidates are not asked about offence history during the application process and are assessed first and foremost on the basis of their skills and suitability for a role, rather than their past mistakes. The only exception to this is within our schools and colleges, where the Keeping Children Safe in Education (KCSIE) regulations requires us to ask candidates to declare criminal convictions at shortlist stage, prior to interview.
Catch22 ensures that those involved in the recruitment process have been suitably trained to identify and assess the relevance and circumstances of offences. We always ensure that they have received appropriate guidance and training in the relevant legislation relating to the employment of ex-offenders (e.g. the Rehabilitation of Offenders Act 1974).
We ensure that an open discussion takes place on the subject of any offence either at interview (if known) or at a later stage.
Failure to reveal information that is directly relevant to the position sought is likely to lead to the withdrawal of an offer of employment or termination of employment contract.
We make every subject of a DBS check aware of the existence of the DBS Code of Practice and make a copy available on request.
We undertake to discuss any matter revealed in a check with the person seeking the position before withdrawing a conditional offer of employment or terminating an employment contract.
Breaches of the Policy
An effective DBS check process is fundamental to the safe operation of services and the maintenance of Catch22’s reputation as a provider of quality services. Breaches of this policy will therefore be viewed seriously and may result in disciplinary action up to and including dismissal.
Related policies
- Safeguarding (Protection of Children and Adults) at Risk policy
- Recruitment and Selection policy
- Code of Conduct
- Disciplinary policy
