DBS check policy template

This policy sets out how [Company] uses Disclosure and Barring Service (DBS) checks: which roles require them, at what level, how often they are repeated, how disclosed information is treated, and how certificate information is stored and destroyed. It applies to employees, workers, volunteers and contractors in the roles listed in clause 2.

The level of check is determined by the role's legal eligibility, not preference. [Company] maintains a role-to-level register: [list role groups, e.g. "Care staff - enhanced with adults' barred list; Finance manager - basic; Office roles - basic or none"]. The reason each role qualifies for its level is recorded with the register. Where a role is not eligible for a standard or enhanced check, no more than a basic check is requested.

Checks are applied for when a conditional offer is accepted. Offers for roles in clause 2 are conditional on a satisfactory check at the required level. Whether and how a person may begin work before a certificate is issued is decided by [role, e.g. the Registered Manager] against sector rules, recorded in writing, and where permitted is subject to [supervision arrangements / DBS Adult First where applicable].

DBS certificates have no expiry date; [Company] re-checks roles in clause 2 every [1/2/3] years, as guided by [regulator/insurer]. [Company] [encourages/requires] staff in these roles to join the DBS Update Service within 30 days of certificate issue [and reimburses the £16 annual fee]. Where a person subscribes and gives consent, a status check replaces a new application at each renewal. [Named role] owns the renewal register and reminder dates.

[Company] assesses disclosed information fairly and individually. A conviction or caution is considered against the role: its relevance to the duties, its seriousness, how long ago it occurred, the person's circumstances since, and the pattern if more than one. Except where the law itself bars a person from a role (barring, in regulated activity), no outcome is automatic. Decisions are made by [named roles], recorded with reasons, and discussed with the candidate before being finalised.

Certificate information is seen only by those who need it to carry out their duties: [named roles]. Once a decision is made, [Company] records the check level, certificate number, issue date and outcome, and does not keep certificate information itself longer than is necessary for the decision or any dispute arising from it. Certificate information is stored securely, separately from general personnel files, and destroyed by secure means when no longer needed.

If a candidate or employee declines a check required by this policy, [Company] explains what the check is for and the consequence of refusal. For roles where a check is a legal or regulatory requirement, the role cannot be offered or continued without one; alternatives (such as redeployment to a role without the requirement) are considered where they exist.

Processing under this policy is carried out under [Company]'s privacy notice and data protection policy. This policy is owned by [named role] and reviewed [annually], including the role-to-level register, the renewal cycle and current DBS fees.