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DCW76-Disclosure and Barring Service (DBS) Checks Policy

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Registration Number: {{org_field_registration_no}}

Disclosure and Barring Service (DBS) Checks Policy

1. Introduction

At {{org_field_name}}, we are committed to ensuring that the people we employ to deliver care are suitable, trustworthy, and safe to work with vulnerable individuals. We recognise that as a domiciliary care provider in Wales, we have a duty of care to protect service users from harm, neglect, or exploitation. One of the most important ways we do this is by undertaking thorough vetting and pre-employment checks, including obtaining appropriate Disclosure and Barring Service (DBS) checks for all staff and volunteers engaged in regulated activity.

The DBS checking process helps us identify whether a prospective or current employee has any criminal convictions, cautions, reprimands, or warnings that may impact their ability to provide safe and effective care. It also allows us to check if an individual is barred from working with adults in regulated activities, as defined under the Safeguarding Vulnerable Groups Act 2006 (as amended) and the Regulation and Inspection of Social Care (Wales) Act 2016.

This policy sets out how {{org_field_name}} requests, manages, and reviews DBS checks to maintain a safe workforce while ensuring compliance with legislation and guidance from Care Inspectorate Wales (CIW), Social Care Wales, and the Disclosure and Barring Service.

2. Purpose of the Policy

The purpose of this policy is to:

3. Scope

This policy applies to all employees of {{org_field_name}}, including care workers, managers, administrative staff, and any volunteers or contractors who may have direct or indirect contact with service users. It also applies during recruitment, throughout employment, and when changes in role or responsibilities occur.

4. Legal and Regulatory Framework

This policy is underpinned by the following legislation, regulations and guidance (as amended from time to time):

5. Levels of DBS Check Required

All care staff engaged in regulated activity will be required to have an Enhanced DBS Check with Adults’ Barred List information. This is the highest level of check available and provides details of both spent and unspent convictions, cautions, reprimands, and information held by local police, as well as confirmation of whether the individual is barred from working with adults.

For roles that do not involve regulated activity but may still bring staff into contact with sensitive information or individuals (for example, administrative staff handling care records), the appropriate level of DBS check will be determined by the Registered Manager.

6. Pre-Employment Checks

Before any staff member begins work with {{org_field_name}}, a DBS check must be carried out. No employee, volunteer, agency worker or contractor will be permitted to undertake regulated activity or work unsupervised with service users until a satisfactory DBS outcome (or Update Service status check outcome, where applicable) is confirmed and the Schedule 1 recruitment checks above have been completed.

Where exceptional circumstances mean a person starts before the DBS outcome is received, we will complete and record a documented risk assessment, restrict duties to supervised/shadowing only, and ensure they are never allocated as a lone worker or placed in a position of personal care responsibility.

Schedule 1 safer recruitment evidence (must be obtained and retained for CIW inspection)

In addition to the DBS process, and in line with Regulation 35 and Schedule 1, we will obtain, verify and retain the following for each person working in the service (employees, volunteers, agency staff and contractors as applicable):

  1. Proof of identity including a recent photograph.
  2. Where applicable, a valid criminal record certificate.
  3. Where applicable, a valid enhanced criminal record certificate including suitability information (Adults’ Barred List where required).
  4. Two written references, including a reference from the last employer (where one exists).
  5. Where the person has previously worked with children or vulnerable adults, verification (so far as reasonably practicable) of the reason their employment/position ended.
  6. Documentary evidence of any relevant qualification.
  7. Where relevant, documentary evidence of registration with Social Care Wales.
  8. A full employment history with a satisfactory written explanation of any gaps.
  9. Evidence of satisfactory linguistic ability for providing care and support to the individuals served.
  10. Details of registration with or membership of any professional body.
    These records will be held in the staff recruitment file and made available to CIW on request/inspection.

Recruitment decisions will take into account the DBS result, the relevance of any convictions, the role applied for, and safeguarding risks. Having a criminal record will not automatically prevent employment, but any information disclosed will be considered carefully, fairly, and in line with the Rehabilitation of Offenders Act.

7. Renewal and Ongoing Checks

DBS checks are not treated as a one-off requirement. In line with Regulation 35 and Schedule 1:

8. Positive Disclosures

If a DBS check reveals information, the Registered Manager will conduct a risk assessment to decide whether the individual can be safely employed. Factors considered will include:

Where a disclosure raises safeguarding concerns, employment will not be offered or may be ended. Where there are concerns that a person working at the service has abused or caused harm to an individual, or placed an individual at risk of abuse or harm, {{org_field_name}} will notify the DBS and any relevant professional registration body without delay.

{{org_field_name}} also recognises the legal duty under the Safeguarding Vulnerable Groups Act 2006 to refer a staff member or volunteer to the DBS where they are removed from working at the service (or resign before they could be dismissed) because they have harmed, or are considered to pose a risk of harm to, a vulnerable adult.

Where required, we will also make any relevant notifications and safeguarding referrals in line with our safeguarding policy and CIW notification requirements.

9. Confidentiality and Data Protection

All information provided through DBS checks will be treated as strictly confidential. {{org_field_name}} will comply with GDPR and the DBS Code of Practice by ensuring that:

DBS handling, record content and retention

We will handle disclosure information in line with the DBS Code of Practice and data protection law. Access to DBS information will be restricted to authorised staff on a strict need-to-know basis. We will normally record only the information required to evidence safer recruitment and compliance (for example: level/type of check, workforce, barred list check requested, certificate number, certificate issue date, decision made, date(s) of Update Service status checks and outcome).
Any copies/images of DBS certificates (if temporarily held) will be stored securely, separated from general personnel records where possible, and destroyed securely once no longer required for the recruitment/decision process.

10. Record Keeping and CIW Evidence

{{org_field_name}} will maintain a recruitment and compliance record for every employee, volunteer, agency worker and relevant contractor that demonstrates completion of the Schedule 1 checks.

DBS evidence will include (as a minimum): DBS level/type requested, Adults’ Barred List check where required, certificate number, issue date, recruitment decision/risk assessment outcome, and—where the Update Service is used—the date and outcome of the pre-employment status check and the annual status checks thereafter.

Agency staff: where agency staff are used, we will obtain written confirmation and/or a checklist from the agency demonstrating completion of equivalent checks and we will retain this evidence for CIW inspection.

11. Roles and Responsibilities

12. Policy Monitoring and Review

This policy will be reviewed annually, or sooner if there are changes to legislation, regulation, or guidance. Compliance will be monitored through internal audits, recruitment file checks, and CIW inspections.

By maintaining robust DBS checking procedures, {{org_field_name}} demonstrates its commitment to safeguarding, to regulatory compliance, and above all, to protecting the people who rely on our care services.

Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.

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