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Registration Number: {{org_field_registration_no}}

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Employee DBS Reporting Policy

1. Purpose

The purpose of this policy is to establish clear guidelines for the Disclosure and Barring Service (DBS) checks and reporting procedures at {{org_field_name}}, ensuring that all staff members meet legal, regulatory, and safeguarding requirements. The DBS check process ensures that individuals working with vulnerable adults are suitable for their roles, maintaining the highest standards of safety, security, and compliance with Care Inspectorate Wales (CIW) regulations.

This policy ensures compliance with The Regulation and Inspection of Social Care (Wales) Act 2016, which mandates safe and lawful recruitment practices, Care Inspectorate Wales (CIW) regulations, which require service providers to ensure all staff are fit for their roles, The Safeguarding Vulnerable Groups Act 2006, which establishes DBS barring and reporting duties, The Rehabilitation of Offenders Act 1974, which governs the disclosure of spent and unspent convictions, The Data Protection Act 2018 and GDPR, ensuring that sensitive DBS information is processed lawfully, and The Disclosure and Barring Service (DBS) Code of Practice, which sets out best practices for handling DBS checks.

This policy aims to ensure that all staff members undergo appropriate DBS checks before and during employment, define clear reporting and risk assessment procedures, outline employee responsibilities for disclosing changes in criminal history, and establish a robust monitoring and renewal process for DBS compliance.

2. Scope

This policy applies to all employees, including permanent, temporary, and agency staff, volunteers, contractors, and students working within the care home, and senior management and HR personnel responsible for processing and monitoring DBS checks.

This policy covers pre-employment DBS checks and risk assessments, DBS renewal and monitoring processes, employee responsibilities in reporting changes, procedures for addressing DBS concerns, and reporting obligations to external agencies.

3. Pre-Employment DBS Checks

3.1 Who Requires a DBS Check?

All employees and volunteers must undergo an Enhanced DBS check with a barred list check before starting work. This includes: Care staff, nurses, and support workers, administrative staff with access to service user records, volunteers and students involved in direct care, and contractors with unsupervised access to service users.

3.2 When DBS Checks Must Be Conducted

DBS checks must be completed before employment commences, and no employee may start work without a valid, satisfactory DBS certificate. DBS checks must be renewed every three years for all staff. Additional DBS checks must be conducted when an employee moves into a new role requiring an enhanced DBS check.

3.3 Accepting Existing DBS Certificates

If an applicant is registered with the DBS Update Service, {{org_field_name}} will conduct an online status check rather than requiring a new application. If an existing certificate is outdated, does not meet the care home’s requirements, or has changed status, a new DBS check must be obtained.

4. Employee Responsibilities in Reporting DBS Changes

4.1 Duty to Disclose

Employees are legally required to report any new criminal convictions, cautions, or barring notifications that occur during their employment. This includes criminal convictions or cautions, inclusion on the DBS barred list, or any police investigations or pending charges that could affect their role. Failure to report changes in DBS status may result in disciplinary action, up to and including dismissal.

4.2 How to Report a DBS Change

Employees must inform their line manager or HR in writing immediately upon becoming aware of any change. They must provide full details of the conviction, caution, or barring notification and attend a confidential meeting with HR to discuss potential risks and any necessary adjustments.

5. Ongoing DBS Monitoring and Renewal

5.1 Renewal Process

DBS checks are renewed every three years to ensure continued compliance with regulatory requirements. Employees are encouraged to register with the DBS Update Service, allowing for real-time status checks. HR maintains a DBS tracking system to ensure renewals occur before expiry, with reminders issued to staff six months in advance of renewal deadlines.

5.2 Random and Additional Checks

Random DBS status checks may be conducted as part of internal safeguarding audits. Additional DBS checks may be required if an employee is under investigation for misconduct or if a safeguarding concern has been raised.

6. Managing DBS Concerns and Risk Assessments

6.1 What Happens if a DBS Check Reveals a Concern?

If a DBS check reveals a conviction, caution, or other safeguarding concern, the following process will be followed:

1. Confidential review by HR and management to assess the severity and relevance of the disclosure.
2. Risk assessment meeting with the employee to determine:
   • Whether the offence poses a risk to service users, staff, or the organisation.
   • Whether the conviction is relevant to the employee’s role and responsibilities.
   • Whether any reasonable adjustments can be made to mitigate risks.
3. Employment status decision, which may result in:
   • Continued employment with additional safeguards (e.g., increased supervision).
   • Role modification to reduce risks.
   • Employment termination if the offence presents an unacceptable safeguarding risk.

6.2 Reporting to CIW and DBS

If an employee is dismissed or removed from their role due to safeguarding concerns, {{org_field_name}} must report the case to the DBS for potential inclusion on the barred list. CIW must be notified of any serious safeguarding incidents involving DBS concerns, following statutory notification requirements.

6.3 Appeals and Employee Rights

Employees have the right to appeal decisions related to their DBS status. Appeals must be submitted in writing within five working days of the decision. An independent review panel will assess the case and determine whether the decision was fair and proportionate.

7. Managing This Policy Efficiently

7.1 Employer Responsibilities

{{org_field_name}} will ensure that all employees undergo DBS checks before starting work, maintain a secure and updated DBS records system, conduct risk assessments for DBS concerns, report safeguarding issues to CIW and DBS, and provide staff training on DBS reporting obligations.

7.2 Employee Responsibilities

Employees must complete DBS applications honestly, report any changes in their criminal history, and cooperate with renewal checks and DBS status monitoring.

8. Related Policies

This policy should be read alongside Safeguarding Adults from Abuse and Improper Treatment Policy, Recruitment, Selection, and Retention Policy, Whistleblowing (Speaking Up) Policy, Disciplinary and Grievance Policy, and Confidentiality and Data Protection (GDPR) Policy.

9. Policy Review

This policy will be reviewed annually or sooner if new legislation, CIW regulations, or operational needs require updates. Regular audits of DBS records and compliance checks will ensure ongoing effectiveness.

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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.