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Employee DBS Reporting Policy

1. Introduction and Purpose

{{org_field_name}} is committed to ensuring the safety and well-being of all service users by maintaining a robust system for Disclosure and Barring Service (DBS) checks and reporting. This policy outlines the procedures for conducting, monitoring, and reporting DBS checks for employees, ensuring compliance with the Health and Social Care Act 2008, CQC regulations, and the Safeguarding Vulnerable Groups Act 2006.

2. Scope of the Policy

This policy applies to all employees, volunteers, contractors, and agency staff engaged in providing care services. It covers:

• Initial DBS checks during recruitment.
• Ongoing monitoring and rechecks.
• Reporting concerns and updating DBS status.

3. Initial DBS Checks During Recruitment

To ensure only suitable individuals are employed, the following steps are undertaken:

• Pre-Employment Screening: All prospective employees must undergo an enhanced DBS check with a barred list check for adults before commencing work.
• Identity Verification: Staff must provide original identification documents and proof of address in line with DBS guidelines.
• Conditional Employment: Candidates may only commence work provisionally while awaiting DBS results if risk assessments and supervision measures are in place.
• Decision Making: Any disclosed information is reviewed by the recruitment panel to assess suitability, ensuring fair consideration under the Rehabilitation of Offenders Act 1974.

4. Ongoing Monitoring and Rechecks

DBS checks are not a one-time process. Our approach includes:

• Annual Self-Declaration: All employees must complete an annual self-declaration form confirming any changes to their criminal record status.
• Rechecks: Enhanced DBS checks are renewed every three years, or earlier if concerns arise.
• DBS Update Service: Employees are encouraged to register with the DBS Update Service to facilitate real-time monitoring of their DBS status.
• Spot Checks: Random audits are conducted to ensure compliance with DBS requirements.

5. Reporting DBS Concerns

Any concerns regarding an employee’s DBS status or behaviour must be addressed promptly to maintain the safety and well-being of service users. Our domiciliary care company has established clear procedures for reporting, investigating, and resolving DBS-related concerns, ensuring compliance with safeguarding requirements.

• Internal Reporting:
  • Staff must report any new convictions, cautions, reprimands, or investigations immediately to their line manager or the HR department. This includes incidents occurring both within and outside of the workplace.
  • Employees are reminded of their contractual obligation to disclose any changes to their criminal record status as part of their employment terms.
  • Line managers will document the report, ensuring confidentiality while initiating the appropriate follow-up actions.
• Risk Assessment:
  • Upon receiving information about a DBS concern, an immediate risk assessment is conducted by the safeguarding lead and HR team.
  • The risk assessment considers the nature and severity of the offence, its relevance to the employee’s role, and the potential risk to service users.
  • During the investigation, the employee may be suspended with pay or assigned to non-care duties if the concern poses an immediate risk.
  • The outcome of the risk assessment determines whether the employee can continue working while the issue is under investigation.
• DBS Referral:
  • If an employee poses a safeguarding risk to vulnerable adults, the organisation is legally required to make a referral to the Disclosure and Barring Service (DBS).
  • A referral can be made here: www.gov.uk/guidance/making-barring-referrals-to-the-dbs
  • A DBS referral is submitted when an employee is dismissed, removed from regulated activity, or resigns while under investigation for conduct that may harm vulnerable individuals.
  • The referral includes comprehensive details, such as incident reports, risk assessments, and investigation outcomes, ensuring that the DBS can make an informed decision.
• CQC Notification:
  • If the DBS concern affects the safety and welfare of service users, the Care Quality Commission (CQC) is notified without delay, in line with Regulation 18 of the Health and Social Care Act 2008.
  • The CQC notification includes details of the incident, actions taken by the organisation, and the risk mitigation measures implemented to protect service users.
  • The registered manager ensures that the notification process is completed promptly and that documentation is retained for auditing purposes.

Follow-Up Actions:

• Following the resolution of the DBS concern, a formal review is conducted to identify lessons learned and areas for process improvement.
• The employee’s ongoing suitability for their role is reassessed, and any necessary adjustments to their duties or supervision are implemented.
• If the employee is cleared of the concern, documentation is updated, and the individual is reinstated to their full duties.

6. Confidentiality and Data Protection

All DBS-related information is handled with strict confidentiality:

• Secure Storage: DBS certificates and related documents are stored securely and accessed only by authorised personnel.
• GDPR Compliance: Information is processed lawfully, fairly, and transparently, following the General Data Protection Regulation (GDPR).
• Retention: DBS certificates are not retained beyond six months after recruitment decisions, though the outcome is recorded.

7. Employee Responsibilities

Employees must:

• Disclose any criminal convictions, cautions, or investigations immediately.
• Participate in annual self-declarations and rechecks.
• Register for the DBS Update Service where possible.

8. Management Responsibilities

Management ensures:

• All new hires complete enhanced DBS checks before starting work.
• Regular monitoring and timely rechecks.
• Swift action if concerns arise, including risk assessments and reporting.

9. Training and Awareness

All staff receive training on:

• The importance of DBS checks in safeguarding.
• How to report concerns about their own or a colleague’s DBS status.
• Confidentiality and data protection requirements.

10. Monitoring and Audit

To maintain compliance and effectiveness:

• Regular audits of DBS records are conducted.
• Non-compliance is addressed through disciplinary procedures.
• Trends and patterns are reviewed to improve the process.

11. Safeguarding and Escalation

If a DBS check reveals a concern, the safeguarding lead initiates an immediate review, including:

• Conducting a risk assessment.
• Referring to the DBS if the individual poses a safeguarding risk.
• Notifying CQC if the issue affects service user safety.

12. Conclusion

This policy ensures that only fit and proper persons are employed, safeguarding vulnerable service users and maintaining trust in our care provision. Regular reviews, clear reporting channels, and ongoing training underpin our commitment to safe recruitment and employment practices.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
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