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Safe Recruitment and Vetting in Domiciliary Care (Children and Adults)

Recruiting staff to work in domiciliary care (providing personal care in clients’ homes or community settings) requires robust vetting and safeguarding measures. In England, extra legal and regulatory steps apply when staff will work with children and young people (0–18), compared to those working only with adults. This report outlines the key requirements and highlights additional measures for child-facing roles, drawing on relevant legislation and guidance – including the Children Act 1989/2004, Working Together to Safeguard Children, Keeping Children Safe in Education, and advice from the CQC, Ofsted, and the DBS. The goal is to inform a recruitment policy that remains compliant and covers both adult and child service users.

Legal and Regulatory Framework

Children (0–18): Key Safeguarding Legislation & Guidance

Children Act 1989 & 2004: The Children Act 1989 established the paramount importance of the child’s welfare, and the Children Act 2004 (Section 11) places a duty on organizations that work with children to safeguard and promote children’s welfare. Under Section 11, agencies (including private care providers and voluntary organizations) must ensure their services give due regard to child safetyleedsscp.org.ukleedsscp.org.uk. This includes implementing safe recruitment practices for any staff or volunteers working regularly with childrenleedsscp.org.uk. In practice, this means thoroughly vetting applicants and obtaining criminal record checks (DBS) as appropriateleedsscp.org.uk.

Working Together to Safeguard Children 2023: This statutory multi-agency guidance reinforces Section 11 duties. All organizations in contact with children should have:

• Robust safer recruitment policies, including when to obtain DBS checks.. Staff and volunteers must be carefully vetted to ensure they are suitable to work with children.
• Ongoing staff supervision and support – new hires should not work unsupervised with children until they are fully checked and deemed competent.. Regular supervision, mentoring, and safeguarding training are expected.
• Safeguarding induction and training: All new staff must receive a mandatory induction covering child protection responsibilities and procedures to follow if they have concerns about a child.. Ongoing training in safeguarding children is essential..
• Designated safeguarding lead: Providers should designate a lead person for child safeguarding who ensures policies are followed and supports staff in recognizing and responding to child protection issues...
• Culture of vigilance: Organizations must create an environment where staff feel able to raise concerns about a child’s welfare and are supported in their safeguarding role..

Keeping Children Safe in Education (KCSIE): While aimed at schools, KCSIE (latest version 2025) is relevant as it exemplifies best practice in safer recruitment. It requires thorough vetting of anyone working with children. Key principles include: obtaining an enhanced DBS check with children’s barred list for roles in regulated activity with children., verifying the candidate’s full employment history and references, and ensuring at least one interviewer is trained in safer recruitment. References must be scrutinized – schools are told not to accept generic “to whom it may concern” references and to confirm the applicant’s suitability to work with children with past employers... Any past safeguarding concerns or allegations (that were substantiated) should be factually disclosed in references to new employers.. These practices, though specific to education, underscore the high standard of diligence expected whenever recruiting for child-facing roles.

Ofsted and Childcare Regulations: Domiciliary care agencies providing personal care to children may fall under Care Quality Commission regulation (see below), but if a service is registered with Ofsted (for example, a children’s home or certain daycare services), additional rules apply. Ofsted’s regulations mirror many safe recruitment requirements. For instance, the Children’s Homes (England) Regulations 2015 mandate that providers obtain: proof of identity (with photo), an enhanced DBS certificate, two written references (one from the most recent employer), a full work history with gaps explained, and verified reasons why any previous roles with children or vulnerable adults ended. If any required information (like a reference) cannot be obtained before a new hire starts, the children’s home must document efforts made and ensure the individual is strictly supervised when working with children until all checks are completed. Ofsted inspectors will check that recruitment records demonstrate all these safeguards are in place.

Adults (18+): Key Safeguarding Legislation & Guidance

Care Act 2014: For adult social care, the Care Act 2014 and its statutory guidance require providers to take steps to prevent abuse and ensure the safety of adults with care and support needs. This includes safe recruitment practices. Providers of care to adults should ensure staff are fit to work with vulnerable people, in line with the Act’s focus on protecting adults at risk. While the Care Act doesn’t prescribe recruitment steps as explicitly as children’s legislation, it establishes responsibilities for safe care. In practice, this means similar checks – DBS vetting, references, etc. – are needed to protect vulnerable adults.

CQC Fundamental Standards (Regulation 19): Domiciliary care agencies (serving adults, children, or both) must register with the Care Quality Commission (CQC) if providing “personal care” as a regulated activity. CQC’s regulations impose safe recruitment obligations for all staff working in regulated care services. Regulation 19 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 is the “Fit and Proper Persons Employed” requirement. Its intent is to ensure providers only employ people who are fit, proper and of good character to care for service users. To comply, providers must operate robust recruitment procedures including all relevant pre-employment checks. They must also monitor staff continuously and address any concerns about a person’s fitness to practice. CQC will refuse registration or take action if a provider cannot demonstrate safe recruitment.

Regulation 19 references Schedule 3, which lists the information that must be obtained and verified before a person is employed in care. These requirements apply equally to adult and child services under CQC. In summary, no individual can be deployed to provide care unless all applicable checks and evidence are on file:

• Identity verification (with a recent photograph to prevent impersonation).
• Right to work in the UK (immigration status) and relevant professional registration if required.
• Qualifications and experience checks – proof of any credentials needed for the role.
• Full employment history – with a written explanation for any gaps in work.
• References or evidence of conduct in previous employment in health or social care. The provider must obtain satisfactory evidence of the person’s conduct in any prior roles involving health, social care or children/vulnerable adults. Typically this means getting written references from previous employers.
• Reason for leaving previous care roles: If the candidate has worked with children or vulnerable adults before, the employer must verify, so far as reasonably practicable, why that employment ended. This is an important safeguard to uncover any past misconduct or disciplinary issues – for example, was the person ever asked to leave due to harming a client. Providers may obtain this verification by directly contacting the prior employer (a phone conversation or reference letter) and recording the outcome. This check is required under both CQC and Ofsted regimes and is a key additional step when vetting anyone who has worked in a caregiving role before.
• Criminal record check (DBS): An appropriate level DBS certificate must be obtained (see next section). For care roles, this will almost always be an enhanced DBS check, and if the role involves regulated activity with adults or children, it must include a check of the relevant barred list.. The original DBS certificate should be seen and validated by the employer.

Only when all Schedule 3 information is gathered and deemed satisfactory can the person be cleared to work in a care role. These measures for adults are fundamentally similar to those for children – reflecting that both groups are vulnerable populations – but working with children brings some additional legal safeguards as detailed below.

DBS Checks and Barred List Requirements

The Disclosure and Barring Service (DBS) plays a crucial role in safe recruitment for both adult and child care services. The DBS provides criminal record checks and manages the barred lists of individuals who are legally barred from working with children and/or adults. Key points include:

• Regulated Activity: Under the Safeguarding Vulnerable Groups Act 2006 (as amended by the Protection of Freedoms Act 2012), certain roles are classified as regulated activity, which makes them eligible – and usually mandatory – for enhanced DBS checks with barred list screening. Personal care is explicitly a regulated activity for both children and adults. For children, any activity involving personal care (such as washing, dressing, toileting, or feeding a child due to age, illness or disability) is regulated activity even if done only once. Likewise, for adults, providing personal care (for example, assistance with bathing, toileting, dressing, eating or drinking) to an adult who needs it due to age, illness or disability is regulated activity. In domiciliary care, staff by definition provide personal care or healthcare to clients in need, so their roles are within regulated activity for vulnerable groups. The employer in this context is considered a regulated activity provider, with legal obligations to check and monitor staff.
• Enhanced DBS Checks: For any staff member or volunteer in regulated activity, an Enhanced DBS check with Barred List check is required before they begin unsupervised work. This entails checking the individual’s full criminal history record plus a query of the Children’s Barred List and/or Adults’ Barred List as appropriate. For example, a care worker supporting a child will need an enhanced DBS including the children’s barred list; a worker supporting adults will require an enhanced check including the adults’ barred list. If a role involves working with both children and adults (some domiciliary care agencies serve both populations), the DBS request should include both workforce barred list checks. It is a criminal offence to knowingly employ someone in regulated activity from whom they are barred, so these checks are critical. As KCSIE guidance notes, employers must obtain an enhanced DBS with children’s barred list information for anyone engaging in regulated activity with children. – the same principle applies in adult care settings for the adult barred list.
• DBS Update Service: Many employers encourage hires to subscribe to the DBS Update Service, which allows periodic online checks to confirm no new criminal information has arisen. This can facilitate ongoing vetting, but it does not replace the initial barred list check. Providers should have a system to re-check DBS status of staff periodically (e.g. annually) or if there is reason for concern.
• Interim Barred List Checks: In rare cases where an employer needs someone to start urgently before the full DBS certificate is returned, there is a facility to do a fast-check of the barred list (previously via DBS online or telephone). However, this should be used only in exceptional circumstances, and the person must never be left unsupervised with children until the full enhanced DBS is obtained. Generally, best practice is to wait for the completed DBS disclosure before the employee has contact with service users.
• Duty to Refer to DBS: Both children’s and adults’ safeguarding frameworks impose a duty to refer staff to the DBS if they have been dismissed or removed from their role (or would have been, had they not left) because they harmed a child or adult or posed a risk of harmleedsscp.org.uk. This is not a pre-employment step, but it’s a crucial post-employment safeguard ensuring that individuals who are dangerous are barred from future care work. A compliant recruitment policy should mention that the organization will refer safeguarding incidents to the DBS and relevant authorities as required.

Safer Recruitment Practices and Vetting Steps

Whether recruiting for adult care or child care roles, the recruitment process must be rigorous and focused on safeguarding. The following practices are required or strongly recommended, with additional safeguards for child-facing roles noted:

• Advertising and Applicant Screening: Recruitment materials should state that the organization is committed to safeguarding vulnerable people and that thorough background checks will be conducted. This can deter unsuitable candidates from applying. Application forms (rather than CVs alone) are preferred, to capture a full history and a declaration of any criminal record. For roles with children, candidates should be asked to explain any gaps in employment and declare that they are not disqualified from working with children (e.g. by a court order). If the role falls under KCSIE or similar guidance, an online search of publicly available information may be done as an additional check (as some schools do).
• Interview Process: Plan structured interviews to probe the candidate’s experience, attitudes, and motivations for working with vulnerable people. At least one member of the panel should have training in safer recruitment techniques (required in schools, and good practice elsewhere). Use values-based interview questions to gauge the candidate’s ethics and empathy. For child-facing roles, include scenario questions about child protection (e.g. “What would you do if you witnessed signs of abuse in a child’s home?”) to test their knowledge and judgment. Observe professional boundaries – any concerning attitudes (e.g. not taking safeguarding seriously) should rule the person out.
• Identity and Right to Work Checks: Always verify the candidate’s identity with original documents (passport, driving licence, etc.) and check their right to work in the UK. Also confirm name changes or aliases to ensure the DBS check will catch all records. Identity confirmation is a basic first step before any other vetting can be relied upon.
• References and Employment History: Obtain at least two references for each candidate, including one from their most recent employer in a care or child-related role (if applicable). For an adult care role, it’s typical to get references covering the past 3–5 years of employment. For a child care role, it is critical to get references from any employer where the candidate worked with children. Under no circumstances should you accept an open-ended “to whom it may concern” reference – references should be directly obtained from the source (the HR department or manager) to ensure authenticity.. Verify the referee’s contact details independently (e.g. call the main company line) if the reference is provided via email, to avoid forged references..
  • Conduct and Safeguarding in References: Ask referees to comment on the candidate’s suitability to work with vulnerable adults or children (as relevant). For child-facing roles, specifically inquire if the referee knows of any reason why the person should not work with children. Schools must ask this; care providers should do the same. Statutory guidance advises that references for those working with children should include any facts about substantiated safeguarding concerns or allegations that relate to the person (for example, “While employed here, X was subject to one safeguarding investigation which was substantiated, involving inappropriate behavior; appropriate disciplinary action was taken”).. Unsubstantiated or false allegations are usually not included, but any serious verified issue must be disclosed to new employers in the interests of child safety.. This level of disclosure is not usually done in adult care references unless specifically requested, but any known issues of abuse or misconduct toward adults should of course be passed on.
  • Full Work History: Require a complete employment history (typically on the application form) and scrutinize it for gaps or frequent job changes. Any unexplained gap should be clarified with the candidate and, if significant, verified. This is important for all staff; however, for someone who will work with children, multiple or unexplained gaps might raise red flags that need resolving. Keep a written record of the candidate’s explanations for gaps or past job departures.
  • Reason for Leaving Previous Roles: As noted earlier, regulations mandate that if a candidate has worked in a position involving children or vulnerable adults in the past, the recruiter must take reasonable steps to verify why that employment ended. This goes beyond a standard reference. It may involve contacting the previous employer’s HR to directly ask, for example, “Did John Doe leave your employment for any reason that might concern his suitability to work with children/vulnerable adults?” Children’s services commonly do this via a LADO (Local Authority Designated Officer) check for any past allegations. Adult services should similarly check for any involvement in serious incidents at previous jobs. Document the outcome of these conversations. If a previous employer won’t respond, note that you attempted to obtain the info. Verification of leaving reasons is an extra safeguard especially relevant to child-facing recruitment, as it can reveal if someone was quietly dismissed for misconduct.
• Disclosure & Barring Checks: As detailed in the prior section, ensure the appropriate level of DBS check is completed before the person starts providing care unsupervised. The DBS certificate should be examined carefully by the hiring manager. If the DBS reveals any criminal record or other information (soft intelligence), a risk assessment must be conducted. Consider the nature of any offense, how long ago it was, and its relevance to the role. For example, a minor offense with no relevance to children might be assessed as low risk, whereas any history of abuse, violence, or exploitation should result in an immediate rejection for care roles. Involve a senior manager or safeguarding lead in these decisions for child-related roles. The rationale for any decision to appoint someone despite blemished DBS findings should be clearly documented. Note: Under the Rehabilitation of Offenders Act 1974 (and its exclusions), care roles are exempt so spent convictions will still appear on enhanced DBS if relevant; all such information must be weighed in the safeguarding context.
• Additional Checks for Specific Cases: If the role requires professional registration (e.g. nurses, social workers), verify the person’s registration and any fitness-to-practice or disciplinary history with their regulator. If the person has lived or worked abroad, obtain overseas criminal record checks or certificates of good conduct from those countries, as well as an extra reference from an overseas employer if possible. These steps are particularly crucial if hiring someone from abroad for a child care role, since the UK DBS will not cover offenses overseas. Also verify the candidate’s physical and mental fitness for the role (usually via a health questionnaire or occupational health check), as required by CQC standards – this applies to all staff but is especially important if caring for small children (who may require lifting, long periods of active engagement, etc.) or vulnerable adults with high needs.
• Safeguarding Agreements: Before beginning work, new hires should read and sign the organization’s Code of Conduct and Safeguarding Policy, indicating they understand their responsibilities (for example, the code may forbid staff from being alone with a child in a closed room or from forming inappropriate relationships with clients). This sets clear expectations from day one.

Training, Supervision and Safeguarding Oversight

Even after the initial vetting, safeguarding continues through probation and beyond. Some requirements differ for staff working with children vs. adults:

• Induction Training: All new staff must undergo an induction that covers core topics like health & safety, confidentiality, and role responsibilities. Crucially, for those working with children, the induction must include child protection procedures and how to recognize and report signs of abuse or neglect.. They should be introduced to the organization’s Designated Safeguarding Officer/Lead (DSL) for child protection and informed about the process for reporting any child welfare concerns. For staff working with adults, induction should similarly cover safeguarding adults at risk (e.g. types of abuse like financial or physical abuse of elders, and reporting protocols under the local Safeguarding Adults Board). The intensity of this training may be greater for child-facing roles due to the complexity of child protection law (e.g. mandatory reporting duties in some instances).
• Supervision of New Staff: In domiciliary care, staff often work alone in clients’ homes, so it’s vital to be confident in their trustworthiness and competence before they are on their own. For child care workers, it is common to have a period of shadowing or working under supervision. For example, a new hire might accompany an experienced staff member to visits for a week or more, or if working solo, there may be frequent check-ins and observation. They should not be left as the sole carer for a child until all checks are back and they have demonstrated basic competence. (If any checks are still pending, interim measures like additional supervision or pairing with another staff are required.) In adult care, shadow shifts and supervisory visits are also good practice, though specific rules may not mandate it as clearly as in children’s services. CQC expects that providers will assess each employee’s competence and only allow unsupervised work when the person is deemed competent and safe.
• Ongoing Training and Safeguarding Updates: Staff should receive regular refresher training in safeguarding – typically annually for child protection (as guided by Working Together) and periodically for adult safeguarding (per the Care Act guidance). If Keeping Children Safe in Education standards are a guide, staff should have annual updates and be aware of issues like child sexual exploitation, online safety, etc., if those are relevant to the care context (for instance, if working with teenagers). Adult care staff should be updated on issues like dementia care, mental capacity and deprivation of liberty (liberty protection safeguards), which tie into safeguarding.
• Management Oversight and Policies: The organization should have clear policies for safeguarding both children and adults. This includes procedures for reporting concerns internally and to external authorities. For child protection, any allegation or concern that a staff member has harmed a child must be reported to the local LADO within one working dayleedsscp.org.uk, and the staff member may need to be suspended or reassigned during investigation. The recruitment policy should reflect that the organization will cooperate with such investigations and has a process to handle allegations against staff (consistent with Working Together guidance)leedsscp.org.uk. For allegations involving adults (e.g. a staff accused of abusing an elderly client), the equivalent is to report to the local authority’s Safeguarding Adults team and possibly notify CQC. While these processes occur post-hire, they underscore the importance of the upfront recruitment rigor to avoid hiring anyone with red flags.
• Differentiated Supervision Requirements: There may be specific rules for staffing ratios or ages in certain child settings (e.g. in early years settings, staff under 17 cannot count toward ratios and must be supervised). In a domiciliary context, if the organization employs any staff under 18, they should never work alone with children – they should be paired with an older mentor until they reach an appropriate age and experience. This isn’t explicitly stated in law for home care, but follows general safeguarding common sense and some regulatory expectations in childcare. By contrast, in adult care, a 17-year-old care assistant may legally work (with appropriate training and support), but providers should still ensure they have sufficient maturity and backup.
• Continuous Monitoring and Appraisal: Ensuring safe care isn’t just about hiring the right people – it also involves monitoring staff behavior and performance. Supervision meetings and annual appraisals should address any issues of conduct. If a staff member begins to exhibit concerning behavior, it should be addressed immediately. Both CQC and Ofsted expect providers to create an environment where staff can voice concerns (whistleblowing) and where any risks to clients are promptly dealt with.. A recruitment policy can note that employment is subject to a satisfactory probation period during which the person’s suitability is further evaluated.

Summary of Additional Measures for Child-Facing Roles

In summary, recruiting and vetting staff for children’s domiciliary care involves everything required for adult care plus additional safeguards mandated by child protection law and guidance. When expanding an adult-focused recruitment policy to cover under-18 clients, ensure the following points are included:

• Enhanced DBS with Child Barred List: Every staff member working with children (even just occasionally) must have an enhanced DBS check that includes the children’s barred list, confirming they are not prohibited from such work.. (For adult care staff, an enhanced DBS with the adult barred list is required if working with adults at risk. If staff will work with both groups, both barred lists should be checked.) It is illegal to employ someone in a child role if they are barred. The recruitment policy should state that all roles involving direct contact with children or vulnerable adults are treated as regulated activity and require barred list DBS clearance.
• Thorough Reference Checks with Safeguarding Focus: Beyond standard professional references, extra effort must be made to verify a candidate’s history in working with children. Always obtain a reference from the last employer where the applicant worked with children (or vulnerable groups) and confirm why they left that job. Incorporate specific questions about the person’s suitability around children and any past safeguarding incidents.. Document all reference checks and any difficulties encountered in obtaining information. For adult-only roles, similar reference diligence is needed, but the questions may be less pointed (focusing on caregiving ability and integrity).
• Child Safeguarding Training and Policy Acknowledgement: Ensure that new hires for child-facing roles receive child protection training at induction (and refreshers regularly).. They should be made aware of Working Together guidelines and how to report child welfare concerns. The recruitment policy should mention that Keeping Children Safe guidelines will be adhered to, where relevant – for example, by having trained safer recruitment staff involved in hiring, and by not allowing unsupervised access to children until all checks and training are completed.
• Supervision and Probation for Child Roles: State in the policy that any staff member working with children will be initially closely supervised. If, in exceptional cases, they begin work before all references or checks are back, they will not be alone with children and will be under line-of-sight supervision. New children’s staff should have more frequent check-ins during probation to assess their understanding of safeguarding. (Adult care staff also should be monitored, but the policy needs to reflect the heightened vigilance required in children’s work.)
• Designated Safeguarding Lead (DSL): Identify who in the organization is responsible for overseeing child safeguarding. The recruitment process for child-facing staff might involve the DSL at interview or in final clearance, to ensure all safeguards are considered. The policy can note that the DSL (or a manager trained in child protection) must sign off on any appointment to a role working with minors.
• Compliance with Regulatory Bodies: Acknowledge the roles of CQC and Ofsted. For a domiciliary care service providing personal care in homes, CQC will be the regulator – the policy must meet CQC’s fundamental standards (Regulation 19 and Schedule 3) for all staff. If any service or activity falls under Ofsted (for example, if the organization later offers daycare or residential services for children), then Ofsted’s safer recruitment requirements (e.g. those in the Children’s Homes Regulations or Early Years Foundation Stage) must be integrated as well. In effect, the strictest applicable standard should be adopted. Notably, both CQC and Ofsted expect to see evidence during inspections that recruitment is handled safely and all required checks are in place.

By incorporating the above into the recruitment policy, an organization can ensure it meets the additional legal and best-practice measures for child safeguarding while also protecting adult service users. The overarching principle from Working Together 2023 is that safeguarding is everyone’s responsibility, and this begins with hiring safe, suitable and vetted individuals to care for children and vulnerable adults.. A rigorous, compliant recruitment approach not only fulfills legal obligations but also significantly reduces the risk of harm, helping to ensure the safety and well-being of all service users – whether they are children, young people, or adults.

Sources:

• Children Act 2004, Section 11 – Safeguarding arrangements dutyleedsscp.org.ukleedsscp.org.uk
• Working Together to Safeguard Children 2023 – Safe recruitment, supervision, and training guidance..
• Keeping Children Safe in Education 2025, Dept. for Education – Safer recruitment (Part 3) excerpt..
• Care Quality Commission (CQC) Regulation 19 and Schedule 3 – Fit and Proper Persons requirement for care staff
• Ofsted Children’s Homes (England) Regulations 2015 – Schedule 2: Recruitment checks (DBS, references, etc.)
• Disclosure and Barring Service – Regulated activity definitions and barred list check requirements

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