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{{org_field_name}}
Registration Number: {{org_field_registration_no}}
Pre-Employment Checks Policy (including DBS & References)
1. Purpose
This policy outlines how {{org_field_name}} conducts comprehensive and legally compliant pre-employment checks for all prospective employees, including Registered Nurses (RNs) and Healthcare Assistants (HCAs) working on zero-hours contracts in care homes. Ensuring that staff are suitable, qualified, and safe to work with vulnerable adults is paramount to maintaining the quality, safety, and integrity of the services we provide.
2. Scope
This policy applies to all individuals applying to work for {{org_field_name}}, regardless of role, contract type, or length of assignment. It covers:
- Permanent and temporary staff
- Bank staff and zero-hours staff
- Volunteers (if applicable)
- Agency workers supplied directly to clients via {{org_field_name}}
This policy is also intended for inspection and auditing bodies such as the Care Quality Commission (CQC), local authorities, and client organisations.
3. Related Policies
- Recruitment Policy
- Equality, Diversity and Inclusion Policy
- Safeguarding Policy
- Data Protection and Confidentiality Policy
- Whistleblowing Policy
- Health and Safety Policy
- Staff Supervision and Appraisal Policy
4. Legal Framework
This policy is guided by the following legislation and regulatory requirements:
- The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
- The Safeguarding Vulnerable Groups Act 2006
- The Data Protection Act 2018 (GDPR)
- The Rehabilitation of Offenders Act 1974
- The Agency Workers Regulations 2010
- The Disclosure and Barring Service (DBS) Code of Practice
- Employment Rights Act 1996
5. Types of Pre-Employment Checks Conducted
5.1 Identity Verification
All candidates must provide original and valid proof of identity. Acceptable documents include:
- Passport (preferred)
- Full Birth Certificate (if no passport)
- UK Driving Licence
- Right to work evidence (e.g., Biometric Residence Permit, Share Code if EEA)
Photocopies will not be accepted as substitutes. Originals are verified and securely scanned, with copies retained in personnel records in line with GDPR requirements.
5.2 Right to Work Checks
We are legally obligated to check every applicant’s right to work in the UK, irrespective of nationality. This is done:
- In person (or via live video where permitted)
- Prior to commencing any work
- In line with the Home Office guidance
All evidence is documented and securely stored.
5.3 Qualification Verification
Candidates applying for roles that require professional qualifications (e.g., Registered Nurses) must provide:
- Original certificates of qualifications
- Evidence of registration with the Nursing and Midwifery Council (NMC)
- Continuous Professional Development (CPD) records, if applicable
Verification is carried out through:
- The NMC Register
- Cross-referencing certificates with awarding bodies if necessary
5.4 Employment History & Gap Explanation
Applicants must provide a full employment history, accounting for any gaps of more than four weeks. Gaps must be explained in writing and may require evidence (e.g., travel, caring responsibilities, illness).
5.5 References
Two employment references are mandatory, covering at least the previous three years of employment. Requirements:
- One reference must be from the most recent employer
- If previously employed in health or social care, one reference must relate to that employment
- Personal or character references may only be accepted if employment references are unavailable, and this must be justified and documented
References are:
- Requested in writing (email or letter)
- Verified via follow-up phone calls to confirm authenticity
- Documented fully in the applicant’s personnel file
5.6 Enhanced Disclosure and Barring Service (DBS) Checks
Due to the nature of our services, all applicants will undergo an Enhanced DBS Check with Adult Barred List check. This ensures compliance with:
- The Safeguarding Vulnerable Groups Act 2006
- The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
DBS Checks are:
- Applied for only after a conditional offer is made
- Valid for up to 3 years but reviewed annually or sooner if required
- Portability via the DBS Update Service is accepted if the applicant is subscribed and consent is given
- Renewed if there is a gap in employment with {{org_field_name}} of more than six months
Applicants with a positive DBS will be risk assessed on a case-by-case basis by the director. The decision, rationale, and any control measures will be documented.
5.7 Occupational Health Clearance
Occupational health questionnaires will be used to assess:
- Fitness to work
- Immunisation status (e.g., Hepatitis B for clinical staff)
- Any reasonable adjustments required
Referrals to occupational health services will be made when necessary.
6. Management of Pre-Employment Checks
All pre-employment checks are the direct responsibility of the director(s) of {{org_field_name}}. The process is managed efficiently through:
- A pre-employment checklist maintained for every applicant
- A secure recruitment file maintained for each applicant
- Periodic audits conducted by the director to verify compliance
- Continuous monitoring to ensure legislative and best practice updates are reflected promptly in procedures
The director(s) will:
- Ensure checks are completed before the individual starts any assignment
- Prevent deployment if checks are incomplete or unsatisfactory
- Record the final approval of each candidate on the pre-employment checklist
- Undertake annual refresher training on safer recruitment practices
7. Confidentiality and Data Protection
All information obtained during the recruitment process is:
- Processed in compliance with the Data Protection Act 2018 (GDPR)
- Held securely and only shared on a need-to-know basis
- Retained and disposed of according to our Data Protection and Confidentiality Policy
8. Staff Training
All staff involved in recruitment, including those conducting interviews or handling pre-employment checks, will receive training on:
- Safer recruitment
- Pre-employment check procedures
- Recognising fraudulent documents
- Data protection responsibilities
Training will be refreshed annually or sooner if legislation changes.
9. Audit and Quality Assurance
The director(s) will:
- Carry out quarterly audits of recruitment files
- Review pre-employment processes for efficiency and compliance
- Record findings and implement any corrective actions
- Report findings to stakeholders when required (e.g., CQC, commissioners)
10. Responsibilities
Director(s) of {{org_field_name}}:
- Lead on implementing and monitoring this policy
- Make the final decision regarding employment offers
- Undertake risk assessments for any positive disclosures
- Maintain up-to-date knowledge of relevant legislation
Staff:
- Provide accurate and honest information during recruitment
- Cooperate fully in providing requested documentation
- Inform the director(s) of any changes that could affect their employment status (e.g., criminal convictions, health issues)
11. Policy Review
This policy will be reviewed annually by the director(s) of {{org_field_name}} or sooner if:
Lessons from audits or incidents indicate a need for improvement
There are changes in legislation or guidance
There are significant organisational changes
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}}
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