{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

---

Pre-Employment Screening and Vetting Policy

1. Purpose

The purpose of this Pre-Employment Screening and Vetting Policy is to ensure that {{org_field_name}}, acting as an employment business supplying temporary workers to client organisations, recruits and supplies only workers who have been appropriately screened and are suitable, competent, qualified and legally authorised to undertake the assignments for which they are supplied.

This policy establishes the processes to be followed when screening and vetting prospective and existing temporary workers, including registered nurses, healthcare assistants and support workers, before they are supplied to client organisations. It is intended to protect people receiving services, temporary workers and client organisations and to ensure that {{org_field_name}} complies with the statutory obligations applicable to an employment business, including the additional requirements applying where a worker will work with vulnerable persons.

{{org_field_name}} does not itself provide or carry on regulated health or social care activities and does not operate as a registered care provider. References in this policy to workers being supplied into health or social care settings do not mean that {{org_field_name}} assumes the regulatory responsibilities of a client organisation that is registered with the Care Quality Commission. Each client remains responsible for complying with the regulatory requirements applicable to the services that it carries on.

This policy sets out the responsibilities of the director, recruitment personnel and temporary workers and explains how screening and vetting information will be obtained, checked, used, recorded, reviewed and protected.

The policy is principally based on the Employment Agencies Act 1973; the Conduct of Employment Agencies and Employment Businesses Regulations 2003, as amended; the Safeguarding Vulnerable Groups Act 2006, as amended; the Police Act 1997; the Rehabilitation of Offenders Act 1974 and applicable Exceptions Orders; the Immigration, Asylum and Nationality Act 2006; the Equality Act 2010; the Data Protection Act 2018; the UK GDPR, as amended; and other legislation applying to the particular worker or assignment.

2. Scope

This policy applies to:

• All applicants seeking to join {{org_field_name}} as temporary workers, including registered nurses, healthcare assistants, and support workers on zero-hours or casual contracts
• All administrative and recruitment staff involved in screening and vetting candidates
• All client organisations utilising staff supplied by {{org_field_name}}
• All placements, whether short-term, ad-hoc, or ongoing, within regulated care services

3. Related Policies

• Recruitment and Selection Policy
• Safeguarding Adults and Children Policy
• Data Protection and Confidentiality Policy
• Code of Conduct for Temporary Workers
• Disciplinary Policy
• Supervision and Appraisal Policy
• Equality, Diversity, and Inclusion Policy

4. Legal and Regulatory Framework

This policy will be operated in accordance with applicable legislation and statutory requirements, including:

• the Employment Agencies Act 1973;
• the Conduct of Employment Agencies and Employment Businesses Regulations 2003, as amended;
• the Safeguarding Vulnerable Groups Act 2006, as amended by relevant subsequent legislation, including the Protection of Freedoms Act 2012;
• the Police Act 1997;
• the Rehabilitation of Offenders Act 1974 and the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975, as amended;
• the Equality Act 2010;
• the Immigration, Asylum and Nationality Act 2006 and applicable Home Office right-to-work requirements;
• the Data Protection Act 2018 and UK GDPR, as amended, including relevant amendments made by the Data (Use and Access) Act 2025;
• the Agency Workers Regulations 2010, where applicable to workers supplied by {{org_field_name}};
• the Care Act 2014, where relevant to safeguarding responsibilities; and
• the Disclosure and Barring Service Code of Practice and applicable statutory DBS requirements and eligibility rules.

Where a temporary worker is supplied to a client organisation that carries on a CQC-regulated activity, the client organisation remains responsible for its own obligations under the Health and Social Care Act 2008 and associated regulations. {{org_field_name}} will provide the client with the information and evidence that it is legally required to provide as an employment business and will comply with any lawful and proportionate assignment-specific requirements notified by the client.

5. Principles

{{org_field_name}} is committed to:

• Conducting fair, thorough, and legally compliant screening of all applicants
• Ensuring that no temporary worker is placed without full vetting and verification
• Preventing unsuitable individuals from working with vulnerable adults
• Promoting equality and transparency throughout the recruitment and vetting process
• Keeping accurate, secure records of all checks and evidence gathered

6. Pre-Employment Screening Process

All applicants will be required to undergo the following screening and vetting checks prior to employment and placement:

6.1 Identity Verification

The applicant must provide:

• A valid passport or full UK birth certificate
• Proof of address dated within the last three months (e.g., utility bill or bank statement)
• A valid photo ID (e.g., driving licence)

All identity documents must be originals and verified in person or via secure digital validation methods.

6.2 Right to Work in the UK

Before a worker begins work for {{org_field_name}}, their right to work in the United Kingdom will be established using a method permitted by the Home Office at the time of the check.

Depending on the worker’s status, {{org_field_name}} will carry out the appropriate check by:

• conducting a Home Office online right-to-work check using the worker’s valid right-to-work share code and date of birth where the worker holds an immigration status that must or may be checked using that service;
• carrying out a prescribed manual check of acceptable original documents where a manual document check is permitted;
• using a compliant Digital Verification Service for an eligible British or Irish citizen holding an appropriate valid passport or Irish passport card, where {{org_field_name}} chooses to use such a service; or
• obtaining verification through the Home Office Employer Checking Service where that service is required or permitted by Home Office rules.

{{org_field_name}} will not accept an immigration document as evidence of right to work where Home Office requirements require the person’s status to be verified through the online service.

For every right-to-work check, {{org_field_name}} will:

• carry out the check before the individual begins employment or work for which {{org_field_name}} is required to establish a statutory excuse;
• satisfy itself that the person whose right to work is being checked is the person shown in the document, digital identity output or Home Office online profile;
• confirm that the person has permission to undertake the type of work being offered and identify any restrictions applying to their work, including restrictions concerning occupation or working hours;
• retain the prescribed evidence of the check and the date on which it was carried out;
• conduct any required follow-up check before a time-limited statutory excuse expires; and
• apply the right-to-work process consistently and without unlawful discrimination.

Where a worker has a time-limited right to work, {{org_field_name}} will maintain an appropriate expiry and follow-up checking process. A worker must immediately inform {{org_field_name}} of any change that may affect their continuing permission to undertake the work for which they are supplied.

Evidence retained for the purpose of establishing a statutory excuse against liability for illegal working will be retained securely for the duration of the worker’s employment or engagement for which the statutory excuse is required and for two years afterwards, after which it will be securely destroyed unless another lawful requirement justifies further retention.

Where Regulation 22 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003 requires evidence of an authorisation required by law to undertake the position, {{org_field_name}} will retain the necessary evidence and will offer the relevant evidence to the hirer as required by those Regulations.

6.3 DBS and Barred List Checks

{{org_field_name}} will determine the lawful level of Disclosure and Barring Service check separately for each role before requesting a criminal-record check. The level of check will be based on the duties actually undertaken, the people with whom the worker will work, the setting in which the work takes place and the statutory eligibility criteria applying at the time of the application.

An Enhanced DBS check with an Adults’ Barred List check will only be requested where the particular position is legally eligible for that level of check, including where the worker will undertake regulated activity with adults within the meaning of the Safeguarding Vulnerable Groups Act 2006, as amended.

Where a role involving adults does not qualify for an Adults’ Barred List check but is legally eligible for another level of DBS check, {{org_field_name}} will request only the level of check to which the role is legally entitled.

Where an assignment involves children, {{org_field_name}} will separately assess eligibility under the statutory rules applying to the children’s workforce and will request Children’s Barred List information only where there is a lawful entitlement to do so.

{{org_field_name}} will not request a Standard, Enhanced or barred-list check merely because a candidate works generally within health or social care. The eligibility assessment will relate to the actual role and activities for which the individual is being considered.

Where a worker presents an existing DBS certificate and is subscribed to the DBS Update Service, {{org_field_name}} may undertake an Update Service status check only where:

• the worker has given the required permission;
• {{org_field_name}} has verified the worker’s identity and the original certificate in accordance with current DBS requirements;
• the certificate is of the appropriate workforce, type and level for the position;
• the agency remains legally entitled to obtain the information contained in that certificate; and
• any barred-list information included in the check is information that {{org_field_name}} is legally entitled to request for the particular position.

Where an existing certificate or Update Service result cannot lawfully or reliably be used for the proposed position, a new DBS application at the appropriate lawful level will be required before the worker is supplied where such a check is required.

Where {{org_field_name}} applies its internal three-year DBS renewal requirement, any repeat application will still be subject to a fresh assessment of the level of DBS check to which the worker’s current role is legally entitled. A barred-list check will never be requested solely because the worker previously held a certificate containing barred-list information.

Any criminal-record or other information disclosed will be assessed fairly and individually, having regard to its relevance to the particular role, safeguarding risks, legal restrictions and the circumstances of the case.

A person who is barred from regulated activity with adults or children must not be knowingly supplied by {{org_field_name}} to undertake regulated activity with the group from which that person is barred.

6.4 Employment References

Where a worker is to be supplied to work with vulnerable persons within the meaning of the Conduct of Employment Agencies and Employment Businesses Regulations 2003, {{org_field_name}} will obtain two written references before introduction or supply in accordance with Regulation 22.

For those positions:

• both references must be obtained from persons who are not relatives of the work-seeker;
• the referees must have agreed that their references may be disclosed to the hirer;
• the references will, wherever reasonably practicable, include appropriate employment or professional references relevant to the work-seeker’s experience and suitability for the position;
• where the candidate has recent health or social care employment, at least one reference will normally be sought from the most recent relevant employer;
• references will be obtained directly from, or independently verified with, the referee wherever necessary to confirm authenticity; and
• copies of the required references will be offered to the hirer before the work-seeker is introduced or supplied, as required by the Conduct of Employment Agencies and Employment Businesses Regulations 2003.

Where {{org_field_name}} has taken all reasonably practicable steps but has been unable to obtain a reference or other information required under Regulation 22, the worker will not be introduced or supplied unless the requirements permitting introduction or supply in those circumstances have been satisfied. This includes informing the hirer of the information that could not be obtained and the steps that {{org_field_name}} took to obtain it.

Any additional company requirement for references covering a specified period of employment history will operate in addition to, and not instead of, the statutory requirements above.

Copies and records relating to references will be retained securely and only for so long as there is a lawful and necessary reason for their retention, subject to any applicable statutory record-keeping requirement.

6.5 Employment History

Applicants must provide:

• A full employment history since leaving secondary education
• Written explanations for any gaps in employment exceeding 28 days
• Details of all previous roles within health and social care, including dates and locations

Employment histories will be verified against references and checked for accuracy.

6.6 Qualifications and Training

Before a worker is supplied, {{org_field_name}} will establish the qualifications, experience, training and authorisations required for the particular assignment from the hirer and will undertake the checks required by law and by the Conduct of Employment Agencies and Employment Businesses Regulations 2003.

Where a qualification or authorisation is required by law, a relevant professional body or the hirer for the position concerned, {{org_field_name}} will obtain and verify appropriate evidence before introduction or supply, subject to the limited circumstances permitted by the Conduct Regulations where required information cannot be obtained.

Workers may be required, according to the position, to provide evidence of relevant qualifications and training, which may include:

• professional registration;
• vocational qualifications;
• the Care Certificate or evidence of equivalent competence, where required by the hirer;
• Basic Life Support;
• Moving and Handling;
• Safeguarding Adults and/or Children, as appropriate to the role;
• Infection Prevention and Control;
• Fire Safety;
• Food Hygiene, where relevant to the duties undertaken; and
• Health and Safety training appropriate to the assignment.

The exact training requirements will be determined by the duties of the assignment, applicable legislation, professional requirements, identified workplace risks and the lawful requirements of the hirer. A course or certificate will not be treated as mandatory merely because it appears in the general list above where it is not relevant to the particular assignment.

{{org_field_name}} will:

• check the authenticity and currency of qualifications, registrations, authorisations and training evidence where required;
• maintain appropriate records of checks and expiry or renewal dates;
• require refresher or further training where necessary for the worker to remain competent and suitable for the assignment;
• maintain an appropriate training and compliance matrix; and
• offer the hirer copies of qualifications and authorisations where required by Regulation 22 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003.

If {{org_field_name}} is unable to obtain a qualification or authorisation required for a role involving vulnerable persons, it will follow the procedure required by Regulation 22 before any introduction or supply takes place.

6.7 Professional Registration (Nurses and Regulated Roles)

For registered nurses and other regulated professionals:

• NMC registration must be active and without restrictions
• Pin numbers will be checked via the NMC Register
• Any conditions, cautions, suspensions, or referrals will be fully assessed and investigated

7. Additional Checks

7.1 Overseas Police Checks

Where applicants have lived outside the UK for more than six continuous months in the past five years, they must:

• Provide a police clearance certificate or equivalent from the relevant country

7.2 Occupational Health and Health Information

{{org_field_name}} will comply with section 60 of the Equality Act 2010 when obtaining health or disability information during recruitment.

Except where one of the statutory exceptions permits a question to be asked earlier, {{org_field_name}} will not require an applicant to complete a general health questionnaire, provide general information about their health or disability, or undergo an occupational health assessment before the applicant has been offered work, conditionally or unconditionally, or has been placed within a pool of successful candidates from whom temporary assignments will be offered.

Before that stage, health or disability questions will only be asked where permitted by law, including where genuinely necessary to:

• establish whether reasonable adjustments are required for the applicant to participate in the recruitment or assessment process;
• establish whether the applicant will be able to carry out a function that is intrinsic to the work, subject to the duty to make reasonable adjustments;
• undertake permitted diversity monitoring separately from selection decisions;
• support lawful positive action; or
• determine whether an applicant has a disability where having a particular disability is an occupational requirement that is lawful under the Equality Act 2010.

After the stage at which health enquiries are lawfully permitted, {{org_field_name}} may obtain occupational health information that is necessary to determine fitness for the proposed duties, identify reasonable adjustments, meet health and safety obligations, or meet a lawful and proportionate requirement of the particular assignment.

Evidence of vaccination or immunisation will only be requested where it is necessary and proportionate for the duties of the particular assignment and there is a lawful basis for obtaining and using that information. No particular vaccination will be treated as universally required unless applicable legislation or a lawful assignment-specific requirement makes it necessary.

Health, disability, vaccination and immunisation information constitutes special-category personal data and will be processed only where {{org_field_name}} has identified and documented both an appropriate lawful basis under Article 6 UK GDPR and an applicable condition under Article 9 UK GDPR, together with any condition or safeguard required by the Data Protection Act 2018.

Access to occupational health information will be restricted to persons who require it for a legitimate and lawful purpose. Wherever practicable, recruitment and placement decision-makers will receive only information necessary to establish fitness, restrictions or adjustments rather than unnecessary underlying medical information.

Reasonable adjustments will be considered and implemented as required by the Equality Act 2010.

8. Assessment and Decision-Making

The director or an appropriately authorised member of staff will review the screening and vetting information relevant to the worker and proposed assignment before a final decision to supply that worker is made.

The assessment will include, where applicable:

• confirmation of identity;
• confirmation of an appropriate right to work;
• references required by the Conduct of Employment Agencies and Employment Businesses Regulations 2003;
• qualifications, training and professional authorisations required for the particular assignment;
• the appropriate DBS and barred-list eligibility assessment and any lawfully obtained result;
• professional registration status;
• relevant employment history;
• assignment-specific requirements communicated by the hirer; and
• any information relevant to the worker’s suitability that {{org_field_name}} may lawfully take into account.

Any concerns identified during screening will be considered individually and proportionately. A formal risk assessment will be completed where appropriate, including where relevant information concerns criminal records, gaps in employment, professional restrictions, safeguarding information or discrepancies in documentation.

Decisions and the reasons for them will be recorded sufficiently to provide an appropriate audit trail, subject to data minimisation and retention requirements.

A worker will only be supplied where {{org_field_name}} has taken the steps required by the Conduct of Employment Agencies and Employment Businesses Regulations 2003 and is satisfied that it is lawful and appropriate to supply the worker to the particular assignment.

8.1 Hirer Information and Assignment Suitability

Before introducing or supplying a work-seeker to a hirer, {{org_field_name}} will obtain sufficient information from the hirer to enable it to select a suitable work-seeker and comply with Regulation 18 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003.

The information obtained will include, as applicable:

• the identity of the hirer and the nature of its business;
• the date on which the worker is required to start;
• the expected duration of the assignment;
• the position and type of work the worker will be required to undertake;
• the location and working hours;
• known health and safety risks arising from the position and the steps taken by the hirer to prevent or control those risks;
• the experience, training, qualifications and authorisations required by law, a professional body or the hirer;
• any expenses payable by or to the worker; and
• any other information required by the Conduct of Employment Agencies and Employment Businesses Regulations 2003 for the particular assignment.

{{org_field_name}} will take all reasonably practicable steps required by Regulation 20 to ensure that the proposed arrangement is not detrimental to the interests of the work-seeker or hirer.

Before supply, {{org_field_name}} will also take reasonable steps to ensure that the hirer and work-seeker are aware of any legal or professional requirements that must be satisfied for the work-seeker to undertake the position.

8.2 Information Arising After Supply

Where, after a temporary worker has been supplied, {{org_field_name}} receives information indicating that the worker may no longer be suitable for the position, {{org_field_name}} will act without delay in accordance with Regulation 20 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003.

Where information indicates that the worker may be unsuitable but the position has not yet been established, {{org_field_name}} will without delay:

• inform the hirer of the relevant information;
• make appropriate enquiries to establish the worker’s suitability; and
• inform the hirer of the enquiries made and any relevant information obtained.

Where information establishes that the worker is unsuitable for the position, {{org_field_name}} will inform the hirer and cease supplying the worker to that position without delay.

Any safeguarding, DBS, professional-regulatory, employment or other action required by law will also be considered and taken separately.

9. Data Protection and Confidentiality

{{org_field_name}} will process personal data obtained through screening and vetting in accordance with the UK GDPR and Data Protection Act 2018, as amended.

For each category of information processed, {{org_field_name}} will identify an appropriate lawful basis under Article 6 UK GDPR before processing takes place. Where special-category personal data is processed, including health, disability, vaccination or immunisation information, {{org_field_name}} will also identify an applicable condition under Article 9 UK GDPR and any corresponding requirement under the Data Protection Act 2018.

Criminal-offence data, including DBS information, will only be processed where {{org_field_name}} has lawful authority to process that information and has satisfied the additional requirements applicable to criminal-offence data.

Where reliance upon a condition under Schedule 1 to the Data Protection Act 2018 requires an Appropriate Policy Document, {{org_field_name}} will ensure that an appropriate and current document is in place.

{{org_field_name}} will:

• collect only information that is adequate, relevant and limited to what is necessary for the recruitment, vetting, assignment and compliance purpose concerned;
• provide applicants and workers with the information required by applicable data protection transparency requirements;
• restrict access to screening and vetting records to authorised persons with a legitimate need to access them;
• apply appropriate technical and organisational security measures;
• ensure information is accurate and, where necessary, kept up to date;
• comply with applicable rights of data subjects;
• retain information only for the period justified by an applicable legal, regulatory or operational requirement; and
• securely delete or destroy information when there is no longer a lawful reason to retain it.

Consent will not be described or relied upon as the blanket lawful basis for all recruitment and compliance processing. Where consent is genuinely relied upon for a particular activity, {{org_field_name}} will ensure that the legal requirements for valid consent are satisfied and that another lawful basis is used where consent would not be appropriate.

Evidence retained to establish a statutory excuse following a right-to-work check will be kept for the duration of the relevant employment or engagement and for two years afterwards, in accordance with Home Office requirements.

Records required by the Conduct of Employment Agencies and Employment Businesses Regulations 2003 will be retained for at least the statutory minimum period prescribed by those Regulations. Where another applicable law requires a longer period, the longer lawful retention requirement will be applied.

DBS certificate information will be stored, used, disclosed, retained and destroyed in accordance with the DBS Code of Practice, applicable data protection requirements and the organisation’s policy governing the secure handling of DBS information. DBS information will not be retained for longer than is necessary for the purpose for which it was obtained.

Applicants and temporary workers are required to provide information that is accurate and not misleading and must inform {{org_field_name}} of relevant changes where required for continued lawful employment, engagement or supply.

10. Handling Criminal Record Disclosures

{{org_field_name}} will obtain and consider criminal-record information only to the extent permitted by law for the particular position.

Before requesting a Standard or Enhanced DBS check or barred-list information, {{org_field_name}} will establish that the position is legally eligible for that level and type of check. {{org_field_name}} will not seek information about criminal matters that it is not legally entitled to require the applicant to disclose.

Where the position is covered by an exception to the Rehabilitation of Offenders Act 1974, {{org_field_name}} will apply the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975, as amended, and applicable filtering rules when determining what information may lawfully be requested and considered.

Criminal-record information lawfully obtained will be:

• considered individually and fairly;
• assessed for relevance to the particular position and duties;
• considered in the context of safeguarding obligations and risks;
• discussed with the applicant where appropriate before an adverse decision is made;
• handled in accordance with the DBS Code of Practice and data protection legislation; and
• disclosed to a hirer or other person only where disclosure is lawful, necessary and made to a person authorised to receive the information.

The existence of a conviction, caution or other information on a DBS certificate will not automatically result in rejection unless employment or supply into the particular position is prohibited by law or the information demonstrates an unacceptable risk that cannot appropriately be managed.

Where an applicant is barred from regulated activity with adults or children, {{org_field_name}} will not knowingly supply that person to undertake regulated activity with the group from which they are barred.

DBS certificate information will only be used for the purpose for which it was lawfully obtained and will be protected against unauthorised access, use or disclosure.

11. Responsibility of the Director

As {{org_field_name}} does not have a registered manager, the director is responsible for:

• Overseeing the application and enforcement of this policy
• Ensuring all vetting activities are completed before placement
• Managing all aspects of risk assessment and escalation
• Ensuring all data and evidence are stored in line with data protection law
• Reviewing vetting trends, audit findings, and compliance risks
• Taking prompt action in case of non-compliance or safeguarding concerns

11.1 Statutory Referrals to the Disclosure and Barring Service

{{org_field_name}} recognises that an employment business supplying personnel to undertake regulated activity may be a personnel supplier for the purposes of the Safeguarding Vulnerable Groups Act 2006 and may have a legal duty to make a referral to the Disclosure and Barring Service where the statutory referral conditions are satisfied.

Where the statutory conditions for a referral are met, {{org_field_name}} will make the required referral to the DBS. A referral to a client organisation, local authority safeguarding service, police force or professional regulator will not be treated as replacing a separate statutory duty to refer to the DBS.

The director will ensure that any situation involving alleged harm, relevant conduct, risk of harm, removal from regulated activity or another circumstance potentially engaging the statutory DBS referral duty is considered promptly against the current statutory referral criteria.

A worker’s resignation, cessation of assignments or other departure will not prevent a referral being considered or made where the legal referral conditions are otherwise satisfied.

{{org_field_name}} will provide information to the DBS where it is legally required to do so and will maintain appropriate records demonstrating consideration of, and compliance with, its statutory safeguarding and referral obligations.

{{org_field_name}} will not knowingly permit or supply a person who is barred from regulated activity to undertake regulated activity with the group from which that person is barred.

12. Review and Updating of Vetting Records

{{org_field_name}} will:

• Monitor the currency of DBS checks, training, and professional registration
• Send reminders to workers about renewals and required updates
• Suspend or de-register workers who fail to update compliance records as required

Temporary workers are expected to:

• Cooperate with renewal processes
• Notify the agency immediately of any change in circumstances that may affect their suitability for work

13. Equality and Fairness

{{org_field_name}} will operate all recruitment, screening, vetting and placement processes in accordance with the Equality Act 2010.

Applicants and workers will not be subjected to unlawful discrimination, harassment or victimisation because of any protected characteristic applicable under the Equality Act 2010, including:

• age;
• disability;
• gender reassignment;
• marriage and civil partnership, where the statutory protection applies;
• pregnancy and maternity;
• race, including colour, nationality and ethnic or national origins;
• religion or belief;
• sex; and
• sexual orientation.

Selection and vetting decisions will be based on lawful, objective and proportionate requirements relevant to the particular role.

{{org_field_name}} will make reasonable adjustments for disabled applicants and workers where required by the Equality Act 2010 and will comply with the statutory restrictions concerning health and disability questions during recruitment.

Right-to-work checks will be undertaken consistently for all persons whom {{org_field_name}} is required to check. {{org_field_name}} will not make assumptions about a person’s right to work or immigration status because of their race, colour, nationality, ethnic or national origins, name, accent or perceived length of residence in the United Kingdom.

A person will not be treated less favourably merely because they hold a time-limited right to work, provided that they have established a lawful entitlement to undertake the work concerned and {{org_field_name}} can comply with the applicable right-to-work requirements.

Criminal-record checking and decisions based on lawfully obtained criminal-record information will also be undertaken fairly and consistently and only to the extent legally permitted for the position concerned.

14. Continuous Improvement

The director will:

• Review this policy annually or earlier if legislation, regulation, or best practice guidance changes
• Audit screening files regularly to ensure compliance and accuracy
• Use learning from incidents, complaints, or inspections to update procedures and staff training

15. Policy Review

This policy will be reviewed annually by the director of {{org_field_name}} or sooner if required by changes in law, best practice guidance, or organisational needs. Any updates will be communicated to relevant stakeholders, staff, and clients accordingly.

---

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.