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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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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}} recruits and supplies only those temporary workers who are safe, competent, qualified, and suitable for the delivery of high-quality care and support in health and social care settings. This policy establishes clear, legally compliant processes for the screening and vetting of all prospective temporary workers, including registered nurses, healthcare assistants, and support workers, prior to their deployment in client establishments. The policy upholds statutory and regulatory standards, ensuring the safety of vulnerable adults, the protection of our client organisations, and the integrity of our workforce. This document further outlines the responsibilities of the director, recruitment personnel, and the temporary workers themselves, and describes how vetting is managed, recorded, and reviewed. The policy is aligned with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, the Care Standards Act 2000, the Safeguarding Vulnerable Groups Act 2006, the Disclosure and Barring Service (DBS) guidelines, the Equality Act 2010, the Rehabilitation of Offenders Act 1974, the Agency Workers Regulations 2010, and the CQC Fundamental Standards.

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 is informed by and compliant with:

• The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (Regulation 19 – Fit and proper persons employed)
• The Disclosure and Barring Service (DBS) Code of Practice
• The Safeguarding Vulnerable Groups Act 2006
• The Care Act 2014
• The Data Protection Act 2018 and the UK GDPR
• The Rehabilitation of Offenders Act 1974 (Exceptions Order)
• The Equality Act 2010
• The Immigration, Asylum and Nationality Act 2006
• The Agency Workers Regulations 2010
• CQC Fundamental Standards

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

To comply with the Immigration, Asylum and Nationality Act 2006, applicants must:

• Provide original documentation demonstrating their legal right to work in the UK
• Have their documentation copied and verified according to the Home Office checklist
• Undergo digital status checks where applicable (e.g., EU Settlement Scheme share code)

6.3 Enhanced DBS Check with Barred List Information

All applicants will undergo an Enhanced DBS check, including a check against the Adult Barred List. {{org_field_name}} will:

• Conduct new DBS checks for all applicants unless they are already registered with the DBS Update Service
• Verify the status of all checks through the Update Service (where applicable)
• Repeat DBS checks every three years or sooner if required due to concerns, change of role, or gap in employment
• Assess any disclosed information using a robust risk assessment and ensure appropriate decisions are made in line with safeguarding principles

6.4 Employment References

Applicants must provide:

• Two satisfactory references, including one from their most recent health or social care employer
• References covering at least the past three years
• Character references if no recent employer references are available (e.g., for newly qualified workers)

{{org_field_name}} will:

• Verify references verbally when necessary
• Contact referees directly to authenticate the reference
• Retain copies of all reference correspondence

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

All applicants must:

• Provide original certificates for qualifications relevant to the role (e.g., NMC registration, NVQ, care certificates)
• Complete or show evidence of up-to-date mandatory training including but not limited to:
  • Basic Life Support
  • Moving and Handling
  • Safeguarding Adults and Children
  • Infection Prevention and Control
  • Fire Safety
  • Food Hygiene
  • Health and Safety
• Undertake refresher training if certification is out of date

{{org_field_name}} will:

• Maintain a training matrix and renewal schedule
• Provide access to e-learning or in-person training where required

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 Declaration

Applicants will be asked to:

• Complete a confidential health questionnaire
• Declare any physical or mental health conditions that may impact their ability to work safely
• Provide evidence of immunisation (e.g., Hepatitis B, MMR, COVID-19) where applicable

The director will:

• Review declarations and refer to occupational health if required
• Consider reasonable adjustments under the Equality Act 2010

8. Assessment and Decision-Making

The director will:

• Review the full pre-employment screening file for each applicant
• Consider the results of all checks before making a decision
• Use a formalised risk assessment process where any concerns arise (e.g., previous convictions, employment gaps)
• Record all decisions with a clear audit trail
• Inform the applicant of the outcome and next steps

9. Data Protection and Confidentiality

{{org_field_name}} will:

• Process personal data in accordance with the Data Protection Act 2018 and GDPR
• Store all vetting records securely and restrict access to authorised personnel only
• Retain documentation only for as long as necessary in accordance with our Records Retention Schedule

Applicants must:

• Provide accurate and honest information
• Consent to data being processed for the purposes of recruitment and compliance
• Be informed of their right to access and correct their data

10. Handling Criminal Record Disclosures

All criminal disclosures will be:

• Risk assessed individually considering the nature, age, relevance, and circumstances of the offence
• Discussed confidentially with the applicant
• Shared with client organisations only where there is a legal and safeguarding justification

A criminal conviction does not automatically exclude an applicant, but {{org_field_name}} reserves the right to refuse employment where the offence poses an unacceptable risk.

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

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

All screening processes will:

• Be applied consistently to all applicants regardless of race, gender, disability, sexual orientation, religion, or age
• Include appropriate adjustments for disabled applicants as required by the Equality Act 2010
• Avoid unfair discrimination in decision-making

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.

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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.