This page of our website will provides guidance in helping you understanding DBS processes and provides the latest guidance received from the DBS together with useful links for more detailed information, we hope you find this information useful.

 

Adult First Checks

This is a service provided by the DBS under the Police Act 1997. It can be used in exceptional cases where a person is permitted to start regulated activity work with adults, before a DBS certificate has been obtained. This service is only available to organisations who are eligible to access the DBS adults’ barred list and who have requested a check of the barred list on their DBS application. The DBS Adult First check allows an individual to be checked against the DBS adults’ barred list ahead of the Disclosure certificate being issued. A preliminary result is sent to the Registered Body who submitted the application, we then forward this information on to the ID checker via the notes system via DBS Assist.

If your original application did not request an Adult First Check, we can arrange for this to be carried out at a later date, but prior to the certificate issue.  Please contact us to discuss your requirements.

Applications received from organisations and countersigned by the ARC Disclosure Service team can only be escalated (raised as a delayed/outstanding application) 60 working days from the date of countersigning/submitting to the DBS.

When an application is 'escalated' this will be raised with the relevant Police Force who are responsible for administering the level of check, including making a decision to prioritise a check or completing an escalation request.  When a check is sent to the police there is a negotiated Service Level Agreement (SLA) in place with the police which allows them 60 days to receive, review and respond to the request.  If at any point they return the check to the DBS for confirmation of any of the information provided to them ie. as a 'conflict', the DBS will investigate and then return the check to the police.  At present this action re-sets the 60 day clock back to zero and the police have a further 60 days.

There are a number of factors that can affect the timely completion of checks, including but not restricted to, the accurate completion of the application, the clarity of the information provided, the existence of conviction or non-conviction information and the operational effectiveness of the Disclosure Units at the police forces involved in the Enhanced Disclosure process.  If the applicant has provided all the mandatory information, then a completion of the initial stages of the check is done within a matter of days.

The applicant must provide a range of ID documents as part of the DBS check application process. As an employer you must:

  • follow the three route ID checking process as outlined
  • check and validate the information provided by the applicant on the application form/ continuation sheet
  • establish the true identity of the applicant through the examination of a range of documents as set out in this guidance
  • make sure the applicant provides details of all names by which they have been known
  • make sure the applicant provides details of all addresses where they have lived in the last five years
  • check that the application form is fully completed and the information it contains is accurate - failing to do this can result in delays

When checking the validity of the documents it is best practice to carry out this examination face-to-face. Other alternative methods include via a live video link, for example Skype and FaceTime. In both cases you must be in physical possession of the original documents. Any risks identified when using live video must be assessed and mitigated by you if implementing this practice. You must not rely on the inspection of the documents via a live video link, or by checking a faxed or scanned copy of the document.

If there are any discrepancies in the information provided by the applicant and/or the identity documents supplied, and fraud is not suspected, please ask the applicant to clarify. If you don’t do this it may compromise the integrity of the DBS service and introduce risk to your recruitment or licensing arrangements.

As an employer you must not attempt to amend the application form without the applicant’s knowledge and agreement. Doing this will invalidate the declaration by the applicant and may breach data protection legislation.

What you must do as part of the ID checking process

  • You must only accept valid, current, and original documentation
  • You must not accept photocopies
  • You must not accept documentation printed from the internet e.g. internet bank statements
  • Identity information for the applicant’s name, date of birth, and address recorded in section A and section B on the DBS application form must be validated
  • You should, in the first instance, seek documents with photographic identity (e.g. passport, new style driving licence, etc.) and for this to be compared against the applicant’s likeness
  • All documents must be in the applicant’s current name as recorded in section A
  • One document must confirm the applicant’s date of birth as recorded in section A
  • You must ensure that the applicant declares all previous name changes, and provides documentary proof to support the change of name; if the applicant is unable to provide proof to support the change of name, you should hold a probing discussion with the applicant about the reasons why, before considering to validate their identity
  • You must see at least one document to confirm the applicant’s current address as recorded in section B, in accordance with the guidance
  • You must provide a full and continuous address history covering the last five years - where possible you should seek documentation to confirm this address history
  • You should cross-match the applicant’s address history with any other information you have been provided with as part of the recruitment, such as their CV; this can highlight if an address has not been given e.g. if the applicant’s CV shows that they have worked in Liverpool in the last five years, but the application form only shows London addresses, you may wish to question the applicant further about this
  • A document from each of the groups should be included only once in the document count, for example, don’t accept two bank statements as two of the required documents, if they are from the same bank
  • You should not accept the foreign equivalent of an identity document if that document is listed as ‘(UK)’ on the list of valid identity documents

The documents needed will depend on the route the application takes. The applicant must try to provide documents from Route 1 first.

It’s important to note that a DBS check does not provide evidence of a person’s right to work in the UK. You must do a separate check to make sure a job applicant is allowed to work in the UK which also includes roles for voluntary work.

If the applicant isn’t a national of the UK, they must use a different route to apply for paid work in the UK. They can use Route 1 for voluntary work.

Route 1

The applicant must be able to show:

  • one document from Group 1, below
  • two further documents from either Group 1, or Group 2a, or 2b, below

At least one of the documents must show the applicant’s current address.

If the applicant isn’t a national of the UK and is applying for voluntary work, they may need to be fingerprinted if they can’t show these documents.

Route 2

Route 2 can only be used if it’s impossible to process the application through Route 1.

If the applicant isn’t a national of the UK and is applying for voluntary work they can’t use Route 2.

If the applicant doesn’t have any of the documents in Group 1, then they must be able to show:

  • one document from Group 2a
  • two further documents from either Group 2a or 2b

At least one of the documents must show the applicant’s current address. The organisation conducting their ID check must then also use an appropriate external ID validation service to check the application.

Route 3

Route 3 can only be used if it’s impossible to process the application through Routes 1 or 2.

For Route 3, the applicant must be able to show:

  • a birth certificate issued after the time of birth (UK, Isle of Man and Channel Islands)
  • one document from Group 2a
  • three further documents from Group 2a or 2b

At least one of the documents must show the applicant’s current address. If the applicant can’t provide these documents they may need to be fingerprinted.

Unusual addresses

The applicant must make sure they fill in the address part of the form correctly if they have an unusual address, for example if they live abroad, in student accommodation or a hostel.

Group 1: Primary identity documents

Document Notes
Passport Any current and valid passport
Biometric residence permit UK
Current driving licence photocard - (full or provisional) UK, Isle of Man, and Channel Islands. From 8 June 2015, the paper counterpart to the photocard driving licence will not be valid and will no longer be issued by DVLA
Birth certificate - issued within 12 months of birth UK, Isle of Man, and Channel Islands - including those issued by UK authorities overseas, for example embassies, High Commissions and HM Forces
Adoption certificate UK and Channel Islands

Group 2a: Trusted government documents

Document Notes
Current driving licence photocard - (full or provisional) All countries outside the UK (excluding Isle of Man and Channel Islands)
Current driving licence (full or provisional) - paper version (if issued before 1998) UK, Isle of Man, and Channel Islands
Birth certificate - issued after time of birth UK, Isle of Man, and Channel Islands
Marriage/civil partnership certificate UK and Channel Islands
Immigration document, visa, or work permit Issued by a country outside the UK. Valid only for roles whereby the applicant is living and working outside of the UK. Visa/permit must relate to the non-UK country in which the role is based
HM Forces ID card UK
Firearms licence UK, Isle of Man, and Channel Islands

All driving licences must be valid.

Group 2b: Financial and social history documents

Documents Notes Issue date and validity
Mortgage statement UK Issued in last 12 months
Bank or building society statement UK and Channel Islands Issued in last 3 months
Bank or building society statement Countries outside the UK Issued in last 3 months - branch must be in the country where the applicant lives and works
Bank or building society account opening confirmation letter UK Issued in last 3 months
Credit card statement UK Issued in last 3 months
Financial statement, for example pension or endowment UK Issued in last 12 months
P45 or P60 statement UK and Channel Islands Issued in last 12 months
Council Tax statement UK and Channel Islands Issued in last 12 months
Letter of sponsorship from future employment provider Non-UK only - valid only for applicants residing outside of the UK at time of application Must still be valid
Utility bill UK - not mobile telephone bill Issued in last 3 months
Benefit statement, for example Child Benefit, pension UK Issued in last 3 months
Central or local government, government agency, or local council document giving entitlement, for example from the Department for Work and Pensions, the Employment Service, HMRC UK and Channel Islands Issued in last 3 months
EEA National ID card Must still be valid
Irish Passport Card Cannot be used with an Irish passport Must still be valid
Cards carrying the PASS accreditation logo UK, Isle of Man, and Channel Islands Must still be valid
Letter from head teacher or college principal UK - for 16 to 19 year olds in full time education - only used in exceptional circumstances if other documents cannot be provided Must still be valid

Applicants who aren’t a national of the UK

An applicant who wants to do paid work and isn’t a national of the UK must be able to show:

  • one primary document
  • two supporting documents

If an applicant is unable to provide this documentation they can’t submit a DBS check. This is because the right to work in the UK can’t be established. They can’t use any other route.

Applicants for voluntary work who aren’t UK nationals must use Route 1.

Non-UK nationals who are eligible for a DBS check and receiving payment for work, even if it is an allowance, for example a foster carer, must use the paid work route.

However, Route 1 can be used by adult household members:

  • in a fostering household
  • in a child-minding household
  • in a host family
  • living where ‘work with children’ takes place, for example, living in a boarding school

Documents for non-UK nationals doing paid work

The documents must be originals, not copies.

At least one of the documents from either the primary or supporting documents lists must show the applicant’s current address.

The primary document list contains the range of documents you may accept for a person who has a permanent or temporary right to work in the UK. More detailed information about how to check an individual’s right to work can be found here.

Primary Documents

A current passport or passport card showing that the holder is a national of Ireland.

A current document issued by the Home Office to a family member of an EEA or Swiss citizen, and which indicates that the holder is permitted to stay in the United Kingdom indefinitely.

A current Biometric Immigration Document (Biometric Residence Permit) issued by the Home Office to the holder indicating that the person named is allowed to stay indefinitely in the UK, or has no time limit on their stay in the UK.

Online evidence of immigration status. Either via the View and Prove service or using the BRP or BRC online service. Issued by the Home Office to the employer or prospective employer, which indicates that the named person may stay in the UK and is permitted to do the work in question. Must be valid. Note: this includes the EUSS digital status confirmation.

A current passport endorsed to show that the holder is exempt from immigration control, is allowed to stay indefinitely in the UK, has the right of abode in the UK, or has no time limit on their stay in the UK.

A current Immigration Status Document issued by the Home Office to the holder with an endorsement indicating that the named person is allowed to stay indefinitely in the UK or has no time limit on their stay in the UK, together with an official document giving the person’s permanent National Insurance number and their name issued by a government agency or a previous employer.

A current passport endorsed to show that the holder is allowed to stay in the UK and is currently allowed to do the type of work in question.

A current Biometric Immigration Document (Biometric Residence Permit) issued by the Home Office to the holder which indicates that the named person can currently stay in the UK and is allowed to do the work in question.

A current document issued by the Home Office to a family member of an EEA or Swiss citizen, and which indicates that the holder is permitted to stay in the United Kingdom for a time limited period and to do the type of work in question.

A frontier worker permit issued under regulation 8 of the Citizens’ Rights (Frontier Workers) (EU Exit) Regulations 2020.

A current Immigration Status Document containing a photograph issued by the Home Office to the holder with a valid endorsement indicating that the named person may stay in the UK, and is allowed to do the type of work in question, together with an official document giving the person’s permanent National Insurance number and their name issued by a government agency or a previous employer.

A document issued by the Home Office showing that the holder has made an application for leave to enter or remain under Appendix EU to the immigration rules on or before 30 June 2021 together with a Positive Verification Notice from the Home Office Employer Checking Service.

An Application Registration Card issued by the Home Office stating that the holder is permitted to take the employment in question, together with a Positive Verification Notice from the Home Office Employer Checking Service.

A Positive Verification Notice issued by the Home Office Employer Checking Service to the employer or prospective employer, which indicates that the named person may stay in the UK and is permitted to do the work in question.

Supporting documents

The applicant must be able to show two documents from any of these groups.

Group 1

Document Notes
Passport Any current and valid passport
Biometric residence permit UK
Current driving licence photocard - (full or provisional) UK, Isle of Man, and Channel Islands
Birth certificate - issued within 12 months of birth UK, Isle of Man, and Channel Islands - including those issued by UK authorities overseas, for example embassies, High Commissions and HM Forces
Adoption certificate UK and Channel Islands

A passport or biometric residence permit can only be used as a supporting document if it’s not already been used as a primary document.

Group 2a

Document Notes
Current driving licence photocard - (full or provisional) All countries outside the UK (excluding Isle of Man and Channel Islands)
Current driving licence (full or provisional) - paper version (if issued before 1998) UK, Isle of Man, and Channel Islands
Birth certificate - issued after time of birth UK, Isle of Man, and Channel Islands
Marriage/civil partnership certificate UK and Channel Islands
Immigration document, visa, or work permit (for applicants living and working outside the UK) Issued by the country where the role is based
HM Forces ID card UK
Firearms licence UK, Isle of Man, and Channel Islands

All driving licences must be valid.

Group 2b

Documents Notes Issue date and validity
Mortgage statement UK Issued in last 12 months
Bank or building society statement UK and Channel Islands Issued in last 3 months
Bank or building society statement (for applicants living and working outside the UK) Countries outside the UK Issued in last 3 months - branch must be in the country where the applicant lives and works
Bank or building society account opening confirmation letter UK Issued in last 3 months
Credit card statement UK Issued in last 3 months
Financial statement, for example pension or endowment UK Issued in last 12 months
P45 or P60 statement UK and Channel Islands Issued in last 12 months
Council Tax statement UK and Channel Islands Issued in last 12 months
Letter of sponsorship from future employment provider Non-UK only - valid only for applicants residing outside of the UK at time of application Must still be valid
Utility bill UK - not mobile telephone bill Issued in last 3 months
Benefit statement, for example Child Benefit, pension UK Issued in last 3 months
Central or local government, government agency, or local council document giving entitlement, for example from the Department for Work and Pensions, the Employment Service, HMRC UK and Channel Islands Issued in last 3 months
EEA National ID card Must still be valid
Cards carrying the PASS accreditation logo UK, Isle of Man, and Channel Islands Must still be valid
Letter from head teacher or college principal UK - for 16 to 19 year olds in full time education - only used in exceptional circumstances if other documents cannot be provided Must still be valid

The ID checking information is available on the DBS website www.gov.uk/dbs or ID checking guidelines

Volunteer Applications:

The DBS definition of a volunteer is defined in the Police Act 1997 (criminal records) Regulations 2002 as:

“Any person engaged in an activity which involves spending time, unpaid (except for travel and other approved out-of-pocket expenses), doing something which aims to benefit some third party and not a close relative.”

To qualify for a free-of-charge criminal record check, the applicant must not benefit directly from the position the DBS application is being submitted for. The applicant must not:

  • benefit directly from the position for which the DBS application is being submitted
  • receive any payment (except for travel and other approved out-of-pocket expenses)
  • be on a work placement
  • be on a course that requires them to do this job role
  • be in a trainee position that will lead to a full-time role/qualification

An example of an ineligible volunteer role is ….

Medical/teaching/social work student on work placement, as part of training – this activity is a mandatory course requirement, is usually paid and is primarily undertaken to benefit the student.

Volunteer guidance from the DBS

To enable your applications to be processed faster, here are a few areas that will speed up your application:

  • workforce selected is incorrect
  • if a barring list is requested please make sure it is for the appropriate workforce
  • other forename(s) not completed - you must make sure that all forenames are included on the application
  • surnames - dates of previous surnames should not overlap
  • job titles not sufficient i.e. an application cannot be processed with just the title 'Volunteer' please state type of role the volunteer will be undertaking - please refer to the definition of 'volunteer' roles above.
  • Ms is entered in the title field - the system will recognise this as the applicant having a change of surname and ask for further information.  If the applicant has not had a change of name please enter name at date of birth and include the birth date from birth to the date of the application
  • first line of the applicants address needs to show the house number and the name of the road, do not enter these details on the 1st and 2nd line of the address fields
  • Post Code - entered in capitals and a space is included in the post code - ie S40 1JY
  • Driving licence details must be entered exactly as the driving licence number, some problems occur when the applicant has not entered a middle name/s on the application, but a middle name is shown on the driving licence number.

Here are a number of useful resources for employers using the ARC Disclosure Service for DBS checks (England and Wales)

Privacy Policies - DBS:

You can access all the DBS Privacy Policies here - DBS Privacy Policies

Guides for Employers:

Nacro has a publication 'Recruiting safely and fairly - a practical guide to employing ex-offenders'.  The practical guide is aimed at employers and recruiters of paid or voluntary staff to help them to understand their legal rights and responsibilities and good practice when employing staff with criminal records.  The guide outlines how to implement fair, safe and responsible policies and practices for employing ex-offenders, based upon a full understanding and assessment of risks involved.

If you have an employee who needs to complete a paper application, or they do not have access to a computer and the application is being completed by the employer in the presence of the employee, you must ask them to read the DBS Applicant Consent - Paper Applications - Aug 18 v1.1 form and sign to authorise the use of their personal data.

CQC Guidance - Disclosure and Barring Service checks v6

DBS Standard Eligibility Guidance

DBS Code of Practice - November 2015

Rehabilitation of Offenders Act 1974

Policy templates for ex-offenders (English & Welsh)

Safeguarding Vulnerable Groups Act 2006

SVGA Amended Schedule 4 - Parts 2 & 3

Barring Referral Guidance

DBS Reprint Guidance

DBS Guidance Leaflets

Regulated Activity - Children:

DBS Child Workforce Guidance

DBS Checks for Childcare Providers

Regulated activity in relation to children: Scope

Early Years Childcare

Regulated Activity - Adults:

DBS Adult Workforce Guidance

Regulated Activity - Adults - POFA 2012

 

Home Based Guidance:

DBS Home Based Position Flowchart

DBS Home Based Position Guidance

Volunteer Role Guidance:

Volunteer Roles DBS Guidance

Other Workforce Guidance:

DBS Other Workforce Guidance

ID checking guidance:

ID Checking Guidelines from 1st July, 2021

Documents Applicants need for ID

You can also find more information on the GOV.UK website page Guidance for Employers

The information provided on this website is for information purposes only. This information is only valid on the day of publication and does not constitute legal, professional, or commercial advice. Whilst every care has been taken to ensure that the content is up to date, useful and accurate, Association for Real Change gives no guarantees, undertakings, or warranties in this regard, or, for any loss or damage caused arising directly or indirectly in connection with reliance on the use of such information.