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Sample Data storage and handling policy, and Equal opportunities policy

Data Storage and handling

Northern Ireland - Handling, Use, Secure Storage, Retention & Disposal of Disclosures and Disclosure Information 

In consideration of our use of AccessNI, to help assess the suitability of applicants for positions of trust, we agree to comply with the AccessNI Code of Practice, Data Protection Act and other legislation in regard to the correct handling, use, storage, retention, and disposal of Disclosures and Disclosure information. 

General Principles  

As an organisation using AccessNI to help assess the suitability of applicants for positions of trust, [Organisation Name] complies fully with AccessNI’s Service Level Agreement regarding the correct handling, use, storage retention and disposal of Disclosure Applications and Disclosure information. We also comply fully with obligations under the Data Protection Act 2018, the UK GDPR and other relevant legislative requirements with regards to the safe handling, storage, retention and disposal of Disclosure Information. 


As we no longer receive a copy certificate from AccessNI, written consent will be obtained from the Applicant when requesting and retaining a (copy of a) Disclosure certificate.

Storage and Access  

Disclosure information is be kept securely, in lockable, non-portable, storage containers with access strictly controlled and limited to those who are entitled to see it as part of their duties.


In accordance with section 124 of the Police Act 1997, Disclosure information is only passed to those who are authorised to receive it in the course of their duties. We maintain a record of all those to whom Disclosures or Disclosure information has been revealed. We recognise it is a criminal offence to pass this information to anyone who is not entitled to receive it.


Disclosure information is only used for the specific purpose for which it was requested and for which the applicant’s full consent has been given.  


Once a recruitment (or other relevant appointment, regulatory or licensing) decision has been taken, we do not keep Disclosure information for any longer than is necessary. We comply with AccessNI’s Service Level Agreement to return the original Disclosure certificate to the applicant once a decision, recruitment or otherwise has been made and will be retained no longer than the agreed period.  


Once the retention period has elapsed, we will ensure that any Disclosure information is immediately destroyed by secure means ie by shredding, pulping or burning. While awaiting destruction, Disclosure information will not be kept in any unsecured receptacle (eg waste-bin or confidential sack). We will not keep any photocopy or other image of the Disclosure or any copy or representation of the contents of a Disclosure or any other relevant non-conviction information supplied by police. However, despite the above, we may keep a record of the date of issue of a Disclosure, the name of the subject, the type of Disclosure requested, the position for which the Disclosure was requested, the AccessNI unique reference number of the Disclosure Certificate and the details of the recruitment decision. 

As an organisation using Access Northern Ireland to help assess the suitability of applicants for positions of trust, (Organisation Name) complies fully with AccessNI’s Code of Practice regarding the correct handling, use, storage retention and disposal of Disclosure Applications and Disclosure information. We also comply fully with its obligations under the Data Protection Act 1998 and other relevant legislation pertaining to the safe handling, storage, retention and disposal of Disclosure information.

Equal opportunities

This policy has been drafted for a Christian care organisation and would need to be adapted to suit the needs of others e.g. a church or non-faith group

  1. This is a Christian organisation committed to social justice and resolutely opposed to discrimination in society. We are committed to providing services on a fair and equitable basis, regardless of race, ethnicity, religion, life-style, sex, sexuality, physical/mental disability, offending background or any other factor. No person requiring services from (name of organisation) will be treated less favourably than any other person on any grounds.
  2. In employment we actively seek to recruit with the right mix of talent, skills and potential, promoting equality for all, and welcome applications from a wide range of candidates. We select all candidates for interview based on their skills, qualifications, experience and commitment to the values and purposes of the organisation.
  3. As an organisation seeking to deliver services within a Christian context, some posts can only be filled by Christians. These posts are specified in the (state where) and kept under regular review. The nature of these posts or the context in which they are carried out, and their link to the ethos of the organisation, give rise to a genuine occupational requirement (GOR) for the post-holders to be Christians. All staff in these posts are required to demonstrate a clear personal commitment to the Christian faith. This policy is implemented in accordance with Employment and Race Directives issued by the government and The Labour Relations Agency (LRA) guidance.
  4. As an organisation using the AccessNI Disclosure Service to assess applicants’ suitability for positions of trust, the church/organisation undertakes to comply fully with the AccessNI Code of Practice and to treat all applicants for positions fairly. It undertakes not to discriminate unfairly against any personon the basis of a conviction or other information revealed.  
  5. A Disclosure is only requested if relevant for the position concerned. For those positions where a Disclosure is required, all application forms, job adverts and recruitment briefs will contain a statement that a Disclosure will be requested in the event of the individual being offered a position. 
  6. Where a Disclosure is to form part of a recruitment process, we encourage all applicants called for interview to provide details of any criminal record at an early stage in the application process. We request that this information is sent separately and in confidence to the Recruiter within the organisation and we guarantee that this information will only be seen by those who need to, as part of the recruitment process. 
  7. Unless the nature of the position allows questioning about your entire criminal record, we only ask about “unspent” convictions as defined in the Rehabilitation of Offenders Act and Rehabilitation of Offenders (Northern Ireland) Order 1978. (By definition thoseworking with children or vulnerable adults would be expected to disclose details of their full criminal history.) 
  8. We ensure that all those in the organisation who are involved in the recruitment process have been suitably trained to identify and assess the relevance of offences. We will also ensure that they have received appropriate guidance and training in the relevant legislation relating to the employment ofexoffenderse.g. the Rehabilitation of Offenders (Northern Ireland) Order.  
  9. At interview, or in separate discussion, we ensure that an open and measured discussion takes placeon the subject of anyoffences or other matter that might be relevant to the position. Failure to reveal information that is directly relevant to the position sought could lead to withdrawal of an offer of employment or voluntary work.  
  10. Every person under-going an AccessNI check will be made aware of the AccessNI Code of Practice and a copy will be available on request
  11. We undertake to discuss any matter revealed in a disclosure with the person seeking a position before withdrawing a conditional offer of employment. 
  12. Having a criminal record will not necessarily bar you from working with us. This will depend upon the nature of the position and the circumstances and background of your offences.
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