Before you register
Carrying out criminal records checks is just one part of a safer recruitment policy. For this reason, we only provide Disclosure Services to organisations that hold a current annual membership with us. Information on membership and how to join can be found here.
There are four important steps an organisation must complete before registering with our Disclosure service:
- Commit to following safer recruitment policies and procedures of which DBS checks is a part.
- Comply with all policies laid down by the Disclosure and Barring Service, including their Code of Practice, Equal Opportunities policies and those relating to the handling of criminal records information.
- Agree to our thirtyone:eight terms of service
- Recruiter declaration of suitability
1. Safer recruitment policies and procedures
A Disclosure and Barring Service check is only part (albeit an essential one) of a safer recruitment process. This process is crucial in preventing unsuitable or dangerous individuals gaining access to vulnerable groups. It includes the completion of a job application form, a self-declaration form, an interview, taking up references and a DBS check as well as the applicant’s agreement to abide by the organisation’s safeguarding policy. Operating a safer recruitment policy sends a powerful message to parents, children, visitors, as well as those intent on harm, that safeguarding is taken seriously in the organisation.
However, it is important to stress to applicants that having a criminal record should not necessarily bar the person from being appointed unless children or vulnerable adults would be put at risk. The scope of a DBS check must be explained to applicants, including the fact that strict confidentiality is observed. Information relating to the Rehabilitation of Offenders and Safe Storage policies should be made available for applicants to see. Importantly, individuals should also be asked to complete an application form and a self-declaration form before a check is applied for. This gives a person the opportunity to discuss any past issues which could emerge in a check. In such circumstances, advice can be given on whether or not information would prevent someone working with children or vulnerable adults. Where there is a ‘blemished’ disclosure, the information given by the applicant in a self-declaration can in some cases help in determining the outcome (for example, in assessing their honesty). If a past conviction is revealed on a certificate, we strongly advise that the Recruiter contact us so we can give advice in order to reach the appropriate employment decision.
Full details of the Safer Recruitment process can be found here.
2. Comply with DBS policy
As an organisation you must agree to formally adopt a policy on the fair treatment of all applicants. Our model Equal Opportunities Statement can be a good place to start.
An organisation must also adopt a policy on the handling and safe keeping of information and agree to work within the DBS Code of Practice. These documents should be formally adopted and kept securely. The DBS expectations have the force of law, which means that if DBS policies are not complied with, applicants might have a valid case for formal complaint.
We will register an organisation if it is still working on these documents at the point application is made to join our service; however, they must have been formally adopted and available to applicants before the Recruiter begins to process checks for workers.
3. Agree to follow the Terms of Service
The purpose of this agreement between thirtyone:eight and your organisation is to set out the terms under which both parties will agree to comply when handling personal information during the DBS disclosure process. This agreement is made on the date your completed registration form is received by thirtyone:eight and will commence at the same time. Unless the Agreement is specifically amended, altered or withdrawn it will be automatically agreed to have rolled over on the anniversary of your registration.
Umbrella Bodies cannot take a recruitment decision on the basis of information contained on a Disclosure Certificate unless the applicant will be directly working for the Umbrella Body. This Agreement recognises that the DBS provides one copy only of a Disclosure Certificate to the applicant. However, the applications submitted online via the Ebulk system enables thirtyone:eight to know when a Disclosure Certificate has been issued and whether there is any information in that certificate. Thirtyone:eight will provide relevant information to your organisation. It is the responsibility of those organisations processing applications to track the progress and see every result.
This agreement is based on the following assumptions:
- An employer/organisation has approached thirtyone:eight to assist with the processing of a DBS disclosure applications
- The employer/organisation requires Basic, Standard or Enhanced disclosures for individuals who they may seek to recruit
- The Umbrella Body/employer has established that there is a legal entitlement to request Standard / Enhanced disclosures from the Disclosure and Barring Service.
- The organisation agrees to meet our charges for services.
- That the information supplied in DBS Applications is correct.
Roles & Responsibilities
Thirtyone:eight as an Umbrella Body will;
- Make available the DBS Code of Practice to the employer / organisation
- Monitor that client organisations are complying with the DBS Code of Practice.
- Ensure there is a legal entitlement for the type of disclosure requested by the applicant
- Assist the organisation’s named Recruiters through the DBS Disclosure process.
- Ensure Disclosure Applications are countersigned properly
- Be the first point of contact with DBS on matters relating to Disclosure Applications submitted through them
- Gather any additional information request by the DBS to resolve any queries, they might have about the applicant's personal details or their role.
- Notify client organisations processing applications via Ebulk that a Disclosure Certificate has been issued by the DBS. The Lead Recruiter can then login to see the result as either ‘Certificate contains no information or ‘Please wait to view applicant certificate’. Where the status shows as ‘Please wait to view applicant certificate’ the organisation must ask the applicant to provide them with their copy of the Disclosure Certificate in order to view the information and progress to the next stage of the recruitment process. (Organisations submitting paper forms will need to view every certificate in order to determine if it contains any information.)
- Provide client organisations with guidance on secure handling and storage of information
In joining thirtyone:eight as a client organisation we will;
- Provide any information requested by thirtyone:eight to provide assurance that the position applied for meets the necessary legal entitlements for the type of Disclosure requested
- To take all reasonable steps to verify the identity of each applicant for Disclosure in line with current DBS requirements.
- Provide information that is accurate and complete to the best of your knowledge, and ensure that all applications satisfy the criteria laid down for Disclosures.
- Comply with provisions set out in DBS Code of Practice and by UK data protection legislation and GDPR.
- Have adopted policies for the recruitment of offenders and safe storage of informationin line with DBS expectations.
- Ensure the information on Disclosure Certificates provided by applicants is retained in a secure manner, accessible only by those with authority to see them. Details of non-court convictions, convictions, police information or barred list information should not be retained after the recruitment decision is made.
- Ensure that Disclosure information is not passed to persons not authorised to receive it
- Comply with recommendations made by the Umbrella Body
- Work with Thirtyone:eight exclusively as an umbrella organisation for the DBS Checks unless required to use the services of a regulatory authority (for example OFSTED) in relation to certain specific activities. Where this happens, Thirtyone:eight must be informed and be given the necessary contact details of the other umbrella organisation involved
- Inform Thirtyone:eight immediately of any breach of confidentiality or another requirement of the Disclosure and Barring Service. In such circumstances, the church/organisation understands that Thirtyone:eight would be required to inform the DBS of the situation.
- Inform Thirtyone:eight immediately when any Recruiter is no longer able to perform that role
- Meet the agreed Thirtyone:eight charges for the service (payment made by direct debit).
- Cooperate with Thirtyone:eight enquiries, investigations or compliance visits which may be required as an umbrella body.
- Terminate these arrangements by giving notice in writing.
- Notify Thirtyone:eight immediately in the event of changes that materially affect the ability of your church/organisation to meet any of these requirements.
- If the organisation is transferring to another umbrella body, a letter of resignation should be sent to Thirtyone:eight giving details of the new umbrella body and proposed date of transfer in order to meet DBS requirements.
4. Recruiter Declaration of suitability
In signing the Registration Form and/or New Recruiter Appointment Form you are confirming that your Lead Recruiter/Recruiter has no relevant unspent convictions, are not currently the subject of any criminal investigation or pending prosecution, and that there is no cause for concern regarding their honesty and integrity nor with their conduct with children, young people or adults at risk in the context of this role AND that if they become the subject of a criminal investigation, or a social services investigation the relevant person within your organisation will be informed with a view to assessing their continued ability to meet suitability for this role.
Authorisation and Agreement
By signing and completing the Disclosure Registration Form (or New Recruiter Appointment Form, if existing members) and submitting this to thirtyone:eight the Senior Leader and Lead Recruiter/Recruiter are agreeing to comply with the details of these terms.