What GOV.UK actually offers #
There are four kinds of check.
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Basic
Shows unspent convictions and conditional cautions.
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Standard
Shows spent and unspent convictions and cautions.
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Enhanced
Shows the same as a standard check plus any information held by local police that is considered relevant to the role.
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Enhanced with barred lists
Adds whether the applicant is on the list of people barred from doing the role.
Scotland and Northern Ireland have their own arrangements.
Which check a given role is eligible for is a question about the role, and GOV.UK is where to settle it. We are not going to summarise eligibility on a consultancy website, because getting it wrong in either direction is somebody else's problem to live with.
The update service, and the bit that catches people out #
GOV.UK says the DBS update service costs £16 a year, that there is no charge for volunteers who meet its conditions, and that it covers standard and enhanced checks only. It lets an employer check the status of a certificate the applicant already holds.
The detail worth knowing is the renewal: the subscription runs for a year, and GOV.UK says that if it is not renewed before it expires, a new DBS check has to be applied for.
What CQC expects around it #
Regulation 19 requires providers to operate robust recruitment procedures including any relevant checks, to have a procedure for ongoing monitoring of staff so they remain able to meet the requirements, and to have arrangements for dealing with staff who are no longer fit.
The regulation is explicit that "person employed" covers volunteers and contractors as well as agency and bank staff, which is the part small services most often discover late.
The chase list behind one hire #
For a single care worker, a service is typically waiting on some combination of:
- Identity documents.
- Right to work evidence.
- The DBS application and its outcome.
- Two references, and the chasing of the referees who do not reply.
- Proof of training and qualifications.
- Care Certificate progress.
- A driving licence and business use insurance if the role needs a car.
- Occupational health where it applies.
- A start date that keeps moving because one of the above has not landed.
Multiply that by a sector with high turnover and it is not a recruitment problem, it is a tracking problem wearing a recruitment costume.
Which parts run on rules, and which do not #
Runs on rules
- A file that is missing a document a checklist says it must have
- A reference requested and not returned after a set number of days
- An update service subscription approaching its renewal date
- A start date arriving before the file is complete
- A training certificate or refresher whose expiry has passed
- An agency or bank worker on the rota with no evidence file held at all
All comparisons between a checklist and a folder. None of them requires an opinion, which is why they can be caught the same way every time.
A manager's job
- Deciding whether somebody is suitable
- Reading a disclosure and deciding what it means
- Weighing a lukewarm reference
- Judging whether a person remains fit for the role
- Making a risk assessment when something turns up
It should stay visibly a manager’s job, because it is exactly the kind of decision an inspection asks you to explain.
One data protection point #
Recruitment files in care hold criminal offence data, and the ICO lists large scale processing of personal data relating to criminal convictions and offences among the processing that requires a data protection impact assessment, to be carried out before the processing begins.
If a system is going to hold or move that data, the DPIA question comes before the software question. The ICO's page is linked below.
If you are weighing a hire against the alternative, the true cost of an employee calculator works from your own figures, and what CQC looks at covers where these files end up being read.