Disclosure And Barring Service Policy

Part A is the policy and procedures to be used by Sherman Cymru in case the results of a Disclosure and Barring Service (DBS) check raises concerns or issues about the appropriateness of the appointment being contemplated by the organisation. Part B is the section which includes and complies with the DBS Code of Practice regarding the correct handling, use, storage, retention and disposal of Disclosures and Disclosure information. This policy should be read and implemented in conjunction with the Sherman Cymru Children and Vulnerable Adults Protection Policy.

Part A1 - The Policy

Sherman Cymru takes the matter of safety for children and vulnerable adults extremely seriously and this policy is an extension of, and supports the Child Protection and Vulnerable Adults policy.

Where a concern or issue is raised by the results of a Disclosure and Barring Service (DBS) check the Executive Director will consult the Chair of the HR and Governance committee and if necessary the Chair of Sherman Cymru, to consider how to proceed.

The consideration will result in one of three following outcomes:

a) The applicant will be offered the post as the concerns are assessed as not being significant enough to not proceed with the appointment.

b) The applicant will be offered the post on the condition that they work alongside someone who will act in a supervisory capacity i.e. the concerns are assessed as being manageable.

c) The applicant will not be offered employment. If this is the outcome, the applicant will be informed of the reasons why employment is not being offered.

Part A2 - The Procedure

1. The DBS check is received by the Executive Director (or a member of the Senior Management Team as designated by the Executive Director) and is considered alongside the post that they have applied for.

2. The Executive Director (or Senior Management Team Member as appropriate) will assess the DBS check in terms of the risk associated with the applicant undertaking the duties required. Where the duties involve working with children or vulnerable adults the risk will be assessed in terms of the likely harm to, or endangerment of the client group. Where the DBS check identifies that the applicant has been subject to criminal charges or investigation relating to children or vulnerable adults, Sherman Cymru is extremely unlikely to proceed with the employment.

3. Where an offer of employment falls under category b or c above, the Executive Director (and or the Chair of the HR and Governance Committee) is to seek confidential advice from appropriate sources on and approval for the proposed course of action.

4. The DBS unique reference number, type of disclosure requested, name of employee and position, and the date when a re-check will be due (after 3 years) will be kept on a database by DBS trained Sherman Cymru administration staff. All other evidence, including the DBS check forms, will be shredded according to DBS guidelines.

5. Where an offer of employment is declined the Executive Director (or delegated member of the Senior Management Team) will confirm this in writing giving the reasons why the offer of employment will not be made.

Part B1 – The Policy

This section deals with the secure storage, handling, use, retention and disposal of disclosures and disclosure information.

As an organisation using the DBS Disclosure Service to help assess the suitability of applicants for positions of trust, the Sherman Cymru complies fully with the DBS Code, its obligations under the Data Protection Act and other relevant legislation pertaining to the safe handling, use, storage, retention and disposal of Disclosure information and this policy is available to those who wish to see it on request.

Part B2 - The Procedure

Storage and Access: Disclosure information is not to be kept on an applicant’s personnel file and is always kept separately and 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.

Handling: In accordance with section 124 of the Police Act 1997, Disclosure information is only passed to those who are authorized to receive it in the course of their duties.

Sherman Cymru will maintain a record of all those to whom Disclosures or Disclosure information has been revealed and Sherman Cymru recognises that it is a criminal offence to pass this information to anyone who is not entitled to receive it.

Usage: 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.

Retention: Once a recruitment (or other relevant) decision has been made, Sherman Cymru will not keep Disclosure information for any longer than is absolutely necessary, to allow for the consideration and resolution of any disputes or complaints.

If in very exceptional circumstances [note 1] it is considered necessary to keep Disclosure information for longer than six months, Sherman Cymru will consult the DBS about this and all relevant legislation and good practice.

Disposal: Once the retention period has elapsed, Sherman Cymru will ensure that any Disclosure information is immediately destroyed by secure means i.e. by shredding, pulping or burning.

While awaiting destruction, Disclosure information will not be kept in any insecure receptacle (e.g. waste bin or confidential waste sack).

Sherman Cymru will not keep any photocopy or other image of the Disclosure or any copy or representation of the contents of a Disclosure.

However, notwithstanding the above, Sherman Cymru will 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 unique reference number of the Disclosure and the details of the recruitment decision taken.

This policy and procedure will be reviewed by Sherman Cymru on an annual basis to ensure that it is working effectively.

NB. This policy and procedure have been drafted prior to Sherman Cymru becoming operational and the details (for example job titles) may change after 1st April 2007. May 2013



Agreed priorities for each department:

Creative Learning:

Staff - Enhanced

Youth Tutors - Enhanced

Education Tutors - Enhanced

Mentors (volunteers) - Enhanced

Production & Operations:

None needed in this dept.

Marketing & Customer Relations:

None needed in this dept.

Admin & Finance:

No need identified.


Being checked with Charity Commission

Work Experience Placements:

It isn't practical to DBS check everyone who may work with a work placement student. Clear guidelines on hours to be worked, lone working etc and carry out risk assessments, must be carried out for each placement.

Agreed Priorities:

Creative Learning dept.

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