Safe Recruitment and DBS Policy
Official School Policy Document
Safer Recruitment and DBS Policy
Policy Owner: Directors / Senior Leadership Team
Approved by: Directors of SV Academy
Date Approved: September 2026
Last Reviewed: September 2026
Next Review: September 2027, or earlier if statutory guidance or legislation changes
1. Statement of Intent
SV Academy is committed to safeguarding and promoting the welfare of children and young people and expects all staff, volunteers, contractors, agency workers and other adults working on behalf of the Academy to share this commitment.
The purpose of this policy is to establish robust safer recruitment procedures which:
- attract appropriately qualified and suitable applicants;
- deter individuals who may be unsuitable to work with children and young people;
- identify and reject applicants who are unsuitable to work with children;
- ensure that all required pre-employment and safeguarding checks are completed;
- promote a culture in which safeguarding is considered throughout recruitment and throughout employment; and
- ensure recruitment decisions are fair, transparent, consistent and properly recorded.
Safeguarding is a central part of recruitment at SV Academy and is not limited to the completion of a Disclosure and Barring Service (DBS) check.
2. Scope
This policy applies, as appropriate, to:
- permanent and temporary staff;
- teaching and non-teaching staff;
- senior leaders and managers;
- agency and supply staff;
- trainee teachers;
- volunteers;
- contractors and self-employed individuals;
- consultants;
- directors and members of the proprietor body where relevant; and
- any other person whose role brings them into contact with children or young people at SV Academy.
3. Statutory and Regulatory Framework
This policy has been prepared with regard to current legislation and statutory guidance, including:
- Keeping Children Safe in Education 2026 (KCSIE);
- Working Together to Safeguard Children;
- the Education (Independent School Standards) Regulations 2014, where applicable;
- the Safeguarding Vulnerable Groups Act 2006;
- the Police Act 1997;
- the Rehabilitation of Offenders Act 1974 and the Exceptions Order 1975;
- the Equality Act 2010;
- the Immigration, Asylum and Nationality Act 2006;
- the Data Protection Act 2018, UK GDPR and the Data (Use and Access) Act 2025;
- the DBS Code of Practice;
- the Teachers' Disciplinary (England) Regulations 2012; and
- relevant Home Office, Department for Education and Disclosure and Barring Service guidance.
SV Academy will review this policy whenever relevant legislation or Department for Education guidance changes.
4. Responsibilities
The Directors of SV Academy have overall responsibility for ensuring that appropriate safer recruitment arrangements are in place.
Those involved in recruitment will understand their responsibilities under this policy and current statutory guidance. Those substantially involved in recruitment should have completed appropriate safer recruitment training, the substance of which should as a minimum cover Part Three of KCSIE.
Where reasonably practicable, recruitment and appointment decisions will involve more than one appropriately authorised person.
5. Planning a Recruitment Exercise
Before a post is advertised, SV Academy will establish:
- the responsibilities and duties of the role;
- the qualifications, skills, experience and behaviours required;
- the extent of contact with children and young people;
- whether the role involves regulated activity;
- the appropriate level of DBS check;
- whether a children's barred list check is required and legally available;
- whether a teacher prohibition check is required;
- whether a Section 128 check is required;
- whether additional overseas checks may be required; and
- the safeguarding responsibilities associated with the role.
The job description and person specification will clearly identify the safeguarding responsibilities of the post.
6. Advertising Vacancies
All advertisements will make clear SV Academy's commitment to safeguarding. Advertisements will normally contain wording substantially similar to:
SV Academy is committed to safeguarding and promoting the welfare of children and young people and expects all staff and volunteers to share this commitment. Appointment will be subject to appropriate safeguarding and pre-employment checks, including an enhanced Disclosure and Barring Service check where applicable.
Advertisements and recruitment information will also make clear the safeguarding responsibilities of the role, that safeguarding checks will be undertaken, whether the role involves regulated activity and, where appropriate, the role's status under the Rehabilitation of Offenders Act 1974 and Exceptions Order 1975.
7. Information Provided to Applicants
Applicants will be provided with, or directed to:
- the job description;
- the person specification;
- information about SV Academy;
- the Child Protection and Safeguarding Policy;
- this Safer Recruitment and DBS Policy;
- information about the selection process; and
- the Academy's policy or statement concerning the recruitment of ex-offenders.
Where the role involves regulated activity, applicants will be informed that it is an offence for a person who is barred from regulated activity with children to apply for such a role.
8. Application Forms
SV Academy will require applicants to complete an appropriate application form. A curriculum vitae may accompany an application, but a CV on its own will not normally be accepted as a substitute for a completed application form.
Applicants will normally be required to provide:
- personal details, including current and former names and current contact details;
- details of present or most recent employment and the reason for leaving;
- a full employment history since leaving education, including education, employment and relevant voluntary work, with reasons for gaps;
- qualifications, awarding bodies and dates of award;
- details of appropriate referees; and
- information demonstrating how they meet the requirements of the role.
9. Shortlisting
Shortlisting will be carried out against the requirements contained within the person specification. At least two people should carry out the shortlisting exercise wherever reasonably practicable.
Those shortlisting candidates will identify and consider gaps in employment, unexplained changes in employment or location, inconsistencies between different parts of the application, and any information requiring clarification at interview. Reasons for selection decisions will be recorded.
10. Self-Declaration by Shortlisted Candidates
Once shortlisted, candidates will be asked to complete an appropriate criminal-record and safeguarding self-declaration before interview. The declaration will request only information that SV Academy is legally entitled to obtain.
Depending on the role and legal entitlement, the declaration may cover relevant criminal history, children's barred list status, prohibition from teaching, prohibition from participation in management, relevant overseas information, childcare disqualification where applicable, and other information which may make an individual unsuitable to work with children.
Candidates will not be required to disclose protected convictions or cautions which they are not legally required to disclose. The declaration will be considered alongside the candidate's application and may be discussed at interview.
11. Online Searches
As part of safeguarding due diligence, SV Academy will consider carrying out a proportionate online search on shortlisted candidates using publicly available information. Shortlisted candidates will be informed that online searches may be undertaken.
Any search will focus on information relevant to the candidate's suitability to work with children or to fulfil the role, will not be used to unlawfully discriminate, and will be handled in accordance with data-protection and equality requirements. Any material concern identified will normally be discussed with the candidate and considered in context before a recruitment decision is made.
12. References
References are an important safeguarding check and are not treated merely as confirmation of employment. Where possible, references will be obtained before interview so that issues can be explored during the selection process.
SV Academy will normally obtain at least two satisfactory references before confirming an appointment.
References will:
- be requested directly by SV Academy from the referee;
- not be accepted where supplied directly by the candidate as an open reference or testimonial;
- normally include the applicant's current or most recent employer;
- where relevant, include the employer from the applicant's most recent period of work with children;
- be obtained from an appropriately senior person with authority to provide the reference;
- be verified as originating from a legitimate source;
- be checked against information contained in the application; and
- be followed up where information is unclear, incomplete or inconsistent.
Referees will be asked to provide factual information concerning the applicant's suitability to work with children and any relevant substantiated safeguarding concerns or disciplinary matters which may properly be disclosed. Unsubstantiated, unfounded, false or malicious allegations will not be requested or treated as substantiated safeguarding information.
Any discrepancy between a reference and the candidate's application will be explored and satisfactorily resolved before an appointment is confirmed.
13. Selection and Interview
All shortlisted candidates will normally participate in an interview. Interviews may take place in person or, where appropriate, through a secure live video platform.
Interviewers will use structured questions and will assess both professional suitability and safeguarding suitability. Candidates may be asked to:
- explain gaps in employment or education history;
- explain frequent changes in employment or location;
- explain discrepancies identified during the recruitment process;
- discuss their motivation for working with children;
- demonstrate an understanding of safeguarding and appropriate professional boundaries;
- respond to relevant safeguarding scenarios;
- explain information identified through references or online searches; and
- demonstrate their suitability for the specific role.
Where appropriate, candidates may also undertake teaching observations, presentations, written tasks, practical exercises or appropriately supervised interaction with pupils or students. Recruitment decisions and the reasons for them will be recorded.
14. Conditional Offers of Employment
Offers of employment will be conditional upon satisfactory completion of all checks applicable to the role. An appointment will not be confirmed until SV Academy is satisfied that the candidate is suitable for the role.
Depending on the position, checks may include:
- verification of identity;
- the appropriate DBS check;
- a children's barred list check where legally permitted and required;
- satisfactory references;
- right-to-work checks;
- verification of qualifications;
- teacher prohibition checks;
- Section 128 checks where applicable;
- appropriate overseas checks;
- childcare disqualification checks where applicable;
- confirmation of professional registration where applicable; and
- confirmation, following a conditional offer where appropriate, that the individual has the physical and mental capacity to undertake the duties of the role in accordance with employment and equality legislation.
15. Identity Checks
SV Academy will verify the identity of successful applicants against appropriate original or approved identity documentation and will consider previous names or changes of name where relevant to safeguarding checks. Identity information must be consistent with the information used for DBS, right-to-work and other safeguarding checks.
16. Disclosure and Barring Service Checks
SV Academy will obtain the level of DBS check appropriate to the role and only where the role is legally eligible for that level of check.
Staff engaged in regulated activity with children will normally require an enhanced DBS check including children's barred list information. An enhanced DBS check without barred list information may be appropriate for certain roles involving contact with children that do not amount to regulated activity. SV Academy will not request barred list information where it is not legally entitled to do so.
17. DBS Update Service
Where an applicant is subscribed to the DBS Update Service, SV Academy may undertake a status check where the certificate is for the same workforce, the level and type of DBS check are appropriate for the new role, any barred-list information required for the role is covered, the applicant gives appropriate consent, and the original certificate is examined as required.
Use of the Update Service does not remove the Academy's responsibility to undertake all other safer recruitment checks.
18. Starting Work Before DBS Clearance
As a general principle, SV Academy will seek to complete all required checks before an individual starts work.
Where the law permits an individual to start before receipt of the DBS certificate, this will only occur exceptionally following a documented safeguarding risk assessment. All other required checks must have been completed and any separate barred-list check that is required and legally available must be completed before the person undertakes regulated activity. Appropriate supervision arrangements must be established and recorded.
Where the legal status of the provision or the role requires the enhanced DBS certificate with barred list information to be obtained before regulated activity begins, the individual will not commence that activity until the required check has been received.
19. Regulated Activity and Volunteers
SV Academy will determine whether staff and volunteer roles constitute regulated activity in accordance with current legislation and KCSIE.
From 1 September 2026, changes to regulated activity brought into force by the Crime and Policing Act 2026 mean that some volunteers who teach, train, instruct or supervise children and meet the statutory frequency conditions may be in regulated activity even where they are supervised. SV Academy will review volunteer roles against the current legal definition.
Where a volunteer is engaged in regulated activity, the required enhanced DBS check including children's barred-list information will be obtained. Existing volunteers whose role became regulated activity as a consequence of the September 2026 change will be reviewed and the required checks undertaken.
Volunteers who are not engaged in regulated activity will be subject to a written risk assessment to determine what checks and supervision are appropriate. Under no circumstances will a volunteer on whom no appropriate checks have been obtained be left unsupervised in a role that amounts to regulated activity.
20. Teacher Prohibition Checks
Where an individual is appointed to carry out teaching work, SV Academy will undertake the appropriate check to establish whether the individual is prohibited from teaching. Checks will be made through the appropriate Department for Education service or other authorised route and recorded where required.
21. Section 128 Checks
Where applicable to SV Academy's legal status and to the role concerned, individuals appointed to management positions will be checked to ensure that they are not subject to a Section 128 direction prohibiting or restricting them from participating in the management of an independent educational setting.
The responsibilities of the individual, rather than job title alone, will determine whether a Section 128 check is required. Details and dates will be recorded on the Single Central Record where required.
22. Right to Work in the UK
Before employment begins, SV Academy will obtain evidence that the individual has the legal right to work in the United Kingdom in accordance with current Home Office requirements. Where a person's right to work is time-limited, appropriate follow-up checks will be undertaken before permission expires.
23. Qualifications and Professional Status
Original certificates, appropriate electronic verification or confirmation directly from the relevant professional or awarding organisation will be used where qualifications are essential to the role.
For teaching roles, the appropriate Department for Education service will be used where necessary to verify Qualified Teacher Status, relevant induction or professional status, and teaching restrictions or prohibitions.
24. Health and Fitness
SV Academy must be satisfied that an individual has the physical and mental capacity to carry out the responsibilities of the role. Any health enquiries will be undertaken at the appropriate stage of recruitment and handled in accordance with the Equality Act 2010. Health or disability information will not be used to unlawfully discriminate, and reasonable adjustments will be considered where appropriate.
25. Applicants Who Have Lived or Worked Outside the UK
A UK DBS check does not normally provide a complete criminal-record history for periods spent outside the United Kingdom. Where an applicant has lived or worked overseas, SV Academy will consider what additional checks are appropriate according to the country, length and nature of the period overseas, the role and the information reasonably available.
Additional checks may include:
- overseas criminal-record checks;
- certificates of good conduct or police-clearance certificates;
- verification through the relevant authority, embassy or consulate;
- additional employment references;
- verification of overseas employment or professional history; and
- certified translations where documentation is not in English.
An overseas criminal-record check does not replace the requirement for an appropriate UK DBS check where one is required.
Where an overseas check cannot be obtained, SV Academy will record the checks attempted, why the information could not be obtained, the alternative evidence considered and the safeguarding risk assessment and decision made. An appointment will not proceed where sufficient information cannot be obtained to satisfy SV Academy that the individual is suitable to work with children.
26. Agency and Supply Staff
Where SV Academy uses agency or third-party staff, it will obtain written confirmation from the supplying organisation that all appropriate recruitment and safeguarding checks have been completed, including the appropriate DBS and other checks required for the role.
SV Academy will verify the person's identity on arrival. Where information has been disclosed on a DBS certificate, the Academy will ensure it has received and considered the relevant information before the individual starts work. Required information will be recorded on the Single Central Record.
27. Contractors and Self-Employed Persons
SV Academy will ensure that contractors working at the Academy have undergone checks appropriate to the nature of their work and their level of contact with children. Where an organisation supplies a contractor, SV Academy will obtain appropriate written confirmation of checks. Self-employed people will be subject to appropriate checks determined by their role and legal eligibility.
Contractors will be required to provide proof of identity on arrival. No unchecked contractor will be permitted unsupervised access to children where this would create a safeguarding risk.
28. Single Central Record
SV Academy will maintain an accurate Single Central Record (SCR) of required recruitment and safeguarding checks.
The SCR will record, as applicable:
- identity checks;
- enhanced DBS checks;
- children's barred-list checks;
- teacher prohibition checks;
- right-to-work checks;
- relevant overseas checks;
- professional qualification checks;
- Section 128 checks;
- agency and third-party confirmations; and
- the date each required check was completed or certificate obtained.
The SCR will include all individuals whom current legislation or statutory guidance requires to be included. It will be reviewed and audited regularly and will be available for inspection.
29. Recruitment of Ex-Offenders
SV Academy is committed to equality of opportunity and to the fair treatment of applicants. Having a criminal record will not automatically prevent an individual from being considered for employment.
SV Academy will only ask for criminal-record information that it is legally entitled to know about. Information disclosed will be considered proportionately, taking account of the nature and seriousness of the offence, relevance to the position, time elapsed, circumstances, any pattern of offending, evidence of rehabilitation, the applicant's explanation and the Academy's safeguarding responsibilities.
Applicants will not be required to disclose convictions or cautions that are protected under current filtering legislation. SV Academy will comply with the DBS Code of Practice and make its policy on the recruitment of ex-offenders available to applicants on request.
30. Information Disclosed on a DBS Certificate
Information disclosed on a DBS certificate will not automatically result in withdrawal of an offer. It will be considered by an appropriately authorised senior person and discussed with the applicant where relevant.
Before a conditional offer is withdrawn because of disclosed information, SV Academy will normally give the applicant an opportunity to explain the circumstances, consider the relevance of the information to the role, assess the safeguarding risk and record the decision and rationale. Safeguarding children will remain the overriding consideration.
31. Handling and Storage of DBS Information
DBS and other safeguarding information will be handled securely and confidentially, with access limited to individuals who have a legitimate need to see it. SV Academy will comply with the DBS Code of Practice, data-protection legislation, statutory record-retention requirements and the Academy's data-protection and records-management arrangements.
Copies of DBS certificates will not be retained for longer than is necessary or lawful. Where a copy is retained, there must be a valid reason and it will normally not be kept for longer than six months, in line with KCSIE and data-protection requirements.
32. Induction
Every new member of staff will receive safeguarding induction appropriate to their role. Induction will include, as applicable:
- SV Academy's Child Protection and Safeguarding Policy;
- the Staff Code of Conduct;
- behaviour and professional-boundary expectations;
- procedures for reporting safeguarding concerns;
- allegations and low-level concerns procedures;
- whistleblowing arrangements;
- the identity and role of the Designated Safeguarding Lead and deputies;
- online safety;
- Prevent responsibilities;
- attendance and child-welfare procedures; and
- other relevant safeguarding policies.
In accordance with KCSIE 2026, all staff will be expected to read Part One of Keeping Children Safe in Education 2026 in full and to understand their safeguarding responsibilities.
33. Probation and Ongoing Safeguarding
Safer recruitment does not end when an employee is appointed. New staff will be appropriately supervised and supported during induction and any probationary period. Managers will remain alert to safeguarding, conduct and professional-boundary issues throughout employment.
Safeguarding concerns about members of staff will be dealt with under SV Academy's relevant safeguarding, allegations, low-level concerns, disciplinary and whistleblowing procedures.
34. Duty to Refer to the Disclosure and Barring Service
SV Academy will make a referral to the DBS where the statutory criteria for a referral are met. This may apply where a person is removed from regulated activity, or would have been removed had they not resigned or otherwise ceased working, because they harmed a child or placed a child at risk of harm and the relevant statutory conditions are satisfied.
A settlement agreement, resignation or departure from the organisation will not prevent SV Academy from fulfilling a legal safeguarding referral duty. Where appropriate, the Academy will also consider referral to other relevant bodies, including the Teaching Regulation Agency and the Local Authority Designated Officer, in accordance with current guidance.
35. Record Keeping
SV Academy will retain appropriate records demonstrating how recruitment decisions were made and that required safer recruitment processes were followed. Records may include application documents, shortlisting records, interview notes, references, online-search records where appropriate, risk assessments, check dates, recruitment decisions and evidence relating to conditional offers.
Records will be retained and disposed of in accordance with data-protection law and the Academy's records-management procedures.
36. Monitoring and Review
The Directors and Senior Leadership Team will monitor implementation of this policy. Recruitment records and the Single Central Record will be subject to periodic internal checks.
This policy will be reviewed at least annually and sooner if Keeping Children Safe in Education is amended, DBS or Home Office guidance changes, relevant legislation changes, an audit or inspection identifies improvements required, or a safeguarding incident indicates that recruitment procedures should be strengthened.
Key Reference Documents
This policy should be read alongside SV Academy’s Child Protection and Safeguarding Policy, Staff Code of Conduct and related safeguarding procedures. The principal external references are Keeping Children Safe in Education 2026, Working Together to Safeguard Children, the DBS Code of Practice and current GOV.UK guidance on DBS checks and the recruitment of ex-offenders.
Policy reviewed and revised: September 2026
Next scheduled review: September 2027