What Is A DBS Policy And Do You Need One?

If your business is carrying out DBS Checks, you need to be sure you’re compliant with the DBS Code of Practice. The Code of Practice outlines the minimum requirements that the Disclosure and Barring Service (DBS) have for people handling DBS Check information.  

A big part of the Code of Practice is ensuring that you have the right policies in place, before you start carrying out DBS Checks. 

Do I need a DBS Policy? 

If you’re carrying out DBS Checks as part of your recruitment process, you need to have a DBS policy in place. 

This is the case whether you’re employing the applicant directly or if you’re recruiting via an agency.  

What is a DBS Policy?

An organisation’s overarching ‘DBS Policy’ should be made up of two separate documents. The first policy should outline how DBS data will be handled.  

Both DBS applications and certificates contain extensive amounts of personal information. This information is protected by the Data Protection Act 1998. Failing to handle DBS data correctly could lead to enforcement action from the Information Commissioner’s Office.  

You can find our guide on how to correctly manage DBS data here.  

The second policy needed is about the recruitment of ex-offenders. 

Any organisation carrying out DBS Checks must also have a written policy on how they will approach the recruitment of individuals who have a criminal record history. 

This is because all employers have a responsibility to treat DBS applicants who have a criminal record fairly and not discriminate automatically because of a conviction or other information revealed.

Is there an example DBS policy?

The DBS do provide a sample policy for the recruitment of ex-offenders. You can find it here.  

The sample policy is designed to be a starting point for firms, but it should be studied by your legal or HR team to ensure that it is suitable for your organisation.  

You should not simply copy and paste the DBS sample policy as it may not be applicable for your organisation.  

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