Parish Responsibilities
The PCC and the incumbent are responsible for ensuring that all those appointed, whether paid or voluntary, to work with children, young people and vulnerable adults at risk of harm are safely recruited, trained, supported and supervised; DBS checks are a tool as part of a safer recruitment process available to organisations if the role is eligible. Please refer to the Safer Recruitment chapter of the Church of England’s Safeguarding Code of Practice in the e-manual. Failure to comply with the safer recruitment process, including obtaining a DBS check for eligible roles could put children, young people or vulnerable adults (as defined by the Care Act 2014) at risk of harm; it could also compromise the parish’s insurance cover and damage the reputation of the wider church. It would also constitute a breach of the Safeguarding (Code of Practice) Measure 2021.
However, DBS checks are NOT a legal requirement – they are a tool as part of a safer recruitment process available when roles are eligible for a DBS check.
Organisations do not have a ‘right’ to any level of check. There are legal restrictions around requesting a check when a role is not eligible, to protect the rights of individuals. Requesting a DBS check for a role that is not eligible is an offence under the Rehabilitation of Offenders Act 1974 and could leave an organisation open to criminal prosecution and fines.
The Disclosure Officer (DO)
The Disclosure Officer is appointed by the PCC to liaise between the parish and the Diocesan Safeguarding Team regarding the administrative aspects of the Disclosure process. DOs have very different responsibilities from those of Parish Safeguarding Officer (PSO); however, in some parishes both positions are held by the same person. The DO is provided with information from our third party provider, APCS about the process of obtaining DBS Disclosures on behalf of parishes.
Levels of checks
There are six levels of checks and each level of check requests a different level of private information on an individual. Enhanced level checks can be for either or both Child and Adult workforces – this creates a further two levels of checks.
Eligibility
Below are some descriptions and examples to assist in determining if a role is eligible for any particular level of check, but this is not exhaustive and meant to be use as a crude guide – for full details please refer to the DBS guidance.
Examples of roles that would not normally meet the eligibility criteria for an Enhanced DBS check:
Please contact us if you are unsure and want to discuss what level of check any role is eligible for.
Retaining Documents
Please remember that from April 2025 the DBS updated their guidance and now requires that a record of identity verification documents are kept for at least 2 years. Their preferred method is to keep copies in either of the following formats:
- Copies of physical documents
- Photocopies saved in PDF
If you're unable to retain copies of the documents, make sure you safely and securely store the following details:
- Type of document
- Country of issue
- Expiry date
- Reference or document number (e.g. passport number/driver's licence number)
- Any notes of discrepancies that were discussed during the check
We have created a couple of tools which are available for you to use to record the information, but you are free to create your own. These resources can be found below:
Please ensure that you are now following this guidance with immediate effect. If you are still unsure, please contact us to discuss your query and we will be happy to help.
DBS Fees from 1 December 2024
