Staff Qualifications and Employment Checks

Regulation 28 of the Children's Homes (England) Regulations 2015 provides that a person may only manage a children’s home if:

• The person is of integrity and good character;
• Having regard to the size of the Home, its Statement of Purpose, and the number and needs (including any needs arising from any disability) of the children:
  • The person has the appropriate experience, qualification and skills to manage the Home effectively and lead the care of children; and
  • The person is physically and mentally fit to manage the Home; and
• Full and satisfactory information is available in relation to the person in respect of each of the matters in Schedule 2;
• Proof of identity including a recent photograph;
• A DBS check at the appropriate level;
• Two written references, including a reference from the person's most recent employer, if any;
• Where a person has previously worked in a position whose duties involved work with children or vulnerable adults verification, so far as reasonably practicable, of the reason why the employment or position ended;
• Documentary evidence of any relevant qualification;
• A full employment history, together with a satisfactory written explanation of any gaps in employment.  

A person has the appropriate experience and qualification if the person has: 

• Within the last 5 years,  worked for at least 2 years in a position relevant to the residential care of children;
• Worked for at least 1 year in a role requiring the supervision and management of staff working in a care role (i.e. a position which consists mainly or solely of providing care for children); and
• Holds a Level 5 Diploma in Leadership and Management for Residential Care or an equivalent qualification.

If a manager was managing a home on 1 April 2014, they should have gained the Diploma by 1 April 2017. Any manager starting to manage a home after 1 April 2014 has 3 years to gain it.

Regulation 28 does allow for the date to gain the qualification to be deferred if a manager has a break in managing a home or if they work part-time.

PLEASE NOTE: If a registered manager was managing a children's Home prior to April 2014, and they do not now hold the Level 5 Diploma qualification or equivalent, they are in breach of regulation 28 unless they have a good reason for a deferral.

If the registered manager holds a qualification they regard as equivalent, they should be able to demonstrate how their qualification meets the competencies in the level 5 diploma and any additional training they have completed to fill any gaps.

Ofsted inspectors will ask to see evidence of qualifications as part of an inspection.

Regulation 32 of the Children's Homes (England) Regulations 2015 requires Children's Home staff to have the appropriate experience, qualifications and skills for the work they will perform. For staff in a care role, the regulations require them to obtain the Level 3 Diploma for Residential Childcare or an equivalent qualification.

If the staff member was working in a care role in a home on 1 April 2014 they should have gained the Level 3 Diploma by 1 April 2016. Any members of staff starting to work in a care role after 1 April 2014 have 2 years to gain the qualification.

Regulation 32 does allow for the date to gain the qualification to be deferred if the staff member has a break in working in a home or if they have worked part-time.

In relation to staff, the regulations also require that:

1. The individual is of integrity and good character;
2. The individual has the appropriate experience, qualification and skills for the work that the individual is to perform;
3. The individual is mentally and physically fit for the purposes of the work that the individual is to perform; and
4. Full and satisfactory information is available in relation to the individual in respect of each of the matters in Schedule 2 (e.g. enhanced Disclosure and Barring Service Check, 2 written references, evidence of relevant qualifications and full employment history (including where a person has previously worked in a position involving work with children or vulnerable adults, verification of why the employment or position ended).

As part of an inspection of the Home, inspectors will take the following into account:

• The attitude and knowledge of the registered person in relation to staff training and development;
• The impact of lack of qualification/training on practice and in particular the quality of care provided to those living in the children’s home; and
• The rationale and individual circumstances taken into account for staff who have been granted a deferral of the time period required to attain the qualification, and arrangements for review of that deferral.

Where none (or very few) of the staff in a home are qualified, and there is no prospect that the remaining staff will achieve the qualification within 6 months or by the relevant date, the judgement for the effectiveness of leaders and managers is likely to be inadequate, and certainly no more than requires improvement.

Schedule 2 of the Children’s Homes (England) Regulations 2015 requires the following checks for people who wish to manage or work in a Children’s Home:

• Proof of identity including a recent photograph;
• An enhanced Disclosure and Barring Service check (depending on the nature of the role);
• Two written references, including a reference from the person’s most recent employer, if any;
• If a person has previously worked in a position involving work with children or vulnerable adults, verification so far as reasonably practicable of the reason why the employment or position ended;
• Documentary evidence of any qualifications which the person considers relevant for the position; and
• A full employment history, together with a satisfactory explanation of any gaps in employment, in writing.

Disclosure and Barring Service (DBS) Checks

The appropriate level DBS checks must be carried out before a person is appointed to engage in Regulated Activity within the Home. To determine which level of DBS check a role is eligible for, refer to the DBS Eligibility Guidance (GOV.UK).

The information contained in an up-to-date DBS certificate must be reviewed to decide whether this reveals any concerns about the person’s suitability to work with children. If there are concerns, the information must be used to come to a conclusion whether or not to appoint the person. Providers and managers must keep up-to-date with what constitutes Regulated Activity and fully investigate any information that indicates that a person may be barred from working with children or vulnerable adults.

Anyone who is barred from work with children is committing an offence if they apply for, offer to do, accept or do any work constituting Regulated Activity. It is also an offence for an employer knowingly to offer work in a regulated position, or to procure work in a regulated position for an individual who is disqualified from working with children, or fail to remove such an individual from such work.

Once appointed, a person must continue to meet the remit-specific regulatory requirements after the initial recruitment process.

In relation to the Disclosure and Barring Service checks, the following must be recorded:

• The date the DBS check was carried out;
• The DBS certificate number;
• The name of the person who checked the original certificate;
• Whether there was any information or concerns arising from the check that required further attention before you decided to appoint the individual;
• The name of the person who carried out the update check, if the individual is registered with the DBS update service;
• If concerns were identified once a person was appointed, steps you have taken to review a person’s suitability to continue to work with children;
• What actions you take if a person changes their role after they have been appointed;
• The actions you have taken in order to protect children from contact with unsuitable persons; this may include referral to the DBS or other relevant authorities.

Disclosure and Barring Service checks should be:

• Treated as confidential;
• Kept secure;
• Destroyed as soon as no longer required.

Information on checks for candidates who have spent time abroad or have come from abroad can be found at: GOV.UK, Criminal records checks for overseas applicants.

Please note: A DBS check has no official expiry date. Any information included will be accurate at the time the check was carried out. It’s up to you to decide when a new check is needed. The frequency at which DBS checks will be repeated should be detailed in the Safer Recruitment Policy.

Disclosure and Barring Service Update Service

The Disclosure and Barring Service (DBS), operate an optional Update Service which is designed to reduce the number of DBS checks requested.

Instead of a new check being necessary whenever an individual applies for a new role working with children, individuals can opt to subscribe to the online Update Service. This will allow them to keep their DBS certificate up to date, so that they can take it with them from role to role, within the children’s workforce.

Employers do not need to register, but can carry out free, instant, online status checks of a registered individual's status. A new DBS check will only be necessary if the status check indicates a change in the individual's status (because new information has been added). See GOV.UK for more information.

For the latest guidance on DBS referrals, see the GOV.UK website.

Checking an applicant’s right to work in the UK

As part of the recruitment process, you must also check that the applicant has the right to work in the UK.

See: GOV.UK: Checking a Job Applicants Right to Work.

Employers can be penalised / fined if they employ someone who does not have the right to work and they did not carry out the correct checks, or did not do them properly.

Policy statement

The safe recruitment of staff is the first step to safeguarding and promoting the welfare of children and staff within the organisation. Brinscall care is committed to safeguarding and promoting the welfare of all children in its care. As an employer, the Home expects all staff and volunteers to share this commitment.

Aims and objectives

The aims of the Safer Recruitment policy is to help deter, reject or identify people who might bring harm to children in our care or are otherwise unsuited to working with them by having appropriate procedures for appointing staff.

• Harm can take form physically or mentally.

The aims of our recruitment policy are as follows:

• To ensure that the best possible staff are recruited on the basis of their merits, abilities and suitability for the position;
• To ensure that all job applicants are considered equally and consistently;
• To ensure that no job applicant is treated unfairly on any grounds including race, colour, nationality, ethnic or national origin, religion or religious belief, sex or sexual orientation, marital or civil partner status, disability or age;
• To ensure compliance with all relevant legislation, recommendations and guidance including the statutory guidance published by the Department for Education (DfE), Keeping Children Safe in Education - September 2019 (KCSIE), the Prevent Duty Guidance for England and Wales 2015 (the Prevent Duty Guidance) and any guidance or code of practice published by the Disclosure and Barring Service (DBS), Working Together to Safeguard Children (2018), Care Standards Act 2000, Department of Health, NSPCC Safer Recruitment (not in Education); and
• To ensure that the company meets its commitment to safeguarding and promoting the welfare of children and young people by carrying out all necessary pre-employment checks.

Employees involved in the recruitment and selection of staff are responsible for familiarising themselves with and complying with the provisions of this policy.

Brinscall care has a principle of open competition in its approach to recruitment and will seek to recruit the best applicant for the job. The recruitment and selection process should ensure the identification of the person best suited to the job for the desired home or position based on the applicant’s abilities, qualification, experience and merit as measured against the job description and person specification.

The recruitment and selection of staff will be conducted in a professional, timely and responsive manner and in compliance with current employment legislation, and relevant safeguarding legislation and statutory guidance including KCSIE 2019 and Prevent Duty Guidance.

If a member of staff involved in the recruitment process has a close personal or familial relationship with an applicant, they must declare it as soon as they are aware of the individual’s application and avoid any involvement in the recruitment and selection decision-making process.

Brinscall care aims to operate this procedure consistently and thoroughly while obtaining, collating, analysing and evaluating information from and about applicants applying for job vacancies at Brinscall care.

Roles and Responsibilities

It is the responsibility of Brinscall care to:

• Ensure the Home has effective policies and procedures in place for recruitment of all staff and volunteers in accordance with DfE guidance, Working Together to Safeguard Children (2018), Care Standards Act 2000, Department of Health, NSPCC Safer Recruitment and legal requirements;
• Implement and monitor the Home’s compliance with them.

It is the responsibility of the Manager and staff involved in recruitment to:

• Ensure that the Home operates safe recruitment procedures and makes sure all appropriate checks are carried out on all staff and volunteers who work at the Home;
• To monitor contractors’ and agencies’ compliance with this document;
• Promote welfare of children and young people at every stage of the procedure.

Definition of Regulated Activity and Frequency

Regulated activity refers to certain roles carried out by applicants in relation to children and vulnerable adults. It covers various types of activities which, by their nature, would entitle an individual to an enhanced DBS check with applicable barred lists.

It’s important to note that regulated activity is different for both children and vulnerable adults.

Regulated activity: children

• Regulated activity in relation to children can be split into two main categories, these include activities and places of work;
• Those working in specified activities will be classed as engaging in regulated activity. Put simply, this is anyone who is teaching/training/instructing/coaching/caring for or supervising children;
• Anyone who is carrying out such a role must have an enhanced DBS check carried out or have a valid up to date certificate with a children’s barred list check.

Applicants would also be classed as working in regulated activity if they were working in a specified establishment. These are referred to as a limited range of establishments, and include, but are not limited to:

• Schools;
• Children’s homes;
• Nurseries.

Permanently working in these institutions would mean an applicant was engaging in regulated activity, e.g. those working as teachers, nursery nurses, or caretakers.

For those who work in these establishments sporadically, such as contractors or visitors, their eligibility for a check would be determined by the frequency of their work or nature of visit. To be eligible for a DBS check they would need to work in any one of these specified places more than three times in a 30-day period.

To confirm if your applicant is engaging in regulated activity with children, visit the DBS guidance.

The company is not permitted to check the Children's Barred List unless an individual will be engaging in "regulated activity" as stated above. The company is required to carry out an enhanced DBS check for all staff who will be engaging in regulated activity. However, the company can also carry out an enhanced DBS check on a person who would be carrying out regulated activity but for the fact that they do not carry out their duties frequently enough i.e. roles which would amount to regulated activity if carried out more frequently.

Recruitment and selection procedure

Advertising

To ensure equality of opportunity, the Home will advertise all vacant posts to encourage as wide a field of applicant as possible, normally this entails an external advertisement.

Any advertisement will make clear the companies’ commitment to safeguarding and promoting the welfare of children.

All documentation relating to applicants will be treated confidentially in accordance with the Data Protection Act (DPA) 2018.

Application Forms

Brinscall care uses its own application form and all applicants for employment will be required to complete an application form containing questions about their academic and full employment history and their suitability for the role (in addition all applicants are required to account for any gaps or discrepancies in employment history). Applicants submitting an incomplete application form will not be shortlisted.

The application form will include the applicant’s declaration regarding convictions and working with children, and will make it clear that the post is exempt from the provisions of the Rehabilitation of Offenders Act 1974. Stand alone CVs will not be accepted.

It is unlawful for Brinscall care to employ anyone who is barred from working with children. It is a criminal offence for any person who is barred from working with children to apply for a position at Brinscall care. All applicants will be made aware that providing false information is an offence and could result in the application being rejected, or summary dismissal if the applicant has been selected, and referral to the police and/or the DBS.

Application forms include the following areas:

• Name and previous names;
• Current address and addresses for the last 5 years;
• Date of Birth;
• Relevant education/ training/ qualifications;
• Details of present/ last employer or education/ voluntary association if not previously employed;
• Previous employment - details of employer/ manager, position held, dates, reason for leaving;
• Experience relating to the person specification;
• Details of two referees (not relatives) both of which should be recent and at least one should be the current or recent e.g. from an employer; teacher, professional colleague etc.
• Details of any criminal conviction or caution;
• Details of time not covered by education or work.

Job Descriptions and Person Specifications

A job description is a key document in the recruitment process, and must be finalised prior to taking any other steps in the process. It will clearly and accurately set out the duties and responsibilities of the job role.

The person specification is of equal importance and informs the selection decision. It details the skills, experience, abilities and expertise that are required to do the specified job. The person specification will include a specific reference to suitability to work with children in a specific capacity which involves close supervision and or direct support for young people.

References

References for short-listed applicants will be sent out immediately after short-listing. The only exception is where an applicant has indicated on their application form that they do not wish their current employer to be contacted at this stage. In such cases, this reference will be taken up immediately after interview.

All offers of employment will be subject to the receipt of a minimum of two references which are considered satisfactory by the company. One of the references must be from the applicant's current or most recent employer. If the current/most recent employment does/did not involve work with children, then the second reference should be from the employer with whom the applicant most recently worked with children. If the candidate has not worked with children previously, the company will determine the candidates skill set and other experience from their application, interview and reference stages. The referee should not be a relative. References will always be sought and obtained directly from the referee and their purpose is to provide objective and factual information to support appointment decisions.

All referees will be asked whether they believe the applicant is suitable for the job for which they have applied and whether they have any reason to believe that the applicant is unsuitable to work with children. Referees will also be asked to confirm that the applicant has not been radicalised, so that they do not support terrorism or any form of "extremism".

Please note that no questions will be asked about health or medical fitness prior to any offer of employment being made. As part of the process, candidates complete a pre employment health questionnaire.

Any discrepancies or anomalies will be followed up. Direct contact by phone will be undertaken with each referee to verify the reference.

Brinscall care does not accept open references, testimonials or references from relatives.

Reference details need to include information on:

• Length of time the person has known the applicant and in what capacity;
• Sickness record;
• Person’s skills strengths and weaknesses/suitability for the post and for working with children and young people;
• Details of any known investigations or disciplinary action;
• Details on probationary periods of employment where applicable;
• Confirmation of known police/DBS check;
• Details regarding knowledge of any criminal convictions or cautions the applicant may have;
• Reasons for leaving employment;
• Details as to whether employer would re-employ.

Any information given about previous experience should be scrutinised to ensure that it is consistent. Satisfactory explanations should be obtained for any gaps in employment. If the candidate is not currently employed it is also necessary to check with the organisation by whom they were most recently employed/ student/ volunteer to confirm details of their status and their reasons for leaving.

Interviews

There will be a face-to-face interview wherever possible, and a minimum of two interviewers will see the applicants for the vacant position. The interview process will explore the applicant’s ability to carry out the job description and meet the person specification. It will enable the panel to explore any anomalies or gaps which have been identified in order to satisfy themselves that the chosen applicant can meet the safeguarding criteria (in line with Safer Recruitment Training).

Any information in regard to past disciplinary action or allegations, cautions or convictions will be discussed and considered in the circumstance of the individual case during the interview process, if it has been disclosed on the application form.

At least one member of any interviewing panel will have undertaken safer recruitment training or refresher training as applicable.

All applicants who are invited to an interview will be required to bring evidence of their identity, address and qualifications. Original documents will only be accepted and photocopies will be taken. Unsuccessful applicant documents will be destroyed 6 months after the recruitment programme.

Offer of appointment and new employee process

If it is decided to make an offer of employment following the formal interview, any such offer will be conditional on the following:

• The agreement of a mutually acceptable start date and the signing of a contract incorporating Brinscall care standard terms and conditions of employment;
• Verification of the applicant's identity (if not previously been verified);
• The receipt of two references (one of which must be from the applicant's most recent employer) which the company considers to be satisfactory:
  1. The company being satisfied that the applicant is not, and has never been, the subject of a serious sanction, restriction or prohibition by any predecessor or successor body, or by a regulator of the a care profession in any other European Economic Area country which prevents the applicant working at the a home within the company or which, in the companies opinion, renders the applicant unsuitable to work at the one of our children’s homes; and
  2. The company being satisfied that the applicant is not, and has never been, the subject of any proceedings before a professional conduct panel or equivalent body in the UK or any other country for any reason which prevents the applicant working for the company or which, in the companies opinion, renders the applicant unsuitable to work for the company.
• Where the position amounts to "regulated activity the receipt of an enhanced disclosure from the DBS which the company considers to be satisfactory;
• Where the position amounts to "regulated activity" confirmation that the applicant is not named on the Children's Barred List;
• Verification of the applicant's medical fitness for the role;
• Verification of the applicant's right to work in the UK;
• Any further checks which are necessary as a result of the applicant having lived or worked outside of the UK; and
• Verification of professional qualifications which the company deems a requirement for the post, or which the applicant otherwise cites in support of their application (where not previously verified).

Whether a position amounts to "regulated activity" must therefore be considered by the company in order to decide which checks are appropriate. It is however likely that in nearly all cases the company will be able to carry out an enhanced DBS check and a Children's Barred List check.

A personnel file checklist will be used to track and audit paperwork obtained in accordance with Safer Recruitment Training. The checklist will be retained on personnel files.

The Rehabilitation of Offenders Act 1974

The Rehabilitation of Offenders Act 1974 does not apply to positions which involve working with, or having access to children in the Home. Therefore, any convictions and cautions that would normally be considered ‘SPENT’ must be declared when applying for any position at Brinscall care.

DBS (Disclosure and Barring Service) Check

Brinscall care applies for an enhanced disclosure from the DBS and a check of the Children's Barred List (now known as an Enhanced Check for Regulated Activity) in respect of all positions at the Home which amount to "regulated activity" as defined in the Safeguarding Vulnerable Groups Act 2006 (as amended). The purpose of carrying out an Enhanced Check for Regulated Activity is to identify whether an applicant is barred from working with children by inclusion on the Children's Barred List and to obtain other relevant suitability information.

It is company policy that the DBS disclosure must be obtained before the commencement of employment of any new employee.

It is company policy to re-check employees’ DBS Certificates every three years and in addition any employee who takes leave for more than three months (i.e. maternity leave, career break etc) must be re-checked before they return back to work.

Members of staff at Brinscall are aware of their obligation to inform the Manager of any cautions or convictions that arise between these checks taking place.

DBS checks will still be requested for applicants with recent periods of overseas residence and those with little or no previous UK residence.

DBS Certificate

The DBS no longer issue Disclosure Certificates to employers, therefore employees/applicants should bring their original Certificate to the Manager or senior manager’s at Brinscall care.

Dealing with convictions

The company operates a formal procedure if a DBS Certificate is returned with details of convictions. Please also see ‘Recruitment of Ex-offenders’ policy and procedure.

Consideration will be given to the Rehabilitation of Offenders Act 1974 and also:

• The nature, seriousness and relevance of the offence;
• How long ago the offence occurred;
• One-off or history of offences;
• Changes in circumstances;
• Decriminalisation and remorse.

A formal meeting will take place face-to-face to establish the facts with the Manager. This may take place during interview and will be reference clearly on interview paperwork. If this meeting is separate,a decision will be made following this meeting. In the event that relevant information (whether in relation to previous convictions or otherwise) is volunteered by an applicant during the recruitment process or obtained through a disclosure check, the Manager will evaluate all of the risk factors above before a position is offered or confirmed.

If an applicant wishes to dispute any information contained in a disclosure, they may do so by contacting the DBS. In cases where the applicant would otherwise be offered a position were it not for the disputed information, the company may, where practicable and at its discretion, defer a final decision about the appointment until the applicant has had a reasonable opportunity to challenge the disclosure information.

Proof of identity, Right to Work in the UK & Verification of Qualifications and/or professional status

All applicants invited to attend an interview with the company will be required to bring their identification documentation such as passport, birth certificate, driving licence etc. with them as proof of identity/eligibility to work in UK in accordance with the Immigration, Asylum and Nationality Act 2006 and DBS identity checking guidelines. Brinscal care does not discriminate on the grounds of age.

Where an applicant claims to have changed their name by deed poll or any other means (e.g. marriage, adoption, statutory declaration) they will be required to provide documentary evidence of the change.

In addition, applicants must be able to demonstrate that they have actually obtained any academic or vocational qualification legally required for the position and claimed in their application form.

Medical Fitness

Brinscall care is legally required to verify the medical fitness of anyone to be appointed to a post at the Home, after an offer of employment has been made but before the appointment can be confirmed.

All applicants are requested to complete a medical questionnaire and where appropriate a doctor’s medical report may be required. This information will be reviewed against the Job Description and the Person Specification for the particular role, together with details of any other physical or mental requirements of the role.

Brinscall care is aware of its duties under the Equality Act 2010. No job offer will be withdrawn without first consulting with the applicant, obtaining medical evidence and considering reasonable adjustments.

Overseas checks

In addition, applicants who have lived/travelled abroad for more than 3 months will need to obtain a criminal records check from the relevant country. The applicant will not be permitted to commence work until the overseas information has been received and is considered satisfactory by the company.

Induction Programme

All new employees will be given an induction programme which will clearly identify Brinscall care policies and procedures, including the Child Protection Policies, code of conduct and make clear the expectations which will govern how staff carry out their roles and responsibilities.

Record Retention/Data Protection

Brinscall care is legally required to undertake the above pre-employment checks. Therefore, if an applicant is successful in their application, we will retain on their personnel file any relevant information provided as part of the application process. This will include copies of documents used to verify identity, right to work in the UK, medical fitness and qualifications. Medical information may be used to help Brinscall care to discharge its obligations as an employer, e.g. so that the we may consider reasonable adjustments if an employee suffers from a disability or to assist with any other workplace issue.

This documentation will be retained by Brinscall care for the duration of the successful applicant's employment with the company All information retained on employees is kept centrally in the Office in a locked and secure cabinet.

Brinscall care will retain all interview notes on all unsuccessful applicants for a period of 6 months, after which time the notes will be confidentially destroyed (i.e. shredded). The 6-month retention period is in accordance with the UK General Data Protection Regulation (UK GDPR) [DPA 2018].

Ongoing Employment

Brinscall care recognises that safer recruitment and selection is not just about the start of employment, but should be part of a larger policy framework for all staff. The company will therefore provide ongoing training and support for all staff, as identified through the Annual Review/appraisal procedure.

Leaving Employment of Brinscall care

Despite the best efforts to recruit safely, there will be occasions when allegations of serious misconduct or abuse against children are raised. This policy is primarily concerned with the promotion of safer recruitment and details the pre employment checks that will be undertaken prior to employment being confirmed. Whilst these are pre-employment checks, the company also has a legal duty to make a referral to the DBS in circumstances where an individual:

• Has applied for a position at Brinscall care despite being barred from working with children; or
• Has been removed by Brinscall care from working in regulated activity (whether paid or unpaid), or has resigned prior to being removed, because they have harmed, or pose a risk of harm to, a child.

Contractors and Agency Staff

Contractors engaged by Brinscall care must complete the same checks for their employees that Brinscall care is required to complete for its staff. Brinscall care requires confirmation that these checks have been completed before employees of the Contractor can commence work at the Home.

Agencies who supply staff to Brinscall care must also complete the pre-employment checks which the company would otherwise complete for its staff. Again, the company requires confirmation that these checks have been completed before an individual can commence work at the Home.

Brinscall care will independently verify the identity of staff supplied by contractors or an agency in and will require the provision of the original DBS certificate before contractors or agency staff can commence work at the Home.

Visitors (and Prevent Duty)

The Prevent Duty Guidance requires Brinscall care to have clear protocols for ensuring that any visitors, whether invited by staff or by children, are suitable and appropriately supervised.

The companies home’s are not permitted to obtain a DBS disclosure or Children's Barred List information on any visitors who do not engage in regulated activity at the Home or perform any other regular duties for or on behalf of the Home.

All visitors will be subject to the Home's usual visitors signing in protocol. This will include signing in and out at Reception and being escorted by a fully vetted member of staff between appointments.

In fulfilling its Prevent Duty obligations the company does not discriminate on the grounds of race, colour, nationality, ethnic or national origin, religion or religious belief, sex or sexual orientation, marital or civil partner status, disability or age.

Volunteers

The company will request an enhanced DBS disclosure and Children's Barred List information on all volunteers undertaking regulated activity with children at the Home. Under no circumstances will Brinscall care permit an unchecked volunteer to have unsupervised contact with the children in its care.

It is the companies policy that a new DBS certificate is required for volunteers who will engage in regulated activity but who have not been involved in any activities with the Home for three consecutive months or more. Those volunteers who are likely to be involved in activities with the Home on a regular basis may be required to sign up to the DBS update service as this permits the Home to obtain up to date criminal records information without delay prior to each new activity in which a volunteer participates.

In addition the company will seek to obtain such further suitability information about a volunteer as it considers appropriate in the circumstances. This may include (but is not limited to the following):

• Formal or informal information provided by staff, parents and other volunteers;
• Character references from the volunteer's place of work or any other relevant source; and
• An informal safer recruitment interview.

Monitoring and Evaluation

The Manager will be responsible for ensuring that this policy is monitored and evaluated throughout their homes. This will be undertaken through formal audits of job vacancies and a yearly Safer Recruitment Evaluation audit.