A TEI must ensure that it is a safe place for all users. While DBS checks have a significant part to play in this, there will always be people in TEI buildings who have not been DBS checked. Indeed, a DBS check only demonstrates that person has no recorded offences – it does not prove that the person is safe. Obtaining a DBS certificate must NOT be seen as a substitute for carrying out other safer recruitment checks and processes, or as the end point of the process. The use of DBS checks forms just one part of a comprehensive selection and ongoing management process, as outlined within the guidance Requirements and this Good Practice Advice document.
Students training for licensed ministry
Any ordinand or student training for licensed lay ministry must have an enhanced DBS with Barred Lists (children and adult workforce). For Ordinands this is checked as part of the Shared Discernment Process, prior to the Stage 1 Panel. There is no requirement to repeat this check by the TEI, even if placements will be in a different diocese.
TEIs must view the enhanced DBS certificate (verifying that it is for working with children and vulnerable adults) and record the following details:
- date of issue;
- the DBS certificate number;
- the date seen and by whom.
TEIs need to be aware of any risk mitigations resulting from a risk assessment carried out by the diocese (under the appropriate information sharing agreement). Some students will be registered with the DBS update service and for such students, TEIs should use the online Update Service system to register an interest in the student, verify their DBS details via that system and then record the relevant details to the log.
Enhanced DBS checks must be renewed every three years, meaning that a student’s DBS re-check is often due during training. This is the responsibility of the sending diocese, but again the TEI needs to see and record the details of the new DBS certificate as described above.
Students sent from other denominations
If a system for DBS checks is available within the denominational structure then this should be used in a way analogous to Church of England Ordinands. If this is not possible then they should be treated as independent students.
Independent students
Any independent student who is taking a full programme of study will normally be undertaking placements. As such, the TEI must do an enhanced DBS with Barred Lists check for such students as part of the admissions process. This would cover the child workforce and also the adult workforce if the student would be carrying out any regulated activity. An offer of a place can only be made subject to a satisfactory enhanced DBS check. TEIs need to be clear about whether or not a DBS check has been made on an independent student. There are circumstances where the check would more appropriately be made by the placement context.
A student wishing to take courses that contain no placement element would not normally meet the criteria for an enhanced DBS check. However, the TEI can do a Basic DBS check on any independent student which needs to be clearly documented in admissions policies. For overseas checks, follow the Safer Recruitment and People Management Guidance.
TEIs should be aware of the risk of an individual who is doing separate modules using their relationship with the TEI to gain trust with a local church and seek a ministerial or other responsible role there. Local churches are, in these circumstances, responsible for arranging the relevant DBS check as well as other safer recruitment processes. However, if the TEI is contacted to confirm whether or not they are a student, the TEI needs to make clear that they are an independent student and whether or not they have been subject to an enhanced DBS check.
Staff and Volunteers
Detailed requirements and further information about DBS checks and safer recruitment can be found in the Safer Recruitment and People Management Guidance. All recruitment must follow this guidance.
All staff or volunteers who undertake regulated activity must have an enhanced DBS check (with or without barring list)1 . It is an offence to undertake an enhanced DBS check where one is not required; therefore TEIs must satisfy themselves that any particular role meets the criteria before applying. There are no eligibility requirements regarding Basic DBS checks, and their use is left to local determination. TEI policy should set out when such checks will be requested, as well as the lawful basis for requesting them from a data protection point of view. Where any DBS check is completed, it must be renewed every three years.
Dealing with a blemished DBS check
Should the TEI or the sending diocese be in receipt of a blemished DBS, the process set out in Section 10 of the Safer Recruitment and People Management Guidance must be followed.
- 1New disclosure and barring services - GOV.UK and Keeping children safe in education - GOV.UK provide guidance on what constitutes regulated activity.