Policy & Procedure: Disclosure Barring Service Application and Documentation

Purpose The purpose of this policy is to ensure that Hatching Dragons complies with UK law regarding Disclosure and Barring Service (DBS) checks and the handling of sensitive DBS information, safeguarding children in our care.

 Scope

This policy & procedure applies to all staff, volunteers, and contractors at Hatching Dragons who have direct or indirect contact with children.


Legal Framework

  • Safeguarding Vulnerable Groups Act 2006

  • Rehabilitation of Offenders Act 1974 (exceptions)

  • UK GDPR and Data Protection Act 2018

  • DBS Code of Practice


DBS Checks

  1. All staff, volunteers, and contractors who work with children will undergo an enhanced DBS check before starting employment.

  2. All employees must be enrolled on DBS Updated Service in line with best practice and internal nursery policy.

  3. Employment or engagement cannot proceed until a clear enhanced DBS report is received. 

  4. Ongoing compliance:

    • Each member of staff must hold an up-to-date DBS certificate and provide other safer recruitment documents to the nursery HR and hiring team before the employment takes place. Employment of the staffer is always a subject to Clear DBS checks and other safer recruitment and suitability checks. Where necessary, and deemed appropriate the nursery reserves the right to conduct periodic safer recruitment checks on all employees, even after their initial hiring, to ensure that all information remains up and relevant. 

    • The nursery will review and confirm that all staff DBSUpdated service checks are current and no new records obtained in the certificate every three months during staff supervision meetings. 

Handling and Storage of DBS Certificates

  1. DBS certificates contain sensitive personal data and must be handled securely.

  2. At Hatching Dragons, DBS certificates are stored securely in the BambooHR platform in a specific folder called “DBS Certificate” which is used for storage of the DBS digital certificate copy ONLY. The folder is with limited access to HR staff and the Designated Safeguarding Lead (DSL) only.

  3. Certificates or details are stored only for legitimate purposes:

    • Proof that a DBS check has been conducted

    • Safeguarding compliance records

  4. Retention and deletion:

    • Certificates are retained only as long as necessary for safeguarding and employment record purposes. This means, if the new certificate is issued the old must be disposed and new one updated. 

    • At the termination of employment, HR or the DSL must manually delete the employee’s DBS certificate from the BambooHR file. 


Sharing and Disclosure

  • DBS certificates must not be shared outside of authorised personnel.

  • Information will only be shared as required by law or for safeguarding purposes with relevant people and authorities only.


Staff Responsibilities

All staff and volunteers must:

  • Provide accurate information for DBS checks and other required service checks. DBS application and updated service checks must be complete together with the applicant available either in person or online. 

  • Ensure that their DBS certificate and service checks are kept up to date (Updated Service Checks requires direct debit subscription and annual fee). This must be done by the member of staff within 4 weeks of the issue date of the certificate. If more than 4 weeks passes by, the member of staff will need to apply for a new DBS certificate. 

  • Report any convictions or cautions that may affect their role. This includes any activity that involves of authorities such as enforcement officers, police, social services, MASH, LADO, Prevent Teams etc. 


8. Employer Responsibilities

Hatching Dragons will:

  • Ensure DBS and other service checks are conducted and complete before employment takes place. 

  • Keep DBS information secure and confidential in the “DBS Certificate” folder in BambooHR.

  • Confirm that all staff DBS and service checks are reviewed every three months during supervision meetings and reports dowloaded and uploaded to BambooHR > Documents > Safer Recruitment > DBS and Police Checks Folder

  • Ensure that manual deletion of DBS certificates occurs upon termination of employment.

  • Follow the DBS Code of Practice and GDPR guidelines.


9. Breach of Policy

Any breach of this policy, including:

  • unauthorised access, copying, or sharing of DBS information,

  • failure to delete DBS certificates at the end of employment, or

  • failure to maintain up-to-date checks,

may result in:

  • Disciplinary action

  • Reporting to the relevant authorities