Policy statement
1. Introduction
This Statement of Practice concerns the secure storage, handling, use, retention and disposal of Disclosure and Barring Service (DBS) certificates and certificate information.
2.1 General principles
As an organisation using the Disclosure and Barring Service (DBS) checking service to help assess the suitability of applicants for positions of trust, NEREO complies fully with the DBS code of practice regarding the correct handling, use, storage, retention and disposal of certificates, certificate information and related query details.
It also complies fully with its obligations under the General Data Protection Regulation (GDPR), Data Protection Act 2018, the UK Data Protection Act 2018 and other relevant legislation pertaining to the safe handling, use, storage, retention and disposal of certificate and DBS related information and has a written policy on these matters, which is available on request.
2.2 Storage and access
Certificate information should be kept securely, in lockable, non-portable, storage containers with access strictly controlled and limited to those who are entitled to see it as part of their duties.
2.3 Handling
In accordance with section 124 of the Police Act 1997, certificate information is only passed to those who are authorised to receive it in the course of their duties. We maintain a record of all those to whom certificates or certificate information has been revealed and it is a criminal offence to pass this information to anyone who is not entitled to receive it.
NEREO reserves the right to retain a copy of the relevant certificate/documentation to deminstrate ‘safer recruitment’ practice where the check relates to an individual in a service area where a CQC/Ofsted inspection or Safeguarding audit may take place for the purposes of inspection. Any copy taken will be held in accordance with Section 2.2 of this Statement.
2.4 Usage
Certificate information is only used for the specific purpose for which it was requested and for which the applicant’s full consent has been given.
2.5 Retention
Once a recruitment (or other relevant) decision has been made, we do not keep certificate information for any longer than is necessary. This retention will allow for the consideration and resolution of any disputes or complaints, or be for the purpose of completing safeguarding audits.
Throughout this time, the usual conditions regarding the safe storage and strictly controlled access will prevail.
2.6 Disposal
Once the retention period has elapsed, we will ensure that any DBS certificate information is immediately destroyed by secure means, for example by shredding, pulping or burning. While awaiting destruction, certificate information will not be kept in any insecure receptacle (e.g. waste bin or confidential waste sack).
We will not keep any photocopy or other image of the certificate or any copy or representation of the contents of a certificate. However, not withstanding the above, we may keep a record of the date of issue of a certificate, the name of the subject, the type of certificate requested, the position for which the certificate was requested, the unique reference number of the certificates and the details of the recruitment decision taken.
2.7 Acting as an umbrella body
Before acting as an umbrella body (an umbrella body being a registered body which countersigns applications and receives certificate information on behalf of other employers or recruiting organisations) for any body who requests we countersign applications for DBS certificates, we will take all reasonable steps to satisfy ourselves that they will handle, use, store, retain and dispose of certificate information in full compliance with the code of practice and in full accordance with this policy.
We will also ensure that any body or individual, at whose request applications for DBS certificates are countersigned, has such a written policy and, if necessary, will provide a model policy for that body or individual to use or adapt for this purpose.
