Internal promotions allow organisations to recognise existing employees and provide opportunities for career development. However, moving into a new position can sometimes change an employee's responsibilities, level of access or contact with vulnerable people. This raises an important question for employers: does the employee need another Disclosure and Barring Service (DBS) check?
Understanding DBS Checks and Internal Promotions can help employers make appropriate screening decisions without unnecessarily repeating checks.
Does an Internal Promotion Automatically Require a New DBS Check?
No. An internal promotion does not automatically mean that a new DBS check is required. DBS eligibility is determined by the duties and responsibilities of the new role, rather than simply by the employee receiving a promotion.
If the new position has substantially different responsibilities, employers should reassess whether it is eligible for a DBS check and whether a different level of check is appropriate.
For example, an employee moving from an administrative position to a role involving regular work with children may have different DBS requirements.
When Might a New DBS Check Be Necessary?
A new check may be appropriate when the employee's new responsibilities mean the role falls within different DBS eligibility criteria.
Employers should consider:
- Whether the new role involves children or vulnerable adults
- Whether the employee will undertake regulated activity
- The level of access to sensitive environments or information
- Whether the workforce category has changed
- Whether the existing certificate is suitable for the new role
The employer should assess the new position based on its actual duties.
What If the Employee Already Has a DBS Certificate?
An existing DBS certificate does not automatically cover every future role. Employers should consider whether the certificate is relevant to the new position.
Where an employee is subscribed to the DBS Update Service, an organisation may be able to check whether there has been a change to the individual's criminal record, subject to the applicable requirements and the employer's responsibilities.
However, the Update Service does not remove the need to consider whether the existing check is suitable for the new role.
Promotions Involving Safeguarding Responsibilities
Internal promotions can sometimes introduce significantly greater safeguarding responsibilities. This is particularly relevant in schools, healthcare, social care, charities and organisations working with vulnerable groups.
For example, an employee who previously worked behind the scenes may move into a management or direct-support position. The organisation should review the new duties before the employee begins carrying them out.
A documented eligibility assessment can help demonstrate that the correct decision was made.
Managing DBS Checks During Promotions
Employers should build DBS considerations into their internal promotion procedures. HR teams can review the employee's existing screening information alongside the duties of the new position.
A structured process can include:
- Reviewing the new job description
- Assessing DBS eligibility
- Checking the existing certificate
- Determining whether a new check is required
- Recording the screening decision
- Completing any necessary application before the new duties begin
This approach helps maintain consistent recruitment and safeguarding standards.
Common Mistakes to Avoid
Employers should avoid automatically requesting a new DBS check for every promotion. Equally, they should not assume that an existing certificate is sufficient simply because the employee has already been screened.
Other mistakes include failing to assess changes in duties, overlooking workforce categories and allowing employees to begin new eligible responsibilities before appropriate screening has been completed.
For professional DBS application support and guidance, organisations can use CRB Direct to help manage their screening requirements.
FAQ
Does every promotion require a new DBS check?
No. A new DBS check is not automatically required simply because an employee has been promoted. The new role's duties and eligibility should be assessed.
Can an existing DBS certificate be used after a promotion?
Sometimes. Employers should determine whether the existing certificate is appropriate for the new role and meets its DBS eligibility requirements.
Does the DBS Update Service guarantee that a new check is unnecessary?
No. The Update Service can provide useful information about changes to a certificate, but employers must still assess whether the existing check is suitable for the new position.
Should DBS eligibility be reviewed before a promotion?
Yes. Reviewing the new responsibilities before the employee starts their new duties helps employers identify whether additional screening is required.
Where can employers get help with DBS checks?
Employers can access DBS application services and guidance through CRB Direct.
Conclusion
Understanding DBS Checks and Internal Promotions helps employers make informed decisions when employees move into new positions. A promotion does not automatically require another DBS check, but significant changes to duties, responsibilities or contact with vulnerable groups may affect eligibility.
By reviewing the new role, considering existing DBS information and documenting decisions, organisations can maintain appropriate safeguarding standards while avoiding unnecessary repeat checks.
