For UK employers, deciding whether a role is eligible for a Disclosure and Barring Service (DBS) check is an important part of safer recruitment. HR teams should not simply request the highest level of check available. The recruiting organisation is responsible for deciding whether a role is eligible and which level of check is appropriate.
Keeping a clear record of these DBS Eligibility Decisions can help organisations demonstrate that their recruitment processes are consistent, considered and based on the duties of the role.
Start With the Role, Not the Job Title
DBS eligibility should be assessed according to the actual responsibilities involved. Factors can include who the employee interacts with, where they work, what activities they perform and how frequently those activities take place. A comprehensive job description can therefore be particularly useful when making an assessment.
HR teams should record the relevant duties considered when determining eligibility rather than simply writing that a role is "DBS required".
Record the Reason for the Decision
An internal DBS record should explain why a particular level of check was considered appropriate.
For example, an organisation might record:
- The job title and department
- Key duties and responsibilities
- Contact with children or adults
- Relevant workforce
- The DBS level considered
- The guidance or eligibility criteria relied upon
- The date of the assessment
- The person responsible for the decision
This creates an audit trail if the role or recruitment process is reviewed later.
Record Changes to Roles
DBS eligibility can change when an employee's duties change. A promotion, transfer or new responsibility may alter the type of work the person carries out and therefore affect DBS eligibility.
HR teams should consider reviewing the original eligibility decision when:
- A job description changes
- An employee moves departments
- New safeguarding responsibilities are introduced
- The organisation begins providing different services
- Working arrangements or activities change significantly
Recording these reviews can help keep DBS decisions aligned with current roles.
Keep the DBS Level Appropriate
Employers should ensure that the level of check requested matches the legal eligibility of the role. Standard and Enhanced checks can only be requested where the relevant legal criteria are met.
If a role is not eligible for a Standard or Enhanced check, a Basic DBS check may still be available, as Basic checks do not have the same specific eligibility criteria.
Recording why a particular level was selected helps prevent assumptions that every position requires an Enhanced check.
Protect Sensitive Information
Eligibility records should be kept separately from unnecessary criminal record information. DBS guidance requires organisations to handle certificate information fairly, securely and only for the purpose for which it was obtained. Information should generally be destroyed after a suitable period, usually no longer than six months, subject to applicable requirements.
HR teams should therefore record the eligibility decision without unnecessarily copying sensitive information from a DBS certificate.
Review Decisions Regularly
Periodic reviews can help organisations identify outdated job descriptions, inconsistent decisions or changes in DBS eligibility guidance.
HR teams should also ensure that relevant staff know where to find current DBS guidance. The DBS eligibility guidance was updated in September 2026, including new guidance covering roles working with children, adults and other workforces.
For organisations processing numerous applications, CRB Direct can provide DBS application services to support their wider recruitment process.
FAQ
Why should HR teams record DBS eligibility decisions?
Recording the reasoning behind an eligibility decision creates a clear audit trail and helps demonstrate that the appropriate DBS level was considered for the role.
Who is responsible for deciding DBS eligibility?
The recruiting organisation is responsible for determining whether a role is eligible for a DBS check and, where applicable, which level is appropriate.
Should HR teams record the candidate's criminal record?
Not necessarily. Eligibility records should focus on the role and the reasoning behind the DBS decision. Sensitive certificate information should be handled separately and securely.
Should DBS eligibility be reviewed when a role changes?
Yes. Changes to duties or activities can affect DBS eligibility, so HR teams should reassess the position when significant changes occur.
How often should DBS eligibility decisions be reviewed?
There is no universal review interval for every organisation. HR teams should review decisions when roles change and whenever relevant DBS guidance or legislation is updated.
Conclusion
Accurate records of DBS Eligibility Decisions can help HR teams maintain consistent and defensible recruitment processes. By assessing the actual duties of each role, recording the reasoning behind the decision, reviewing changes and protecting sensitive information, organisations can manage DBS requirements more effectively.
A structured approach also makes it easier to identify outdated decisions and ensure that DBS applications remain appropriate for the roles being recruited.
