For small businesses in the UK, having a clear Disclosure and Barring Service (DBS) checking policy can help support safer recruitment and protect employees, customers and the wider public. A written policy explains when criminal record checks are appropriate, how applications are managed and how information is handled fairly.
Creating a practical DBS Checking Policy for a Small Business does not need to be complicated. The key is to establish consistent procedures that meet the needs of the organisation and comply with relevant legal requirements.
Identify Which Roles Need DBS Checks
The first step is to review the responsibilities of each position. Not every employee requires a DBS check, and employers should not request higher-level checks without a valid legal basis.
Basic DBS checks are available to individuals and can be used by employers as part of recruitment. Standard and Enhanced checks are restricted to roles that meet specific eligibility requirements.
For example, certain positions involving regulated activity with children or adults may qualify for Enhanced checks, potentially including a relevant barred list check. Employers should consult the official DBS eligibility guidance before deciding which check is appropriate.
Establish a Clear Application Process
A written policy should explain who is responsible for requesting checks, verifying applicants' identities and monitoring application progress. Assigning these duties to a manager or designated HR contact can help a small business maintain consistency.
The procedure should also explain when checks will take place, what applicants need to provide and how delays will be communicated. Employers should make sure candidates understand why a check is required and how the information will be used.
Handle Criminal Record Information Fairly
A DBS certificate should not automatically determine whether someone is suitable for employment. Employers should consider information in context, including its relevance to the position and any explanation provided by the applicant.
A recruitment policy should explain how disclosed information will be assessed fairly and consistently. Employers must also follow applicable rules concerning protected convictions, spent convictions and the lawful use of criminal record information.
A clear approach helps reduce the risk of unfair decisions and supports a more transparent recruitment process.
Protect DBS Information
Criminal record information must be handled securely and only accessed by authorised individuals who need it for legitimate purposes.
Small businesses should establish procedures for storing relevant records, restricting access and disposing of information securely when it is no longer required. The policy should also address confidentiality and compliance with applicable data protection requirements.
Employers should consult the DBS guidance on handling certificate information to ensure their procedures are appropriate.
Review the Policy Regularly
A DBS checking policy should be reviewed periodically and whenever recruitment practices or relevant guidance changes. Businesses should check that role eligibility assessments remain accurate and that staff understand their responsibilities.
It is also useful to keep records of decisions about which roles require checks and to review the process when recruitment difficulties arise.
For more information about criminal record screening and DBS applications, visit CRB Direct.
Frequently Asked Questions
Does every small business need a DBS checking policy?
Not every business is legally required to have a standalone written policy. However, documenting procedures can help employers apply checks consistently and demonstrate responsible recruitment practices.
Can a small business request an Enhanced DBS check for every employee?
No. Enhanced DBS checks are only available for roles that meet the relevant legal eligibility requirements.
How often should a DBS checking policy be reviewed?
Businesses should review their policy regularly and whenever relevant legislation, DBS guidance or recruitment arrangements change.
Can an employer reject someone because of a criminal record?
Employers should assess disclosed information fairly, considering its relevance to the role and applicable legal protections. A criminal record should not automatically result in rejection.
What should a DBS checking policy include?
It should cover role eligibility, application procedures, identity verification, fair assessment of disclosed information, confidentiality, secure information handling and regular policy reviews.
