DBS Compliance

Are Enhanced DBS checks, including the Adult Barred List, obtained and verified for all care staff prior to them commencing regulated activity?

What we look for: Sample 5 recently recruited staff files to ensure the DBS certificate was received before their first unshadowed shift. Good looks like zero gaps in safe recruitment. A fail is any staff member providing personal care before the full DBS or appropriate risk-assessed Adult First check is confirmed.

Evidence: Staff recruitment files, central training/HR matrix, DBS certificates (or reference numbers)

If staff commence work using an Adult First check pending a full DBS, is a robust risk assessment in place ensuring they are strictly shadowed and supervised?

What we look for: Check rotas and staff files for anyone who started with an Adult First check. Ensure they were never rostered to work alone and that shadowing is clearly documented. A fail is an unsupported staff member delivering care without the full Enhanced DBS in place.

Evidence: Risk assessments, shadow rotas, supervision logs, Adult First confirmation emails

Where a DBS certificate contains positive disclosure information (e.g., convictions/cautions), is a comprehensive, manager-signed risk assessment on file?

What we look for: Review files of any staff known to have positive disclosures. The risk assessment must detail the nature of the offence, time elapsed, relevance to care work, and mitigating factors. A fail is a positive disclosure ignored or assessed without senior management sign-off.

Evidence: Positive disclosure risk assessments, interview notes, Registered Manager sign-off

Is there a systematic process for checking the DBS Update Service (e.g., annually) for staff who have subscribed, including documented consent?

What we look for: Sample records for staff on the Update Service to ensure the provider is actively running status checks at least annually. Good practice involves a tracker alerting HR when a check is due. A fail is having staff on the Update Service but never actually verifying their status.

Evidence: Update Service consent forms, logged check dates, screenshots of status checks

For staff not subscribed to the Update Service, are DBS certificates renewed in line with the provider's stated policy (e.g., every 3 years)?

What we look for: Check the central compliance matrix against the provider's own DBS renewal policy. Identify any staff whose certificates have expired under this policy. A fail is a significant number of overdue renewals with no evidence of new applications being processed.

Evidence: HR policy, staff compliance matrix, renewal application tracking

Does the provider accurately verify that all applied DBS checks are specifically at the 'Enhanced' level and include the 'Adult Barred List' check?

What we look for: Ensure standard or basic checks are not mistakenly used for frontline care staff. Every care worker must have an Enhanced check checking the adult barred list. A fail is finding standard DBS checks on file for staff performing regulated activities.

Evidence: Central HR matrix, DBS application portal records, spot check of DBS reference numbers

Is there a clear procedure and historic evidence (where applicable) of making referrals to the DBS if a staff member is dismissed for safeguarding reasons?

What we look for: Ask the manager about their legal duty to refer to the DBS if someone is dismissed (or resigns pending dismissal) for harming a person drawing on care. Review the safeguarding log for any such incidents to verify a referral was made. A fail is a missed legal duty to refer a dangerous worker to the DBS.

Evidence: Safeguarding policy, dismissal records, DBS referral forms, CQC notification logs

Are DBS records stored and destroyed in compliance with the DBS Code of Practice and GDPR guidelines (not keeping certificates longer than 6 months)?

What we look for: Inspect staff files to see if physical or scanned copies of DBS certificates are kept indefinitely. The provider should only record the certificate number, date, and clearance status after 6 months. A fail is finding years of original DBS certificates hoarded in staff files.

Evidence: HR filing cabinets, secure digital drives, DBS retention policy, document destruction logs