Safer recruitment audit

Who it applies to

Every CQC-registered adult social care provider that employs staff, agency workers or volunteers in regulated activity. The audit should cover new starters and a rolling sample of longer-serving staff.

What Schedule 3 asks you to hold

Schedule 3 lists the information a provider must have for each person employed. In practice, the audit looks for:

• Proof of identity, including a recent photograph
• A DBS check at the right level, with barred list check where eligible
• Satisfactory evidence of conduct in previous health or social care work, and why that work ended
• A full employment history with a written explanation of any gaps
• Verification of qualifications relevant to the role, and professional registration where required
• Evidence of right to work in the UK
• Information about any physical or mental health conditions relevant to the role, after an offer is made

How to run the audit

• Sample: all starters since the last audit, plus at least a few longer-serving files each month
• Check each file against the same list so results are comparable month to month
• Record what was missing, not just 'fail' — for example 'gap Mar–Aug 2023 not explained'
• Where a check is missing, decide on risk management now (supervised work, risk assessment) and set a deadline
• Re-audit the files you fixed to prove the action worked

Common findings in inspection reports

• Employment gaps noted on the application but never explored at interview
• References from friends or colleagues rather than the last employer
• Staff starting before the DBS returned with no risk assessment in place
• Overseas recruits without a certificate of good conduct from their home country
• Agency staff profiles not requested or not kept

Internal audit questions

1. 1.Does every file contain photo ID and a recent photograph?
2. 2.Is there a DBS check at the right level, dated before the start date or covered by a risk assessment?
3. 3.Is the full employment history recorded, with every gap explained in writing?
4. 4.Are there at least two references, including the most recent employer in care?
5. 5.Is the reason for leaving previous care work recorded and verified?
6. 6.Is right to work evidenced and, where time-limited, is the expiry tracked?
7. 7.Have qualifications and professional registration been checked with the issuing body?
8. 8.Is there an interview record showing values and gaps were explored?

How MyCareCompliance can help

MyCareCompliance includes a monthly Staff File / Safer Recruitment audit template mapped to Regulation 19. Each gap becomes an action with an owner and due date, and staff records in Workforce track DBS, right to work and other document expiries so you are warned before something lapses.

Official sources

• Regulation 19 — Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (legislation.gov.uk)
• Schedule 3 — information required in respect of persons employed (legislation.gov.uk)
• CQC guidance on Regulation 19