DBS Checks for Employers

A Basic DBS check reveals only unspent convictions and conditional cautions. Any employer can request a basic check for any role — but only the individual can apply for their own basic check (employers cannot apply on their behalf directly). Basic checks are suitable for roles with no specific legal requirement for a higher-level check.

A Standard DBS check reveals spent and unspent convictions, cautions, reprimands, and warnings held on the Police National Computer. It is only available for roles specifically listed in the Rehabilitation of Offenders Act 1974 (Exceptions) Order — these include certain legal, financial, and healthcare roles. An Enhanced DBS check also includes any relevant information held by local police. An Enhanced check with a barred list check is required for regulated activity — roles involving close or unsupervised contact with children or vulnerable adults. Requesting a higher-level check than permitted is unlawful.

Regulated activity covers work that involves regular, close contact with children or adults at risk in specified settings (schools, care homes, hospitals, etc.) or in specified roles (teaching, personal care, healthcare). Employers engaging anyone in regulated activity must check the relevant DBS barred list. It is a criminal offence under the Safeguarding Vulnerable Groups Act 2006 to knowingly employ a barred individual in regulated activity, or to fail to refer someone who has harmed or poses a risk of harm to a vulnerable group to the DBS for consideration of barring.

Organisations engaged in regulated activity must register with the DBS through an umbrella body or as a registered body. The DBS Update Service allows employers to check whether an existing certificate remains current — subscribing employees can consent to employers running repeat checks without a new application each time.

A criminal record does not automatically disqualify someone from employment. You must consider the nature and relevance of the offence to the role, its age, and the individual's circumstances since. The only exception is barred individuals for regulated activity — employment there is an absolute prohibition. For all other roles, you should assess the information individually and give the applicant an opportunity to discuss any disclosures before making a decision.

Your organisation should have a written Policy on the Recruitment of Ex-Offenders (required by the DBS Code of Practice for registered bodies) and a data handling policy for DBS certificates. DBS information is sensitive personal data under UK GDPR — it must be stored securely, accessed only on a need-to-know basis, and destroyed once no longer needed (usually by secure shredding within six months of a recruitment decision).

The DBS Update Service allows individuals to subscribe (at £16 per year) to keep their DBS certificate current online. Once subscribed, an employer can carry out a free online status check — with the individual's consent — to confirm whether the certificate remains valid or whether new information has come to light since it was issued. This is the nearest thing to a portable DBS certificate and is particularly valuable in sectors such as healthcare, education, and social care where workers move frequently between employers. However, portability is not absolute: the job role must be of the same type and level as the original check, and the employer must verify the original certificate in person before relying on the status check.

Portability has important limits. Enhanced checks include local police intelligence, which may vary by police force area. An Enhanced check obtained for work in one county may not include relevant local intelligence if the worker moves to a different area. For this reason, some large employers and umbrella bodies require a fresh Enhanced check regardless of Update Service status when staff relocate significantly. Always check your organisation's safeguarding policy on portability before accepting a certificate from a previous employer.

Barred list checks are the most critical component of safeguarding in regulated activity. There are two lists maintained by the DBS: the Children's Barred List and the Adults' Barred List. Employers must check the relevant list for anyone being considered for a regulated activity role. Checking the barred list is only lawful as part of an Enhanced DBS application for a regulated activity role — you cannot check barred lists independently. It is a criminal offence under the Safeguarding Vulnerable Groups Act 2006 to employ a barred person in regulated activity, and a separate criminal offence to fail to refer someone to the DBS for consideration of barring after they have caused harm or posed a risk of harm to a vulnerable group.