The Single Central Record Guide

Specific and detailed information on each statutory check

Any offer of appointment made to a successful candidate must be conditional on satisfactory completion of the relevant and necessary pre-employment checks.

It is your statutory duty to ensure that any person in regulated activity has been checked against the relevant barred lists before they start employment.

What is “regulated activity” with children?

A person is considered to be engaging in regulated activity with children if they are employed regularly in a specified place (school, children's home, children's centre, nursery) or if, as a result of their duties, they:

  • Are, or will be, responsible for teaching, training, instructing, caring for or supervising children on a regular basis;
  • Will carry out paid, or unsupervised work regularly in a school or college where this provides an opportunity for contact with children; or
  • Will engage in intimate or personal care – or overnight activity, even if this happens only once.

What is “regulated activity” with adults?

A person is considered to be engaging in regulated activity with adults if they are engaging in these activities:

  • Healthcare: a health care professional or acting under the direction or supervision of one, e.g. doctor, physiotherapist
  • Personal care: assistance with washing, dressing, eating, drinking and toileting; or teaching someone to do these things
  • Social work: provision by a social care worker of social work in connection with health needs or social services
  • Assistance with a person’s cash, bills or shopping due to their age, illness or disability
  • Assistance with conduct of an adult’s own affairs, e.g lasting or enduring power of attorney
  • Conveying adults for reasons of age, illness, disability to, from or between places where they receive healthcare, personal care or social work. This would not include friends, family or taxi drivers.

NB There is no requirement to do activities a certain number of times before a person is engaging in regulated activity with adults.

Identity check / Evidence of Identity

It is your statutory duty to carry out checks to confirm an individual’s identity. Identity checks should be completed before, or as soon as practicable after, any individual takes up their position.

To carry out the statutory duty of an identity check, you must follow GOV.UK’s guidance to:

  • Follow the three route ID checking process as outlined here
  • Check and validate the information provided by the applicant on the application form/continuation sheet
  • Establish the true identity of the applicant through the examination of a range of documents as set out in the above guidance
  • Make sure the applicant provides details of all names by which they have been known
  • Make sure the applicant provides details of all addresses where they have lived in the last five years
  • Check that the application form is fully completed and the information it contains is accurate. Failing to do this can result in delays

The above check should prove and confirm the persons identity, which should match all other documentation.

It is advised in the KCSiE that a copy of the documents used to verify the successful candidate’s identity, right to work and required qualifications should be kept for the personnel file.

Your checklist:

  1. Perform the above identity check
  2. Record the date of the check on your SCR

If your school deems it good practice according to your processes, our SCR Tracker profile also provides default fields for you to input what evidence was seen, and who did the check. Furthermore, you can attach all evidence scans onto each staff record at the bottom of the profile.

Right to work in the UK

It is your statutory duty to conduct a check before you employ an individual, to confirm that they are legally allowed to do the work in question for you.

If an individual’s right to work is time-limited, you should conduct a follow-up check shortly before it is due to come to an end. 

There are two ways to perform a right to work check: manually, or online. Both will be briefly outlined below, but we strongly urge you to follow the GOV.UK guidance here.

How to perform a manual right to work check

  1. Obtain original versions of one or more acceptable documents.
  2. Check the document’s validity in the presence of the holder.
  3. Make and retain a clear copy, signed and dated with a clear statement confirming that the document was verified and copied on this date.

Simply writing a date on the copy document does not, in itself, confirm that this is the actual date when the check was undertaken. If you write a date on the copy document, you must also clearly state and record that this is the date on which you conducted the check.

How to perform an online right to work check

Please follow the GOV.UK steps here

All copies of documents taken should be kept securely for the duration of the worker’s employment and for two years afterwards.

The copy must then be securely destroyed.

The above check should prove and confirm the persons eligibility to work in the UK.

Your checklist:

  1. Perform the above online or manual Right to work in the UK check for the individual
  2. Record the date you performed the check on your SCR

If your school deems it good practice according to your processes, our SCR Tracker profile also provides default fields for you to input who did the check. Furthermore, you can attach all evidence scans onto each staff record at the bottom of the profile.

Please also refer to the full Right to Work guidance on the GOV.UK website here.

DBS checks and certificates, including barred list information

What types of DBS check are there?

The below is directly sourced from the GOV.UK guidance on checks processed by the Disclosure and Barring Service, or DBS:

Types of DBS check that you can request:

  • a basic check, which shows unspent convictions and conditional cautions
  • a standard check, which shows spent and unspent convictions, cautions, reprimands and final warnings
  • an enhanced check, which shows the same as a standard check plus any information held by local police that’s considered relevant to the role
  • an enhanced check with barred lists, which shows the same as an enhanced check plus whether the applicant is on the list of people barred from doing the role

source: https://www.gov.uk/dbs-check-applicant-criminal-record

Schools, colleges and Local Authorities may be registered with the DBS as their own registered body, or may purchase DBS checks from an external Registered or Umbrella body.

An example of something you might find on an enhanced DBS certificate check but not a standard DBS check might be that the individual is being investigated for a crime but has yet to be charged.

When you choose to apply for an enhanced DBS certificate, you may have the option of searching for barred list information. This is typically known as “a barred list check”.

A barred list check searches the children’s barred list and / or adult’s barred list to see whether the applicant is barred from working with either group in regulated activity. Please see [Section 5] for the definition of regulated activity. It is illegal for you to knowingly employ a barred person in the sector from which they are barred.

Once the checks are complete, the DBS will send the certificate to the applicant. The applicant must show the original DBS certificate to their potential employer before they take up post or as soon as is practicable afterwards.

The applicant should present their original paper DBS certificate to the recruiting organisation within 28 days of date of issue; employers cannot require an applicant to produce their certificate earlier than this although they should be encouraged to present it as soon as possible in order to confirm a start date.

If your school or college chooses to allow an individual to start work in regulated activity before the DBS certificate is available, you must ensure the individual is appropriately supervised and that all other checks (including a separate barred list check) have been completed.

The DBS cannot provide barred list information on any person (including volunteers) who are not in, or seeking to enter in, regulated activity.

Your checklist:

  1. Perform the above DBS check relevant to the role
  2. Record the date you performed the check and whether certificates obtained

If your school deems it good practice according to your processes, our SCR Tracker profile also provides default fields for you to input who did the check and the DBS Disclosure number.

Past terminology to note:

The DBS certificate check is formerly known as the “CRB” (Criminal Records Bureau) certificate check, and the barred list check is often confused with the “List 99 check” which no longer exists.

Do I need to keep copies of DBS certificates?

No, schools and colleges do not need to keep copies of DBS certificates in order to fulfil the duty of maintaining the single central record.

To ensure that you comply with the requirements of the Data Protection Act 2018, a copy should not be kept for longer than six months (if a school or college chooses to retain one).

Do I need to do DBS renewals?

No. The Rehabilitation of Offenders Act 1974 (Exceptions Order 1975) gives employers in some sectors (including education) the right to see someone's criminal history at the point they are making a recruitment decision, but not after this point.

The exception to this is if an employer wishes to undertake a new check if there is:

(a)   a break in service of 12 weeks or more

(b)  reason to believe that new information will be disclosed (e.g. when the member of staff discloses that they have a new conviction or caution, or after an allegation of professional abuse has been investigated).

(c)   concern about the member of staff

(d)  a staff member moving from a post not in regulated activity to a post which is in regulated activity

(e)  a staff member moving from a post in regulated activity with children to regulated activity with adults

 This is stated clearly in KCSiE paragraph 162 where, if a staff member moves from a role without regulated activity to a role with regulated activity, they are to be treated as if they are a new member of staff.

The Disclosure & Barring Service website states that a check can be made on a record of ‘someone applying for a role’, and also states in guidance to employers that there is 'no official expiry date for a criminal record check issued by DBS’.

Should I use the DBS Update Service?

The DBS introduced its Update Service in June 2013 as an aid to reducing the number of DBS checks that were needed. Schools are free to decide whether to use the update service or not. It can be sensible to move towards using the DBS Update service, due to cost-effectiveness over time, and being more up-to-date than certificates can be.

A person can register any time up to 28 days from the DBS application being submitted or up to 30 days after the certificate has been printed. The employee registering for the Update Service has to apply and pay £13 with a personal debit card. The employer cannot apply for them, or pay the fee. When the employee is on the Update Service, the employer can reimburse this fee if they wish. Volunteers can apply for free.

When an employee is on the Update Service, employers will usually check their status annually. This status check is online, immediate and free. Employees will be able to see via their personal account who has checked them online and when this check was performed.

On SCR Tracker, you can use an extra column or field where you can note that the employee is on the Update Service, and track their status check date and renewal date. However it is not your statutory duty to show this information on your SCR, so the fields can be hidden upon Inspection.

Previously lived or worked outside the UK check

For these individuals, it is your statutory duty to carry out the same checks as all other staff. In addition to undertaking a DBS check for staff that have lived overseas, it is also necessary for you to undertake further checks with the country where they lived if available.

These checks may include certificates from local police forces or embassies / overseas references, and you must ensure that you follow up on any information provided to you. Documents that are not provided in English must be translated by a certified translator; do not ask the individual to provide a translation.

It is your statutory duty to undertake further checks that you feel are appropriate to surface relevant events that have occurred outside the UK.

For an A-Z list of criminal records checks for overseas applicants, see the guidance here.

Your checklist:

  1. If the candidate has lived or worked overseas, carry out the relevant checks above from local police forces / embassies / references, and follow up on information provided to you
  2. Record the date your checks were made

If your school deems it good practice according to your processes, our SCR Tracker profile also provides default fields for you to input the details of each overseas check you carried out and any notes, as well as who did the check. Furthermore, you can attach all evidence scans onto each staff record at the bottom of the profile.

What about an EEA Sanctions & Restrictions Check?

For candidates who have lived or worked in the EEA, it was your statutory duty to also carry out an EEA Sanctions and Restrictions check between 2016 and 2020.

  • This checks for information about any teacher sanction or restriction that an EEA professional regulating authority has imposed on or after 18th January 2016 and before 1st January 2021, and which have been notified to the TRA.
  • Whilst finding such restrictions does not prevent you from employing this candidate, it is your statutory duty to consider the circumstances that led to this restriction or sanction, and whether the candidate is suitable for employment.

From the 1st of January 2021, the EEA Sanctions and Restrictions check changed. Professional regulators in the EEA will no longer share information with the TRA about sanctions imposed on EEA teachers. Instead, teachers will be asked to provide a letter of professional standing.  

That means that for all new staff, the EEA Sanctions and Restrictions check will not be conducted.

However, you do need to keep this section on your SCR to demonstrate that the checks were done for staff appointed from 2016 to 2020.

On SCR Tracker the EEA Sanctions and Restrictions section will remain on the system so that you have access to historical check data, but we will tweak it slightly so that the 'Are checks Required?' option is off by default for a new member of staff.

See the full guidance here: GOV.UK

New to using the TRA?

The Secure Access / DfE Sign-in portal via the Teaching Regulation Agency’s (TRA) Teacher Services is a free service available to all schools and colleges. Registration is required for first time users and can be requested from Teacher Services.

How do I use the TRA?

Please consult A guide for using the TRA and proceed to this link to sign into the TRA. The school should complete the TRA checks (as appropriate to the role), print the teacher's record to retain in the personnel file and 'claim' the teacher on the TRA website. Alternatively, schools can save the teacher's record on SCR Tracker.

Section 128 check

This check confirms whether or not an individual has been barred from taking up a management role (at an independent school, academy and/or free school), under the terms of a direction made by the Secretary of State for Education.

In order to carry out this check, use the free Employer Secure Access sign-in portal to access the Teaching Regulation Agency’s (TRA) Teacher Services’ web page (see TRA FAQs below).

Here, you can check if a person you are proposing to recruit to a management position is prohibited from undertaking that work under a section 128 direction.

Roles in ‘management’ include but are not limited to:

  • Headteacher
  • Any teaching positions on the senior leadership team
  • Any teaching positions which carry a department headship
  • Members of proprietor bodies
  • Governors if the governing body is the proprietor body for the school
  • And whichever other role you deem with reason as ‘taking part in management’

You can also request a section 128 direction to be disclosed during an enhanced DBS check when you request barred list information. To do this, you must specify that ‘children’s workforce independent schools’ is stated as the employment on the application form.

Your checklist:

  1. Establish whether the person requires a Section 128 check, and perform the above check using the TRA or during an enhanced DBS check
  2. Record the date of when you performed the check

If your school deems it good practice according to your processes, our SCR Tracker profile also provides a default field for you to input the details of who did the check.

New to using the TRA?

The Secure Access / DfE Sign-in portal via the Teaching Regulation Agency’s (TRA) Teacher Services is a free service available to all schools and colleges. Registration is required for first time users and can be requested from Teacher Services.

How do I use the TRA?

Please consult A guide for using the TRA and proceed to this link to sign into the TRA. The school should complete the TRA checks (as appropriate to the role), print the teacher's record to retain in the personnel file and 'claim' the teacher on the TRA website. Alternatively, schools can save the teacher's record on SCR Tracker. 

Prohibition from teaching check (and GTCE sanctions)

This is a required check for new starters to check prior to appointment that a teacher is not prohibited from teaching. In order to carry out this check, use the free Employer Secure Access sign-in portal to access the Teaching Regulation Agency’s (TRA) Teacher Services’ web page (see TRA FAQs below).

A person who is prohibited must not be appointed to a role that involves teaching work in schools, sixth form colleges, 16-19 academies, relevant youth accommodation and children’s homes in England.

This check used to only apply to teachers who had qualified teacher status (QTS), but this is no longer the case.

For any teachers appointed after the 1st of April 2012 who have not been checked, you should carry out this check retrospectively. Although there is no requirement to retrospectively check teachers who commenced their current employment prior to that date it would still be prudent to do so.

There remains a number of individuals who are still subject to disciplinary sanctions, which were imposed by the General Teaching Council for England (GTCE) prior to its abolition in 2012.

New to using the TRA?

The Secure Access / DfE Sign-in portal via the Teaching Regulation Agency’s (TRA) Teacher Services is a free service available to all schools and colleges. Registration is required for first time users and can be requested from Teacher Services.

How do I use the TRA?

Please consult A guide for using the TRA and proceed to this link to sign into the TRA. The school should complete the TRA checks (as appropriate to the role), print the teacher's record to retain in the personnel file and 'claim' the teacher on the TRA website. Alternatively, schools can save the teacher's record on SCR Tracker.

Professional qualification check

Where a qualification is a requirement for the role, you must check and confirm evidence of such professional qualifications as part of your record.

This includes QTS, QTLS, NPQH and registration as a teacher with the DfE. In order to carry out this check, use the free Employer Secure Access sign-in portal to access the Teaching Regulation Agency’s (TRA) Teacher Services’ web page (see TRA FAQs below).

If you know the teacher’s reference number (TRN), and date of birth, you can use the teacher search facility in Teacher Services to view the record for any individual you are considering, including any trainee, newly qualified, or fully qualified teacher.

 Amongst other details, you’ll be able to:

  • view a teacher’s initial teacher training qualifications
  • confirm if they have been awarded QTS
  • check whether they have successfully completed their teacher induction period
  • view any additional qualifications, including relevant mandatory qualifications and national professional qualifications

If you do not know the individual’s TRN, you will still have access to alphabetical lists of teachers and others with current prohibitions, restrictions, sanctions, or who have failed induction/probation.

If you want to confirm if an individual is eligible for employment in a role which requires QTS as a result of receiving Qualified Teacher Learning and Skills (QTLS) status, you will need to contact the Society for Education and Training.

What is QTS?

QTS, or qualified teacher status, must be attained in order to take up a teaching post in England in a:

  • maintained primary school
  • maintained secondary school
  • maintained special school
  • non-maintained special school

New to using the TRA?

The Secure Access / DfE Sign-in portal via the Teaching Regulation Agency’s (TRA) Teacher Services is a free service available to all schools and colleges. Registration is required for first time users and can be requested from Teacher Services.

How do I use the TRA?

Please consult A guide for using the TRA and proceed to this link to sign into the TRA. The school should complete the TRA checks (as appropriate to the role), print the teacher's record to retain in the personnel file and 'claim' the teacher on the TRA website. Alternatively, schools can save the teacher's record on SCR Tracker. 

For more information, see the full GOV.UK guidance here.

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