LIGHTHOUSE CENTRAL DBS POLICY

 Updated: 28th February 2023

Definitions

Throughout this policy, the term ‘Lighthouse’ shall be taken to mean, collectively:

• Lighthouse Beaconsfield, Registered Charity No.1198953
• Lighthouse Burnham, Registered Charity No. 1182190
• Lighthouse Cressex, Registered Charity No. 1183476
• Lighthouse Haddenham, Registered Charity No. 1201685
• Lighthouse Hazlemere, Registered Charity No. 1178562
• Lighthouse High Wycombe, Registered Charity No. 1114541
• Lighthouse Langley, Registered Charity No. 1181000
• Lighthouse Loudwater, Registered Charity No. 1197125 
• Lighthouse Mansfield, Registered Charity No. 1164680
• Lighthouse Marlow, Registered Charity No. 1178062
• Lighthouse Princes Risborough, Registered Charity No. 1178119
• Lighthouse Safe Harbour, Registered Charity No.1180779
• Lighthouse Shelswell, Registered Charity No. 1187651
• Lighthouse Central, Registered Charity No. 1169839

and Lighthouse Water Eaton which is an associate Lighthouse through St Frideswide’s Church, a resource hub in the Diocese of Oxford for community organising and church growth.

These charities share a common administration system and database.  Applicants may transfer between Lighthouses at any time.  Data including DBS Disclosure information that is shared is done so under GDPR regulations.

This policy should be read in conjunction with the Lighthouse Safeguarding Policy and covers:

1. DBS Policy
2. Recruitment of Ex-offenders
3. Secure Storage, Handling, Use, Retention & Disposal of Disclosures and Disclosure Information

1.            Overall Statement of Policy on Safeguarding

The Trustees and Management Teams of each Lighthouse recognise the importance of our ministry with children and young people in need of protection and our responsibility to protect everyone entrusted to our care.  We are committed to their safeguarding and well-being.

Specifically:

• We believe all adults should enjoy and have access to every aspect of the life of Lighthouse unless they pose a risk to the safety of those we serve.
• We undertake to exercise proper care in the appointment and selection of all those who will work with children and young people.

We are committed to:

• Keeping up to date with and following UK legislation; denominational requirements and good practice recommendations in relation to safeguarding children and young people.

In support of these ends we will:

• Apply current nationally required procedures and good practice recommendations in the recruitment of leaders and helpers

2.            DBS Policy

• Lighthouse Central will observe guidance issued or supported by the Disclosure and Barring Service (DBS) and will comply fully with the DBS Code of Practice and Explanatory Guide.
• We will not unfairly discriminate against the subject of Disclosure information on the basis of conviction or other details revealed in accordance with our policy on the recruitment of ex-offenders (see below)
• We will handle, use, store, retain and dispose of Disclosure information in full compliance with the DBS Code and in full accordance with our policy on the handling and safe keeping of Disclosure information (see below). To this end we will not copy any completed application forms.
• Lighthouse Central will ensure that Disclosures and the information they contain are available only to those who need to have access in the course of their duties.
• Lighthouse Central will co-operate with requests from the DBS to undertake assurance checks as to the proper use and safekeeping of Disclosure information.
• Lighthouse Central will report to the DBS any suspected malpractice in relation to the DBS Code of Practice or any suspected offences in relation to the misuse of Disclosures.
• Each Lighthouse will appoint a DBS administrator who will ensure that all persons involved in checking DBS applications for their Lighthouse are trained in and kept up to date on changes to DBS requirements.  We are aware of the potential pitfalls of identity checks being carried out by connected persons and ensure that DBS identity checks are not undertaken by any such connected persons.
• An Enhanced DBS check is required for all volunteers aged 16 and over, including Trustees and other management committee members.
• If a volunteer is not on site at the same time as children (e.g. overnight security, car park attendant, site build up and breakdown) no DBS is required.
• If the applicant refuses to complete a DBS application, we will not proceed further with the applicant. In addition if an applicant fails to complete a DBS after having a Trustee sign-off the previous year Lighthouse will be unable to proceed further with this applicant.
• In exceptional circumstances e.g. where the applicant has applied too late or is unable to provide the appropriate supporting documentation Lighthouse may still offer the applicant a volunteer position but only after a careful risk assessment. This is entirely at the discretion of the Trustees and will be clearly documented in the individual’s record in the database.
• Volunteer positions will be conditional upon a satisfactory DBS check having been received
• Lighthouse accepts existing DBS disclosures from other organisations where the applicant has registered with the DBS Update Service and has given us permission to check their DBS disclosure via this service.
• Lighthouse accepts existing Enhanced Child Workforce DBS disclosures from key organisations namely: the Church, Schools, charities, children’s homes, fostering service, organisations working with young people such as scouts, Girls Brigade etc. The volunteer will need to show the certificate and a form of ID with an address to a Lighthouse DBS checker
• Disclosures and the information they contain will only be available to those who need to have access in the course of their duties.
• DBS applications will be processed through Peters Research on behalf of Lighthouse Central. There is a charge of £3.00 per application processed paid by the Lighthouse.
• We will issue to the applicant guidance notes and DBS application forms. We will also advise each applicant of the existence of the DBS Code of Practice and make a copy available upon request.
• Volunteers are required to sign a declaration that they have read and understood the Disclosure and Barring Service Standard and Enhanced DBS Check Privacy Policy.  https://www.gov.uk/government/publications/standard-and-enhanced-dbs-check-privacy-policy/standard-and-enhanced-dbs-check-privacy-policy
• We will provide training for all checkers. Only when this training has been completed and they have signed to confirm their adherence to the procedures will they be considered an authorised checker.
• We will check the applications and relevant proofs of identity in line with the guidelines provided by the DBS. All relevant details will be recorded on the application form and where necessary on an additional information sheet. We only conduct ID checks on a face to face basis. If an applicant is unable or unwilling to comply with this policy they will be advised to use the 'Veri-fy' service.  https://www.veri-fy.co.uk/
• Completed applications will be forwarded to Lighthouse Central for processing.
• If there are any errors or omissions the form will be returned by Lighthouse Central with a covering note to the appropriate Lighthouse DBS checker. It is the responsibility of each checker to contact the applicant to make the necessary amendments.
• No copies of application forms will be kept.
• On reviewing the applicant's DBS Certificate the Lighthouse DBS administrator will update the LH database to show that the DBS is satisfactory. In the event of it not being satisfactory the Lighthouse DBS administrator will contact the relevant Lighthouse chairman who will then review the volunteer’s application to see if the information on the DBS Certificate is in line with the information supplied at the time of application. If not, the Lighthouse chairman will contact the applicant to provide them with a final opportunity to supply information about any un-declared convictions. The Lighthouse chairman, in consultation with other trustees, will make the decision as to whether or not the applicant may be accepted.  If full information has not been provided, the applicant will be refused automatically.
• At no time will Lighthouse Central be involved in recruitment decisions.
• No copies of DBS disclosures will be kept.
• The Database has Risk Assessments with details of all applicants who do not have a fully executed DBS Disclosure ie: application processed by the DBS, certificate issued and seen by the DBS checker.

3.            Lighthouse Policy Statement on the Recruitment of Ex-offenders

• As an organisation using the DBS Disclosure service to assess applicants’ suitability for positions of trust, Lighthouse complies fully with the DBS Code of Practice and undertakes to treat all applicants for positions fairly. It undertakes not to discriminate unfairly against any subject of a Disclosure on the basis of a conviction or other information revealed.
• Lighthouse is committed to the fair treatment of its staff, potential staff or users of its services, regardless of race, gender, religion, sexual orientation, responsibilities for dependants, age, physical/mental disability or offending background.
• This policy statement on the recruitment of ex-offenders is made available to all Disclosure applicants at the outset of the recruitment process (advertised as available from www.lighthousecentral.org or on request).
• We actively promote equality of opportunity for all with the right mix of talent, skills and potential and welcome applications from a wide range of candidates, including those with criminal records. We select all candidates based on their skills, qualifications and experience.
• A Disclosure is always requested as Lighthouse is working with children and young people.  All application forms will contain a statement that a Disclosure will be requested.  We ask all applicants to provide details of their criminal record on the application form provided.  This form will only be seen by those who need to see it as part of the recruitment process.
• As a position with Lighthouse may lead to having sole charge of children, young people or vulnerable adults, applicants are exempt from the “Rehabilitation of Offenders Act 1974”.  We therefore require details of both “spent” and “unspent” convictions as defined in the act.
• We will ensure that all those in Lighthouse who are involved in the recruitment process fully understand how to identify and assess the relevance and circumstances of offences. We also ensure that they have received appropriate guidance in the relevant legislation relating to the employment of ex-offenders, e.g. the Rehabilitation of Offenders Act 1974.  In the first instance, we will ensure that all who are involved in the recruitment process are aware of the guide produced by social justice charity NACRO (National Association for the Care and Resettlement of Offenders) in association with CIPD and DBS.  https://www.nacro.org.uk/resettlement-advice-service/support-for-employers/recruiting-safely-and-fairly-guide-a-practical-guide-to-employing-ex-offenders/
• In any interview, we will ensure that an open and measured discussion takes place on the subject of any offences or other matter that might be relevant to the position. Failure to reveal information that is directly relevant to the position sought could lead to withdrawal of an invitation to participate.
• We make every subject of a DBS Disclosure aware of the existence of the DBS Code of Practice and make a copy available on request. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/474742/Code_of_Practice_for_Disclosure_and_Barring_Service_Nov_15.pdf
• We undertake to discuss any matter revealed in a Disclosure with the person seeking the position before declining the applicant a position at Lighthouse. Having a criminal record will not necessarily bar an applicant from working with Lighthouse. This will depend on the nature of the position and the circumstances and background of the applicant’s offences.

4.            Lighthouse Policy Statement on the Secure Storage, Handling, Use, Retention & Disposal of Disclosures and Disclosure Information

• General Principles: As an organisation using the Criminal Records Bureau (DBS) Disclosure service to help assess the suitability of applicants for positions of trust, Lighthouse complies fully with the DBS Code of Practice regarding the correct handling, use, storage, retention and disposal of Disclosures and Disclosure information. It also complies fully with its obligations under GDPR (2018) and other relevant legislation pertaining to the safe handling, use, storage, retention and disposal of Disclosure information and has a Lighthouse Data Privacy Notice on these matters, which is available at www.lighthousecentral.org
• Storage and access: Disclosure information will be kept securely, in lockable, non-portable, storage containers with access strictly controlled and limited to those who are entitled to see it as part of their duties.
• Handling: In accordance with section 124 of the Police Act 1997, Disclosure information is only passed to those who are authorised to receive it in the course of their duties. We maintain a record of all those to whom Disclosures or Disclosure information has been revealed and recognise that it is a criminal offence to pass this information to anyone who is not entitled to receive it.
• Usage: Disclosure information is only used for the specific purpose for which it was requested and for which the applicant’s full consent has been given.
• Retention: Once a recruitment (or other relevant) decision has been made we do not keep certificate information for any longer than is necessary. This is generally for a period of up to six months, to allow for the consideration and resolution of any disputes or complaints. If, in very exceptional circumstances, it is considered necessary to keep certificate information for longer than 6 months, we will consult DBS about this and will give full consideration to the data protection and human rights of the individual before doing so. Throughout this time, the usual conditions regarding safe storage and strictly controlled access will prevail.
• Disposal:   Once the retention period has elapsed, we will ensure that any DBS Certificate information is immediately destroyed by secure means, i.e. by shredding, pulping or burning. While awaiting destruction, Disclosure information will not be kept in any insecure receptacle (e.g. waste bin or confidential waste sack). We will not keep any photocopy or other image of the Disclosure or any copy or representation of the contents of a Disclosure. However notwithstanding the above we will keep a record of the date of issue of a Disclosure, the name of the subject, the type of Disclosure requested, the position for which the Disclosure was requested, the unique reference number of the Disclosure and the details of the recruitment decision taken for a period of 15 years. This is a requirement of our insurance policy.