Disclosure of Information & Disclosure & Barring Service Policy

This policy operates in line with the Centre’s Confidentiality Policy and Recruitment of Offenders Policy.

General Principles

As an organisation using the Disclosure & Barring Service (DBS) to help assess the suitability of applicants for positions of trust, Bath Child Contact Centre complies fully with the DBS Code of Practice and undertakes to treat all clients, applicants for positions and stakeholders fairly. It undertakes not to discriminate unfairly against any subject of a Disclosure on the basis of a conviction or other information revealed.

The Centre also complies fully with its obligations under the Data Protection Act 1998 and other relevant legislation pertaining to the safe handling, use, storage, retention and disposal of Disclosure information and has a written policy on these matters, detailed below.

As a member of the National Association of Child Contact Centres and as part of the National Standards, the Centre uses the National Association to process its DBS Disclosures.


All advertisements for positions within the Centre, whether for volunteers or paid staff, will contain the statement that a DBS Disclosure will be requested in the event of a successful applicant.

In accordance with the Rehabilitation of Offenders Act 1974, all application forms will contain the statement that a criminal record will not necessarily be a bar to obtaining a position.

Paid Staff / Volunteers / Management Committee

The Centre recognises that an offence listed in a Disclosure is not necessarily a bar to employment.

Any applicant, on completion of the DBS form, agrees to submit the DBS Disclosure to the Centre on receipt.

The Centre will review any information listed in a Disclosure and in accordance with the DBS Code of Practice will consider the following when reviewing an applicant’s suitability:

a. Whether the conviction or other matter revealed is relevant to the position in question;
b. The seriousness of any offence or other matter revealed;
c. The length of time since the offence or other matter occurred;
d. Whether the applicant has a pattern of offending behaviour or other relevant matters; and
e. The circumstances surrounding the offence and the explanation(s) offered by the convicted person.

The Management Committee or persons with legal responsibility will have the final decision as to the suitability of an appointment of a person whose application is subject to Disclosure information. This decision will be taken in accordance with the Rehabilitation of Offenders Act 1974 and will be after discussion with the individual applicant.

Each applicant will be made aware that upon request a copy of the DBS Code of Conduct and this policy can be provided. This statement will be included in the application form.

The Centre processes all Disclosures at the level of ‘enhanced’ as defined by the Disclosure & Barring Service.

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.


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 is revealed and all parties are made aware that it is a criminal offence to pass this information on to anyone who is not entitled to receive it.


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.


Disclosure information is retained for the full duration of the qualification term, normally three years, following our safe storage procedures and controlled access.

After the three year duration, updated Disclosure information is requested and again retained securely. The previous Disclosure information is then destroyed following our disposal procedures.

Earlier disposal only takes place should a volunteer / employee resign from their position.


Once the retention period has elapsed, we will ensure that any Disclosure 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). No photocopy or other image of the Disclosure, or any copy or representation of the contents of a Disclosure will be kept. However, notwithstanding the above, a record of the date of issue of a Disclosure, name of the subject, 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, may be kept.