Practice recruitment procedures: disclosure and barring service (DBS) checks

A disclosure and barring service (DBS) check helps employers make safer recruitment decisions; however, in general practice, it is mandatory that certain members of staff – all clinical staff, for example – have a DBS. The following guidance is provided by the Care and Quality Commission (CQC), and outlines who should have a disclosure and barring service (DBS) check?

Working within a general practice means working with people – often vulnerable people. To make safe recruitment decisions you will need to have procedures in place to:

• prevent unsuitable people from working with vulnerable groups;
• safeguard service users from abuse.

The following key line of enquiry (KLOE) S1.4 considers how safety is promoted in recruitment practice – including ongoing checks such as DBS checks.

Procedures to undertake DBS checks

Practices should:

• Have processes in place for undertaking criminal record checks at the appropriate level for staff who require them.
• Assess the different responsibilities and activities of staff to determine if they are eligible for a DBS check and to what level.
• Recognise the eligibility for checks, and at what level, depends on the roles and responsibilities of the job and not the individual being recruited. This is based on the level of contact staff have with patients, particularly children and vulnerable adults.

The guidance above has been agreed with the British Medical Association (BMA), the Royal College of General Practitioners (RCGP), the National Clinical Assessment Service (NCAS) and the Medical Defence Union (MDU).

CQC does not decide who is eligible for a DBS check or not. We look at whether suitable procedures are in place and that checks are being carried out appropriately.

To find out who is eligible for a check, you can:

• use the NHS Employers DBS check eligibility tool
• contact the Disclosure and Barring Service.

Clinical staff (including GPs, nurses and healthcare assistants)

Guidance states that all clinical staff require a DBS check.

GPs should have had criminal records checks completed as part of their Performers List checks. In some cases, practices may use these checks rather than obtaining an additional DBS check when the GP begins working for the practice. If so the practice should be able to demonstrate they have suitable assurance from NHS England that an appropriate check has been completed.

Non-clinical staff

There is no general requirement for non-clinical staff (for example reception or administrative staff) to have a DBS check. This depends on their specific duties and responsibilities. Practices may not be breaching regulations if certain non-clinical staff have not received DBS checks. The practice should consider this on a case-by-case basis. For example:

• Access to medical records alone does not mean that non-clinical staff need to receive a DBS check.
• Non-clinical staff who carry out chaperone duties may require a DBS check due to the nature of these duties and the level of patient contact.
• Non-clinical staff who supervise a baby or child whilst their parent or carer is having an appointment will require a DBS check.

If a practice decides not to carry out a DBS check for any non-clinical staff they need to provide a clear rationale for the decision. This should, include an appropriate risk assessment.

Renewal

DBS advise that there is no general requirement to repeat checks for staff that remain employed if there is no change in their place or terms of work. It is up to the employer to decide if and when a new check is needed. Practices should be able to provide evidence that they have appropriately considered where new checks are needed. This includes carrying out risk assessments to support the decision.

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