DBS (Disclosure and Barring Service) Policy

1. Purpose

Forces & Families United CIC (“FFU”) is committed to safeguarding children, young people, adults at risk, and all individuals who engage with our services.

This policy sets out FFU’s approach to Disclosure and Barring Service (DBS) checks to ensure that individuals working on behalf of FFU are suitable for their roles and that safeguarding risks are minimised.

DBS checks form part of FFU’s safer recruitment, safeguarding, and risk-management framework and are not a substitute for supervision, training, or good governance.

2. Legal Framework

This policy operates in accordance with:

  • The Safeguarding Vulnerable Groups Act 2006

  • The Protection of Freedoms Act 2012

  • The Data Protection Act 2018

  • UK GDPR

  • DBS Code of Practice

  • Relevant safeguarding guidance for voluntary and community organisations

3. Scope

This policy applies to:

  • Directors

  • Volunteers

  • Session leaders and facilitators

  • Contractors and consultants

  • Any individual acting on behalf of FFU

This includes activities delivered in person, online, one-to-one, or in group settings.

4. Regulated and Non-Regulated Activity

FFU recognises the legal distinction between regulated activity and non-regulated activity.

Regulated activity includes (but is not limited to):

  • Unsupervised work with children

  • Unsupervised work with adults at risk

  • Personal care, supervision, advice, or support roles

  • Roles involving positions of trust or authority

Non-regulated activity may include:

  • Administrative or back-office roles

  • One-off supervised activities

  • Support roles without direct safeguarding responsibility

A DBS check may still be required for non-regulated roles where FFU assesses there is safeguarding risk.

5. Levels of DBS Check

FFU may request one of the following depending on role risk:

  • Basic DBS Check

  • Standard DBS Check

  • Enhanced DBS Check

  • Enhanced DBS Check with Barred Lists

The level required will be determined by FFU following a role-based risk assessment.

6. Who Requires a DBS Check

A DBS check is required where a role:

  • Involves regular or intensive contact with children or adults at risk

  • Includes unsupervised access to vulnerable individuals

  • Involves safeguarding responsibility

  • Includes leadership, management, or safeguarding oversight

  • Poses reputational or safeguarding risk to FFU

Individuals must not begin unsupervised work in a role requiring DBS clearance until the check is completed and reviewed.

7. DBS and Recruitment Decisions

A DBS certificate does not automatically disqualify an individual from involvement with FFU.

FFU will:

  • Assess disclosures fairly and proportionately

  • Consider relevance, severity, timing, and role context

  • Apply safeguarding judgment, not blanket exclusion

Failure to disclose relevant information or attempts to mislead FFU may result in withdrawal of role or disciplinary action.

8. Confidentiality and Data Protection

FFU complies fully with data-protection law:

  • DBS certificates are not copied or retained

  • Only essential information is recorded

  • Access is restricted to authorised personnel

  • Data is stored securely and lawfully

DBS information is treated as special category personal data.

9. Ongoing Responsibility

All individuals subject to DBS clearance must:

  • Follow FFU safeguarding policies

  • Maintain professional boundaries

  • Declare new convictions or relevant changes

  • Undertake refresher training as required

DBS clearance does not replace supervision, conduct standards, or safeguarding duties.

10. Breaches

Failure to comply with this policy may result in:

  • Suspension or removal from role

  • Disciplinary action

  • Referral to external authorities where appropriate

11. Review

This policy will be reviewed:

  • Annually

  • Following safeguarding incidents

  • Following changes in law or guidance