03 Apr Detailed guide: DBS checks: guidance for employers
An employer may request a criminal record check as part of their recruitment process. These checks are processed by the Disclosure and Barring Service (DBS).
For certain roles, the check will also include information held on the DBS children’s and adults’ barred lists, alongside any information held by local police forces, that is considered to be relevant to the applied-for post.
These checks are to assist employers in making safer recruitment and licensing decisions, however a check is just one part of recruitment practice. When a check has been processed by the DBS and completed, the applicant will receive a DBS certificate.
The DBS can’t access criminal records held overseas so a DBS check may not provide a complete view of an applicant’s criminal record if they have lived outside the UK.
Employers should still ensure that they have access to all the information available to them, to make a safer recruitment decision. You can read about how to get a criminal record check for overseas applicants, or those who have previously lived outside the UK, on the Home Office website.
Eligibility to ask ‘an exempted question’
Access to the DBS checking service is only available to registered employers who are entitled by law to ask an individual to reveal their full criminal history, including spent convictions – this excludes protected cautions and convictions that will be filtered from a criminal record check – also known as asking ‘an exempted question’.
An exempted question applies when the individual will be working in specific occupations, for certain licenses and specified positions. These are covered by the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975.
The minimum age at which someone can be asked to apply for a criminal record check is 16 years old.
More information about who is eligible for a criminal record check, can be found in the DBS eligibility guidance.
The code of practice
The code of practice is issued under section 122(2) of the Police Act 1997. Organisations using the DBS checking service must comply with the code of practice. It is there to ensure that organisations are aware of their obligations, and that the information released will be used fairly.
The code also ensures that sensitive and personal information, disclosed by the DBS, is handled and stored appropriately and is kept for only as long as is necessary.
The code of practice for registered persons and other recipients of DBS check information can be found here.
Storing information for DBS certificate information
The correct storage of DBS certificate information is important. The code of practice requires that the information revealed is considered only for the purpose for which it was obtained and should be destroyed after a suitable period has passed – usually no longer than six months.
Organisations must use any information revealed on DBS certificates fairly. More information on the handling and storage of DBS certificate information is available.
Organisations must also satisfy the DBS that they are complying with the code of practice. This means cooperating with requests from the DBS to carry out assurance checks, and reporting suspected malpractice that relates to the code or misuse of DBS certificates.
If we believe that the code of practice isn’t being followed, we can refuse to issue a DBS certificate.
Usually, a job applicant has no legal obligation to reveal spent convictions. If an applicant has a conviction that has become spent, the employer must treat the applicant as if the conviction has not happened. A refusal to employ a rehabilitated person on the grounds of a spent conviction is unlawful under the Rehabilitation of Offenders Act (ROA) 1974.
Certain areas of employment are exempt under the ROA 1974 (Exceptions) Order 1975, and employers may ask about spent convictions – this is known as asking an exempted question. When answering, the applicant would have a legal obligation to reveal spent convictions.
The code of practice states that information on a DBS certificate should only be used in the context of a policy on the recruitment of ex-offenders. This is designed to protect applicants from unfair discrimination, based on non-relevant past convictions. We have created a specimen policy on the recruitment of ex-offenders to help guide organisations.
The minimum age at which someone can be asked to apply for a criminal record check is 16 years old.
Transgender process for DBS checks
DBS offers a confidential checking process for transgender applicants.
This process is for transgender applicants who do not wish to reveal details of their previous identity to the person who asked them to complete an application form for a DBS check.
A self-employed person who is eligible for a standard or enhanced DBS check can ask the organisation that wishes to contract their services, to apply for their check.
A self-employed person who needs a basic check can apply through the DBS’ online application route if they live or work in England or Wales. They can apply to Disclosure Scotland if they live or work in Scotland.
Registering as an organisation with the DBS
Organisations can either register with DBS if they submit more than 100 check applications per year, or they can use an organisation offering umbrella body services to apply for DBS checks.
To satisfy the conditions of registration you must:
- submit more than 100 eligible DBS check applications per year
- be entitled to ask exempted questions under the Rehabilitation of Offenders Act 1974
- comply with the DBS code of practice
- pay the appropriate fees in relation to applications for DBS checks, as well as registration of the organisation and countersignatories
You must also provide specific and up-to-date information to the DBS for registration to be granted. This includes:
- organisation status
- proposed countersignatories and lead countersignatory
- the nature of your business
- the positions of employment you intend to submit the checks for
- how you intend to meet the threshold of 100 applications per year
Details of the RBS Compliance Policy can be found here.
Cost of registration
Registration costs £300, with a £5 cost for each countersignatory to be registered.
Your registration fee will be charged after the DBS has assessed your registration documentation, carried out pre-registration checks and invited you to register.
Call our Customer Services team on 03000 200 190 to request a pre-registration questionnaire and information pack.
Using the e-bulk service
If you are registered directly with the DBS, and you submit at least 1,500 applications per year, you may be able to use the e-bulk electronic application system.
More about the e-bulk service can be found here.
Changing your registration details
All Registered Bodies must keep the DBS informed about any changes to their registration details including the following:
- your organisation no longer wishes to be registered with the DBS
- your organisation wishes to become, or cease to be, an umbrella body
- your lead countersignatory is leaving (or has already left) and needs to be replaced by another person
- a countersignatory(ies) is leaving or no longer performs this role
- your organisation changes its name and/or address
- a countersignatory changes their name, signature and/or address
- the lead countersignatory changes their name, signature and/or address
Failure to keep your details up-to-date may result in delays to the service that we provide.
You should inform the DBS in writing, on company letter-headed paper, and provide the following information:
- registered body number
- your (lead) countersignatory number and signature
- details of the change(s) – such as the previous and new name/address of the registered body, the effective date of the change, and the name and registration number(s) of the countersignatories affected
If the lead signatory or a countersignatory is not available, a letter from a director or equivalent can be accepted.
Send your letter to:
DBS Customer Services
PO Box 3961
Royal Wootton Bassett
Countersignatories have an important role in the DBS checking process.
A countersignatory is a person within a Registered Body who is registered with the DBS to countersign applications, making a declaration that the position is eligible for the DBS check requested.
Guidance is available to help you complete the countersignatory application form.
A lead countersignatory is a senior figure within a Registered Body who will oversee the DBS process within their organisation.
Guidance is available to help you complete the lead countersignatory application form.
The minimum age at which someone can apply to become a countersignatory is 18 years old.
Using umbrella body services to submit DBS checks
An umbrella body is a Registered Body that gives other non-registered organisations access to DBS checks.
If your organisation has a requirement to carry out fewer than 100 checks per year, you should use the services of an umbrella body. Your organisation must also be eligible to ask the exempted question.
If you are already a Registered Body and would like to offer an additional umbrella service, you should email firstname.lastname@example.org.
ID validation for DBS checks
When an individual applies for a DBS check their identity must be verified by the Registered Body.
Registered Bodies must follow the DBS 3-route identity checking process to validate the name, date of birth and address provided by the applicant in sections ‘a’ and ‘b’ of the application form.
More information can be found in the DBS identity checking guidelines.
Failure to validate an applicant’s identity
If the applicant’s identity has not been validated by the 3-route process, the countersignatory should mark the ‘no’ box at question ‘w59’ on the application form and return the form to the DBS. You may be asked to review this decision by the DBS before the application can proceed, which may delay the overall process.
Applicants who cannot provide the necessary documents will be asked to go for fingerprinting at their local police station. This is likely to cause delay to the overall application process.
Dealing with discrepancies on the application form
If there are any discrepancies between the information on the form and the identity documents supplied, and fraud is not suspected, you should seek clarification from the applicant.
Do not attempt to amend the application form without the applicant’s knowledge and agreement, as it will invalidate the declaration by the applicant in section ‘e’ of the form and may breach data protection legislation.
If you suspect that you have been presented with a false identity or documents, do not proceed with the application process. You should report suspected identity fraud on the Action Fraud website.
Types of DBS checks and how to apply
Types of DBS checks
Basic check – £25
The basic check can be used for any position or purpose. A basic certificate will contain details of convictions and cautions from the Police National Computer (PNC) that are considered to be unspent under the terms of the Rehabilitation of Offenders Act (ROA) 1974.
Standard check – £26
The standard check is available for duties, positions and licences included in the Rehabilitation of Offenders Act (ROA) 1974 (Exceptions) Order 1975, for example, court officers, employment within a prison, and Security Industry Authority (SIA) licences.
A standard level certificate contains details of all spent and unspent convictions, cautions, reprimands and final warnings from the Police National Computer (PNC) which have not been filtered in line with legislation.
Enhanced check – £44
The enhanced check is available for specific duties, positions and licences included in both the Rehabilitation of Offenders Act 1974 (Exceptions Order 1975) and the Police Act 1997 (Criminal Records) regulations, for example, regularly caring for, training, supervising or being solely in charge of children, specified activities with adults in receipt of health care or social care services and applicants for gaming and lottery licences.
An enhanced level certificate contains the same PNC information as the standard level certificate but also includes a check of information held by police forces.
Enhanced with a barred list check – £44
The enhanced check with barred list check(s) is only available for those individuals who are carrying out regulated activity and a small number of positions listed in Police Act 1997 (Criminal Records) regulations, for example, prospective adoptive parents and taxi and Private Hire Vehicle (PHV) licences.
An enhanced level certificate with barred list check(s) contains the same PNC information and check of information held by police forces as an enhanced level check but in addition will check against the children’s and/or adult’s barred lists.
If your application includes a request to check the barred list(s) the DBS has a statutory duty to consider any information that suggests you may pose a risk of harm. We will write to you if you are affected.
DBS adult first check – £6
DBS adult first is a service available to organisations who can request a check of the DBS adults’ barred list. Depending on the result, a person can be permitted to start work, under supervision, with vulnerable adults before a DBS certificate has been obtained.
More guidance regarding adult first checks can be found here.
The requests carry strict criteria:
- the position must require a criminal record check by law
- the position must be eligible for access to the DBS adults’ barred list
- the organisation must have requested a check of the DBS adults’ barred list on the DBS application form
The DBS’ reply to an adult first check request will contain one of the following responses and will clearly state that it only forms the first part of the criminal record check application process and that further information will follow:
- option 1: ‘Registered Body must wait for the DBS certificate’
- option 2: ‘no match exists for this person on the current adults’ barred list’
If the adult first check indicates that the Registered Body must wait for the DBS certificate, the details provided may have indicated a match on the DBS adults’ barred list. However, further investigation is required to confirm this and you should await the certificate. Alternatively, the check will state that no match exists for the individual on the adults’ barred list.
How to apply for a DBS check
Standard or enhanced checks
As an employer or Registered Body, you provide the candidate with a DBS application form to complete and return to you.
Registered Bodies can order new forms through our online tracking service or by calling us on 03000 200 190.
You must make sure the application form is fully completed and the information is accurate. You also need to confirm the applicant’s identity and verify evidence of their name, date of birth and current address.
Guidance is available on completing the form below.
If a basic check is required, the employer can ask the individual to apply directly to DBS (if they work in England or Wales) or Disclosure Scotland (if they work in Scotland). Alternatively, the employer can carry out the check through a Responsible Organisation, if they have the applicant’s consent.
Where possible, countersignatories should only record the information required in the relevant boxes provided on the application form. Where this is not possible, countersignatories should submit a DBS continuation sheet together with the application form.
Where to send the completed form
Once you have signed and dated the application form, you should send the application to:
PO Box 3961
Royal Wootton Bassett
Avoiding common mistakes on the DBS application form
A list of the most recent common errors made on the DBS application form, and guidance for both applicants and countersignatories, can be found here.
The DBS definition of a volunteer is defined in the Police Act 1997 (criminal records) Regulations 2002 as:
“Any person engaged in an activity which involves spending time, unpaid (except for travel and other approved out-of-pocket expenses), doing something which aims to benefit some third party and not a close relative.”
To qualify for a free-of-charge criminal record check, the applicant must not:
- benefit directly from the position for which the DBS application is being submitted
- receive any payment (except for travel and other approved out-of-pocket expenses)
- be on a work placement
- be on a course that requires them to do this job role
- be in a trainee position that will lead to a full-time role/qualification
It states on the DBS application form ‘By placing a cross in the yes box (at section 68) you confirm that the post meets the DBS definition for a free-of-charge volunteer application. Please note that DBS may recover the application fee if box 68 is marked in error and this could result in the cancellation of your DBS registration’.
Only standard or enhanced volunteer applications are free-of-charge.
Please read through the examples in the table below showing common volunteer errors.
Examples of eligible and ineligible volunteer roles
|Position applied for||DBS volunteer status||Reasoning|
|Parent helpers in schools||Eligible||This activity is entirely voluntary, is unpaid and is primarily aimed at providing a service to a third party|
|Scout/Guide||Eligible||This activity is entirely voluntary, is unpaid and is primarily aimed at providing a service to a third party|
|Adoptive parents and other household members over 18 years old||Eligible||This activity is entirely voluntary, is unpaid and is primarily aimed at providing a service to a third party|
|Foster carers and members of the same household over 18 years old||Ineligible||This activity is entirely voluntary but foster carers usually receive payments for these activities therefore it is deemed that neither foster carers nor other members of the household are entitled to free checks|
|Individuals working abroad on volunteering projects||Ineligible||This activity is entirely voluntary and is primarily aimed at providing a service to a third party, but these persons usually receive payment of a local salary and lump sum payments above and beyond what could be described as ‘travel and other approved out-of-pocket expenses’. If no salary or lump sum payment is received, then they are eligible for a free-of-charge criminal record check|
|Medical/teaching/social work student on work placement, as part of training||Ineligible||This activity is a mandatory course requirement, is usually paid and is primarily undertaken to benefit the student|
If you need further guidance please email email@example.com.
Stages of the DBS checking process
Stages of the DBS checking process
The process for a basic check varies to the stages detailed below, as stages 3 and 4 do not apply.
Stage 1 – application form received and validated
The application form is checked for errors or omissions. The form is either scanned onto the DBS system or returned for correction to the countersignatory within 24 hours of receipt.
Stage 2 – Police National Computer (PNC) searched
Key data from the application form is compared against details from the Police National Computer (PNC) to search for any matches.
Stage 3 – Children and adults’ barred lists searched (where applicable)
Key data from the application form is compared against barred lists to search for any matches.
Stage 4 – Records held by the police searched
Enhanced checks are sent by secure, electronic means to the police for an additional check of records before the information is sent back to the DBS. Your details may be same as, or similar to details held at any police force across the country. To make sure potential matches are not missed, those police forces will check the details against their information.
Stage 5 – DBS certificate printed
All the information to be disclosed is printed under highly secure procedures and posted to the applicant. The applicant will then need to show their DBS certificate to the employer who requested the criminal record check.
How to track a DBS application
Standard or enhanced checks
The DBS provides a free, online tracking service that allows you to track the progress of either of these standard or enhanced types of application:
You will be able to see:
- what stage the application has reached in the checking process
- if an application had to be returned due to errors
- if the results of the criminal record check have been dispatched
Tracking individual applications
You will need:
- an application form submitted to the DBS
- an application form reference number
- the date of birth of the applicant
Tracking multiple applications
You will need to provide the:
- registered body number
- countersignatory number
- countersignatory’s date of birth
The person being given a DBS check (the applicant), employers and Responsible Organisations can track the progress of basic checks by using the DBS online account tracking service. They do not need to create an account however they will need the application reference number, applicant’s surname and date of birth.
This guide provides more information regarding tracking a basic check application. ##Ordering blank DBS application forms
Registered organisations and countersignatories who can access the multiple applications tracking service can order blank application forms online, using the same login details.
You can also call the DBS helpline to order blank application forms.
You must be registered with DBS to order blank application forms.
Processing times for DBS checks
Each application is different and the completion time can vary with some checks taking longer, especially if they are at an enhanced level and are referred to the police for checks against non-conviction data.
You can find out more about processing times on our performance pages.
Individuals can join the Update Service which allows them to reuse their DBS certificates when applying for similar jobs.
The Update Service is only available for standard and enhanced checks. You cannot join the Update Service with a basic check.
More information about the Update Service can be found here.
To enable individuals to reuse their DBS certificates in the Update Service, Registered Bodies must now include the relevant workforce in line 1 and the ‘Position Applied For’ in line 2 of field x61 on the application form.
Filtering information and guidance
Certain specified old and minor offences are removed from criminal record certificates issued from 29 May 2013 – this is known as filtering.
More information about the filtering process can be found in the DBS filtering guidance.
Checking via the DBS
DBS cannot access criminal records held overseas, but it is possible to submit an application while the applicant is overseas.
In a small number of cases, overseas criminal records are held on the Police National Computer (PNC) and these would be revealed as part of a criminal record check. You must still verify the identity of an overseas applicant.
As the DBS cannot access criminal records held overseas, a criminal record check may not provide a complete picture of an individual’s criminal record.
For more information please see the following Home Office guidance: Criminal records checks for overseas applicants
Checking via embassies
If you are recruiting people from overseas and wish to check their overseas criminal record, you should contact the embassy or High Commission of the country in question.
Contact details for embassies and High Commissions in the UK can be found on the Foreign & Commonwealth Office (FCO) website.
You can also contact the FCO Response Centre on 020 7008 1500.
If the foreign check needs translating, the embassy of the country concerned may be able to help.
The DBS is not involved in the processing of applications made by individuals to overseas authorities and will not be responsible for the contents or the length of time taken for information to be returned.
Certificates of good conduct
You should try to obtain a certificate of good conduct, and any other references, from potential overseas employees. The standard of foreign police checks varies. For more information about a specific standard, you should contact the authorities in a particular country, or their embassy.
The DBS does not offer a translation service, so either you (or the employee) should obtain a certified translation of the certificate of good conduct.
Checking an applicant’s right to work in the UK
The employer is responsible for ensuring employees have the right to work within the UK. The DBS does not check this.
The Centre for the Protection of National Infrastructure
The Centre for the Protection of National Infrastructure (CPNI) provides protective security advice. This is for companies and organisations that deliver the UK’s essential services.
More information about overseas criminal records checks can be found on the CPNI website.
An applicant can raise a dispute if they believe there’s been a mistake in either:
- the records provided, like wrong or irrelevant information on convictions
- personal information, like a name or employer’s details
An employer or licensing authority can also appeal a DBS check if they’ve spoken to the applicant first.
More information can be found on the DBS appeals and disputes page.
Duration of criminal record check validity
There is no official expiry date for a criminal record check issued by DBS.
Any information revealed on a DBS certificate will be accurate at the time the certificate was issued. You should check the ‘date of issue’ on a certificate to decide whether to request a newer one. In certain employment sectors, a new criminal record check may be required periodically.
You may also be required by law to carry out a fresh check of the DBS children’s and/or adults’ barring lists in accordance with sector-specific guidance.
You can keep a DBS certificate for no longer than 6 months, to allow for consideration and resolution of any disputes or complaints after a recruitment or suitability decision is made. If it is considered necessary to keep the certificate information for longer, you should consult the DBS.
Accepting a previously-issued DBS check
It’s the employers’ decision to decide whether to accept a previously-issued DBS check.
If the applicant hasn’t joined the Update Service, you should consider the following before making a decision:
- the applicant’s criminal record or other relevant information may have changed since its issue
- the level of that check may not be right for the position you’re recruiting for
- you’ll need to check that the original application position and workforce are correct for the role you’re recruiting for (any original certificate issued from June 2013 will show the workforce ‘child’ or ‘adult’, ‘child and adult’ or ‘other’)
- the police disclose information on an enhanced DBS certificate based on child or adult workforce, for which the criminal record check was originally applied for
- the police disclose information on an enhanced DBS certificate which was submitted for ‘other’ workforce, in relation to the position for which the criminal record check was originally applied for
- the information revealed was based on the identity of the applicant, which was validated by another Registered Body
- that the identity details on the certificate match those of the applicant
You can go to our guidance pages for information about eligibility for standard and enhanced checks.
Following the merger of the Criminal Records Bureau (CRB) and the Independent Safeguarding Authority to create the DBS, CRB-branded certificates should be treated the same as DBS-branded certificates.
Security features of a DBS certificate
It is essential that employers have processes in place that enable them to make safe recruitment decisions. As part of the decision-making process, employers must ensure they see an original DBS certificate. Copies or digital photographs are not acceptable and must be rejected.
A DBS certificate contains the DBS logo on the front face and contains a number of security features which can be used to verify whether it has been counterfeited or altered.
The areas to be aware of and examined are as follows:
- an original DBS certificate has printing on both sides; the paper size is 209mm width x 404mm length which is larger than A4
- the personal information print colour on the certificate is purple
- a ‘crown seal’ watermark repeated down the right-hand side of the certificate is visible both on the surface and when holding the certificate up to the light
- a background design with the word ‘Disclosure’ appears in a wave-like pattern across both sides of the document – on the front of the certificate this pattern is green and on the rear of the document this is purple
If you are unsure whether a DBS certificate is genuine, or you think that it may have been altered, you should contact the DBS immediately at FDIT@dbs.gov.uk.
DBS notifications sent to Registered Bodies via the e-bulk service for standard or enhanced checks, or to a Responsible Organisation via the basic web service, which reveal no information, may be transcribed in a letter format and will not be printed on DBS secure certificate paper. The electronic content can be included in a letter or document under the provision that the DBS logo must not be used. The DBS logo is a registered trademark in the United Kingdom, and the DBS does not allow or permit Registered Bodies or Responsible Organisations to use this logo.
Any letter should have a statement at the beginning that says, ‘This is not a certificate issued by the DBS’. Neither the document nor associated guidance on the back of the DBS certificate, should be reproduced in such a way that an individual or organisation could believe it to be a DBS certificate within the meaning of sections 113A, 113B, 114 and 116 of the Police Act 1997.
If you are presented with a clear certificate and after checking the Update Service it states “no further information on certificate,” please contact the DBS at FDIT@dbs.gov.uk, as the certificate may have been tampered with.
Withdrawing a DBS Application
An application for a DBS check can be withdrawn but the application fee is non-refundable. The DBS check can only be withdrawn before it reaches printing stage.
Any future need for a DBS check would have to be submitted as a new application, and a new fee payment would need to be made.
Registered Bodies should ask for a DBS application to be withdrawn when the applicant is no longer being considered for, or is no longer in the position. This is because you no longer have a right to see the outcome of the DBS checking process.
You can read about the roles that are most often submitted to DBS in our eligibility guidance.
The roles in the eligibility guide reflect how they are written in legislation, not how they are written in job descriptions in contracts. You will need to understand if the duties of the person named in the application, meet the legislative criteria for the level of check you have submitted.
Requesting a Withdrawal – Applicant or Registered Body
An applicant or the Registered Body (RB) can request a withdrawal by using one of the following methods:
- informing the relevant local police force (LPF)
- The LPF convey the information to the DBS informing us of the withdrawal request
- The withdrawals team then send a pro-forma letter to either the RB or the applicant (whichever is relevant) to confirm withdrawal in writing
- Once the reply has been received by the withdrawals team, the application is withdrawn, and a letter is sent to the applicant and/or the RB to confirm completion of withdrawal
- writing or faxing the withdrawal directly to the DBS withdrawals team:
2nd Floor West
PO Box 165
Fax: 0151 676 1925
- or emailing DBS Customer Services:
Registered Body Withdrawal Request – please provide the:
- applicant’s full name
- application reference number
- date the letter was sent
- countersignatory number
- matching countersignatory’s signature (an email does not require a signature)
It is also helpful if you provide the applicant’s address and date of birth.
Applicant Withdrawal Request – please provide:
- your full name
- your application reference number
- your full address
- the date the letter was sent
- your signature (an email does not require a signature)
If a withdrawal request is received with insufficient information, a pro-forma letter requesting more information will be sent to you from the Withdrawals department.
DBS contact information is available on the homepage.
Click here to read more.