Cottesmore School


Safer Recruitment Pending DBS Check Policy & RA

Safer Recruitment Pending DBS Check Policy & RA


  • What if the Disclosure Check is Not Available Before the Start Date?
  • What is Appropriate Supervision?
  • Risk Assessment: Supervision Pending Disclosure
  • Pending DBS Check Risk Assessment

What if the Disclosure Check is Not Available Before the Start Date?

New starters undertaking “regulated” activity must not commence employment in that role until all of the statutory pre-employment checks (see 4 below) have been carried out, including the DBS Enhanced Disclosure check.

In the unlikely event that it has not been possible to obtain a satisfactory Disclosure before the individual is scheduled to commence employment and Cottesmore believes that it is necessary for the individual to start work, the Head has discretion to allow an individual to begin work pending receipt. However, the Head can only allow the employee to commence work in the event that the individual is appropriately supervised AND that all the other statutory pre-employment checks have been completed.

What is Appropriate Supervision?

Appropriate supervision for individuals who start work prior to the result of a DBS Disclosure being known should reflect what is known about the person concerned, their experience, the nature of their duties and the level of responsibility they will carry. The level of supervision required will probably be high (a constant chaperoning situation).

Risk Assessment: Supervision Pending Disclosure

In these circumstances, the Head and Bursar are required to complete the form Risk Assessment: Supervision Pending Disclosure (see section 6 below) and submit it via the Bursary which will, in turn, forward it to the Headmaster. Only the Head or the Proprietor (if the Head is away from School) may authorise that the individual can commence employment having had regard to the information supplied on the Risk Assessment form below.

Pending DBS Check Risk Assessment

This form can be used to assist in assessing and recording the risks of allowing someone to start work or volunteering before a DBS (Disclosure and Barring Service) check is received or where a DBS certificate shows relevant convictions or other relevant information. The risk assessment must be undertaken in accordance with the Policy on Employment of Ex-Offenders and Disclosure and Barring Service checks.

The completion of this risk assessment form is the joint responsibility of the Bursar and Head. It must be authorised by the Head before the person can start or continue working with children or their records.  This completed risk assessment form must be placed on the individual’s personnel file and made available to HR, Audit, Safeguarding and Ofsted inspections.

In very exceptional circumstances staff (but not volunteers) who work with children or their records may work without a clear DBS certificate if they are closely supervised, having been through the appropriate checks including the Barred List check (within sight and sound of someone with a clear DBS check). However, this will normally only be permissible when not to allow them to work would disrupt the care of children. People may only work in these circumstances when all of the following applies:

  • The appointment is necessary to allow the service provision to continue.
  • In the case of children, the person has an enhanced DBS certificate issued within the last year by another body and the person provides the original enhanced DBS certificate to the appointing manager as evidence.
  • All other Safer Recruitment checks are in place.
  • An enhanced DBS check has been applied for.
  • The person has no unsupervised contact with children.
  • They have no access to records.
  • This risk assessment and risk management plan has been completed and signed off by the relevant Deputy Director/Head Teacher.

Due to the high risks involved appointees to work in one to one situations or similar environments must not start work until the fresh DBS certificate has been seen or the DBS management site says in the employees section: “None Recorded”.

Please note that candidates may be able to carry out induction, training and supervised tasks whilst waiting for the DBS certificate to be returned.




Information required.


Has the THE COTTESMORE SCHOOL SAFER RECRUITMENT QUICK REFERENCE TICK LISTbeen completed, including all of the following?

Application Form - check gaps, discrepancies or anomalies





Appropriate and satisfactory references


Give details where you have obtained clarification or missing information on the applicant or verification of the referees position in the organisation.


Qualifications – Have you checked and verified that the candidates qualifications fulfil the requirements in the selection criteria?


Confirm that you have actively asked the person if they have any convictions, cautions, reprimands, warnings, bind-overs, pending prosecutions or disqualifications.


Have you seen and verified asylum and immigration checks?



Barred List check must be carried out before they start work.



Criminal Records Bureau Disclosure Checks


Does the candidate already hold a DBS certificate?

If not, please go to Q6.




Who was the DBS certificate obtained by?


3.Was the DBS certificate issued within the last 12 months?


4.Is the DBS certificate “Enhanced level”?


5a. The DBS certificate  must indicate “None Recorded” against the ISA Children’s Barred list information.





6. Has the candidate completed a new DBS certificate Application form?

Confirm date that the application form has been forwarded to the DBS or Recruitment team in the Shared Service Centre for processing. Failure to provide a date may mean delays in the person commencing work.






Date completed DBS application returned to Atlantic Data:     

7.     Has the candidate been a resident outside of the United Kingdom?

If yes, is the candidate able to produce the Police Check or DBS equivalent from other countries lived in?

If no, is a Police Check or DBS equivalent from that country being sought?














(Please delete as appropriate)



Did the applicant declare the matters on the DBS Application form and Cottesmore Application form?

Yes / No

If ‘No’ state reason


Does the individual agree that the information detailed on the DBS Certificate is correct?

Yes/ No

If ‘No’ what do they think is incorrect and why?


Can safeguards be implemented to reduce/remove any risk e.g. no unsupervised contact?

Yes / No

If ‘Yes’ specify what



What supervision is available and how readily?

Give details




Any further information

Is there any other information relevant to this Risk Assessment regarding the candidate, the work itself or the location/environment where the activities will take place?     



Risk Assessment completed by:

Signed                                                        Date:     

Print Name     


Risk Assessment Authorised by: 

Signed (Head)                                              Date     

Print Name (Head)     


If authorised by the Head, please retain this locally in a locked secure cabinet.  


Reviewed by TFR, September 2019
To be reviewed, September 2020