Safer Recruitment and the SCR

What is Safer Recruitment?

Safer recruitment is the set of practices that organisations such as schools follow to ensure that the staff they hire are suitable to work with children and young people. This is a fundamental aspect of a school’s statutory obligation to keep their students safe from harm. You can read more about this on the NSPCC website.

Safer Recruitment is one of the few things not included in the long list of responsibilities assigned to a Safeguarding Lead in Keeping Children Safe in Education (KCSIE). However, it is important that the Safeguarding Lead, and indeed all staff involved in recruitment, understand the safeguarding requirements when appointing new employees. KCSIE explains the importance of a culture of safe recruitment to ‘help deter, reject or identify people who might abuse children.’

The Single Central Record

The maintenance of a Single Central Record (SCR) is a statutory requirement for all schools and colleges in both England and Wales. There are very strict guidelines in place in terms of the information that needs to be recorded and retained in the SCR. Essentially, the SCR is a register that records all of the essential recruitment checks that are undertaken prior to a person being appointed.

These would include checks on the following:

• The applicant’s identity
• Checks with the Disclosure and Barring Service (DBS)
• Prohibition from teaching and other sanctions that may have been imposed
• Right to work in the UK and living or working overseas
• Professional qualifications

The SCR checks are a critical part of the recruitment process and apply to all persons appointed by the school including teaching staff, support staff, supply staff, contractors, volunteers and school governors/trustees. The checks themselves will vary dependent on the role the person is carrying out at the school but for every individual, a separate entry is made on the SCR which maintains a complete record of the checking process.

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Safer Recruitment Process: Application Forms and References

The first experience you will have of a candidate will be their application form. Unless they are specifically applying for a pastoral/safeguarding role it is unlikely that safeguarding will feature on their application statement. However, there are some things essential to check if a candidate is called for interview. For instance, if a candidate has moved quickly from previous jobs or if they have had several different roles in a short space of time, there might be a perfectly good explanation but it is certainly something that you should question during an interview. Similarly, if there are any unexplained gaps in employment this should also be explored at the interview and further information obtained

Even more importantly when requesting references for a candidate, it is vital that these are checked thoroughly. Of course, you would hope that a former employer would be very clear if there have been any issues have arisen with regards to safeguarding, but sometimes referees can be ambiguous with their wording, particularly if there was a concern but nothing conclusive emerged. If it is at all unclear then ensure you contact the referee directly. There is very clear wording in KCSIE regarding the definitions that should be used when determining the outcome of allegation investigations:

• Substantiated: there is sufficient evidence to prove the allegation
• Malicious: there is sufficient evidence to disprove the allegation and there has been a deliberate act to deceive
• False: there is sufficient evidence to disprove the allegation
• Unsubstantiated: there is insufficient evidence to either prove or disprove the allegation - The term, therefore, does not imply guilt or innocence
• Unfounded: to reflect cases where there is no evidence or proper basis which supports the allegation being made

Remember that referees are the people that the candidate are most confident will be positive about them. If you remain concerned about, for instance, a very short appointment in one particular role, you may want to call them yourself and ask for their opinion on the candidate in addition to asking the candidate about their time in that role.

Safer Recruitment During the Interview Stage

It is vital that anyone working at your school has the right checks and documents completed before being appointed. In some cases, the interview process will form part of this check, if you need to ask about any concerns that arise from a candidate’s application form. Going further than this, the interview is the ideal opportunity to ensure that a candidate is someone who fully understands the importance of safeguarding, and will be a positive and engaged part of whole-school safeguarding. There should always be part of the interview which questions the candidate’s understanding of safeguarding in schools.

Whatever their role, anyone looking to work in a school should understand the importance of that frequently repeated phrase that ‘safeguarding is everyone’s responsibility’. This is not to say that every successful candidate for a job should have an encyclopaedic knowledge of safeguarding policy. They should certainly appreciate its importance and show that they will be positive about developing their understanding of safeguarding where necessary. You can gauge a candidate’s experience from their application form and also ask them open questions such as:

• ‘What experience do you have of dealing with safeguarding issues with children?’
• ‘When did you last have safeguarding training?’

From this you can judge what level of safeguarding knowledge you can expect from the candidate. For instance, when interviewing a candidate who has recently finished their teacher training, ask them what they would do if a student came to them with a safeguarding concern. I would expect them to be able to go through all of the key points such as not promising confidentiality, explicitly. If unable, you might question how seriously they take their safeguarding role. Similarly, you would expect anyone applying for a safeguarding/pastoral role in the school to know the school’s policy in detail.

In contrast, if there is a candidate looking to work in the catering department coming from a non-school position, they might be unaware of the process for dealing with a disclosure. However, you would expect them in an interview to understand why safeguarding is important and that they have a part to play in that along with every member of the department.

Essentially you are looking for a positive mindset towards safeguarding and a confidence that if there are gaps in knowledge the candidate will be proactive about participating in safeguarding training appropriate to their role.

Safer Recruitment during Covid: DBS and Right to Work Checks

As with many sectors, education recruitment has been hit by the impact of Coronavirus. The key message for all schools is that the usual safeguarding processes must be followed, even if some elements need to be done remotely. In particular, the Single Central Record must continue to be kept up to date and schools must continue to refer safeguarding issues to the DBS and the Teaching Regulation Agency, regardless of if hearings are suspended.

In order to help with this, the Disclosure and Barring Service has changed its guidance on standard and enhanced DBS ID checking so that ID documents can be viewed via video link and scanned images can be used submitting a DBS check. It is very important to note that the applicant must present the original versions of these documents when they first report to work in person.

Similarly, Immigration Enforcement has also made temporary changes to the right to work checks. Checks can now be made during video calls, scanned documents can be used to make a check and employers should use the Employer Checking Service if an applicant cannot provide any acceptable documents. While it is illegal to knowingly employ someone without the right to work in the UK, schools are warned that no one should be discriminated against if they are unable to show you their documents. As noted in the code of practice for employers: avoiding unlawful discrimination while preventing illegal working.

The government will publish information when these measures end, so schools should look out for this and carry out retrospective checks within 8 weeks on existing employees who begin employment during these measures.

KCSIE 2021 Guidance: Updates to safer Recruitment 

On September 1st 2021 Keeping Children Safe in Education released a new version of the statutory guidance.  The guidance sets out the legal duties an establishment must follow to safeguard and promote the welfare of children and young people under the age of 18 in schools and colleges. It includes a part on Safer Recruitment.

The changes include:

Post 16 Education

Safeguarding provisions extended to providers of post-16 education.

The Education and Training (Welfare of Children) Act 2021 extended safeguarding provisions to providers of post 16 Education; 16-19 Academies, Special Post-16 institutions and Independent Training Providers. Some safer recruitment regulations do not apply to these providers and as such, some of the “musts” for colleges do not apply to them.

These checks are an essential part of safeguarding, carried out to help employers check the suitability of candidates. Therefore, the providers set out above should carry out these pre-appointment checks.

Pre-appointment checks

Verify a candidate’s identity, it is important to be sure that the person is who they claim to be, this includes being aware of the potential for individuals changing their name.

Best practice is checking the name on their birth certificate, where this is available.

Barred List Checks

Barred lists need to be checked (and also only used) when:

• you have an Early Careers Teacher and you are waiting for their DBS with the inclusion of an enhanced certificate with barred list information
• or when a person has worked in a school but has not been at that school for more than 3 months

Section 128 Directions

Added information on when a section 128 direction will be disclosed when an enhanced DBS check with children’s barred list information is requested, provided that ‘child workforce independent schools’ is specified on the application form as the position applied for. Where a person is not eligible for a children’s barred list check but will be working in a management position in an independent school, a section 128 check should be carried out using the TRA’s Employer Access service.

You can read the rest of the KCSIE 2021 update HERE

Robust Recording Systems are at the Heart of Safer Recruitment

It will be critically important for you to record accurate information about the recruitment checks that you have undertaken as part of the process and for you to be able to retrieve that information easily when you need to.

It is important to remember that the data that you are recording is kept secure and is only made available to persons who have the authority to access it. The type of information being recorded about applicants would at the very least be defined as ‘personal information’ and in some cases, it could be considered as ‘sensitive’ so having robust systems in place that are able to manage that requirement will be essential.

It’s also worth bearing in mind that the process for recruitment checking can be quite complex, depending on the type of role being applied for so having an effective system in place that can guide users through that process would also be an important benefit for schools.

We also know that the accuracy and effectiveness of a school’s SCR is a high priority for both Ofsted and Estyn and is normally inspected on the very first morning of a school inspection. It is therefore essential that the data they are inspecting is easy to access and interpret and presents the information in a logical format, rather than relying on paper records and/or spreadsheets.

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The Benefits of a Digital Safer Recruitment System

As the safer recruitment process becomes more robust, the dangers increase and individual country’s legislation develops, more and more schools are realising that paper records or Excel spreadsheets just are not good enough. Purpose-built digital systems provide peace of mind, help to reduce admin time with streamlined processes and provide a secure central vault where all elements of the safer recruitment checks can be stored.

A digital system, such as Sentry for Safer Recruitment, enables those responsible for recruitment to easily record all safer recruitment checks and to closely track every step of that process. The system has been designed to guide you through the recruitment process, to monitor the progress of outstanding checks and to ensure compliance with the relevant legislation.

Sentry ensures that your recruitment processes are robust and acts as a critical first line of defence against those individuals who may present significant risks to children and young people.