This post by Tim Burchell at UK Private Investigators is part of our blog series, “The Recruitment Rule I’d Break”.
The recruitment rule I would break is simple: once someone has passed their DBS check, that box is ticked.
It is an understandable shortcut. Recruitment involves deadlines, compliance tasks and pressure to fill roles. But a completed check can become false reassurance when nobody can explain what it established, what it did not establish and why it remains appropriate for the work being done.
That is the test I would put at the beginning of every checking decision. Why was this check carried out? What did it establish? What could it not establish? How did the result affect the recruitment decision? If those questions cannot be answered, the organisation may have completed a process without reaching a defensible decision.
The updated DBS guidance makes one limitation particularly clear. A DBS Update Service status check reflects the information available at the moment the check is made. It can indicate that the certificate remains current or that new information means a new certificate should be requested. It is not continuous monitoring, and DBS does not automatically notify the recruiter or employer if the status changes later.
A clear status result therefore does not mean that nothing relevant can ever have happened since the original certificate was issued. It means DBS has not confirmed new information that would change the status of that certificate at the time of the check. That is useful evidence, but it is still evidence at a point in time.
There is another assumption I would challenge: that an Update Service certificate is automatically suitable for a different role. The service applies to eligible Standard and Enhanced certificates, not Basic checks. Before a status check is made, the individual’s consent is required. The recruiter or employer must also be legally entitled to request the same type and level of check for the role, covering the same workforce and relevant barred list where applicable. If the role changes, those conditions must be checked again.
Those are requirements and limitations set out in DBS guidance. My additional recommendation is that recruiters keep a short decision record showing the role, the check used, why it was appropriate, the consent obtained, the result and who reviewed it. That is not a substitute for the guidance. It is a practical way to show that the guidance was applied thoughtfully.
The DBS does not prescribe one universal rechecking timetable. It recommends that organisations choose a risk based schedule, considering the nature of the role, the potential risk, regulatory requirements and safeguarding policies. I agree with that approach, but I would not replace one box ticking rule with another by checking everyone at the same arbitrary interval.
The right question is what should trigger another check. A move into a materially different role may do so. So may a safeguarding concern, a change in responsibilities or information that calls the original evidence into question. For some roles, a scheduled status check may be appropriate. For others, the balance of risk and lawful entitlement will be different.
The Update Service should also sit within wider safer recruitment. Identity, employment history, qualifications and references may still matter, depending on the role. None should be collected simply because it is available. Each check should have a defined purpose and a lawful scope.
The DBS check is useful. The mistake is treating its completion as the end of judgement.
A better rule is this: every check should be explainable. Recruiters and employers should be able to say why it was carried out, what it established, what it did not establish and why the next check, if any, is proportionate to the role.
