Regulatory Updates: Changes to Withdrawal Process and Email Address Guidance

The Disclosure and Barring Service (DBS) process millions of criminal record checks each year. This means they process vast amounts of people’s personal information and makes them one of the largest data controllers in the UK. Being in this position means that they are constantly required to assess and refine their processes to ensure that they are doing all they can to protect the data of the UK public. One of the best ways to ensure this is by having a streamlined and manageable process.  

Over the past few years, the DBS’s have been consulting with Registered Bodies like Personnel Checks to identify problems in the current process and things that can be done to improve it. Part of this research has involved looking at how errors within an applicant's submitted information can be dealt with.   

As a result of this, August 2019 saw the introduction of a withdrawals policy. This policy maintains that certain mistakes on a DBS application form could result in its withdrawal from the process. The DBS is now expanding this policy to become more comprehensive.  

Expanding the Withdrawals Policy  

The current withdrawals policy states that errors in two specific fields will cause an application to be withdrawn, the ‘Position Applied For (Workforce Only)’ and ‘Working At Home Address ‘field. However, the DBS Code of Practice stresses the importance of accurate information being entered into the form. Inaccuracies cause delays and, in some instances, can cause a DBS Check to be withdrawn from the process, even if they don’t meet the criteria of the current policy.  

The new withdrawals policy has been developed to ensure that the DBS remain GDPR compliant and are only processing correctly validated information. This means that if any information is entered onto an application form inaccurately and this is identified by the DBS then said application will be withdrawn. When this happens, the DBS will write to us to inform us of the withdrawal. It is then our responsibility to contact the relevant person(s). This policy will come into effect from May 31st, 2021.   

There are three distinct points in place to try and mitigate the chance of errors being made. Applicants are given a chance to review all the information that they have entered, before submitting their application form. After this, applicants are then asked to declare that they have provided “complete and true information in support of this application” at the point of submission. The responsible ID Verifier then must cross-reference the applicant's ID documents against the information provided on the application form.  

We always recommend spending as much time as needed to ensure that a DBS application is completed correctly. Even if you’re in a rush to get a result, it is much quicker to check thoroughly than having to submit a completely new DBS Check due to a simple error.  

Clarification of Email Address Guidance for Basic DBS Checks  

The DBS has also issued a reminder regarding how email addresses should be entered on Basic DBS Application forms. They have clarified that the email address MUST be the applicants own email address. This means that you cannot use a friend, colleague or family member’s email address on applications for Basic DBS Checks. To be clear, this only affects Basic DBS applications. For Standard and Enhanced DBS applications, there are no specific criteria regarding e-mail addresses. This is because the systems used to process Basic DBS checks is different from the other two levels of check.   

We would always recommend using an individual's personal email for any kind of background check due to the nature of the information involved. In situations where an applicant may not have an email address, we strongly advise creating an email account before starting an application. However, an alternative email address can still be used for Standard and Enhanced DBS Checks if the circumstances leave no other choice. It will not affect the application.   

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For more information about how Personnel Checks background screening solutions can aid your organisation, get in touch! You can give us a call on 01254 355688 or drop us an email at letstalk@personnelchecks.co.uk