Door staff should have to go through an enhanced check with barred list check, more of a check (and costing more) than the standard DBS check they have to go through via the SIA. That was among the recommendations of an official review of the ‘disclosure and barring regime’ for the Home Office.
As a standard DBS check costs £18 and an enhanced check £38, it would appear likely that the SIA application fee will have to rise £20. The SIA on April 6 reduced it from £190 to a historic low of £184 thanks to ‘various efficiency and cost savings’ by the SIA and record highs of badged people, mainly with a door badge.
The SIA put it to the review that the extra checking might affect the labour market (that some would be ‘deterred by any additional cost’ from applying), and the extra checking could mean delays in badging. Mr Bailey however concluded that ‘the potential risk to both adults and children posed by encounters with door supervisors justifies, indeed requires, the extra level of safeguarding’, and likewise for close protection operatives.
To apply for an SIA licence you must consent to the DBS providing the certificate directly to the SIA. You the applicant receive a paper copy; the SIA pays for the check, and charges you (as part of the £184 cost of applying). Mr Bailey wrote of unnamed ‘notorious cases of serving police officers, persons in a position of authority to whom members of the public would turn for help and protection, who abused their position and committed offences of the gravest kind’. Door staff may similarly have ‘opportunity for abusive conduct’ with children, or drunk or otherwise vulnerable people.
The Security Industry Authority (SIA) told the review that the SIA carries out standard DBS checks on all applicants for a licence, front-line and non-front-line. Having a criminal record, even for sex offences, does not necessarily mean that a licence application, or renewal, will be refused. The regulator’s Licensing and Standards arm has a Sexual Offences Group Review Team which meets weekly to assess sexual offences and offences against children cases, ‘to ensure that the SIA systematic, consistent and robust approach’.
As of 1 August 2022, the total number of active SIA-licence holders across the sector was about 400,000: door supervision made up 300,000 and close protection 15,000. The SIA told the review that a door supervision licence is ‘a popular choice for applicants’ because it also allows the holder to work as a security guard (whereas a contract guarding badge doesn’t allow you to work a door). Most door badge holders don’t intend to work as door supervisors at licensed premises.
As the review points out, anyone can obtain a ‘basic DBS check’, which discloses all unspent convictions and cautions, for any purpose, such as to satisfy an employer such as a school.
The review also included councillors in local government, as they may take decisions about the care of children and vulnerable adults. Councillors are eligible for enhanced DBS checks, which disclose spent and unspent convictions and cautions, and may disclose police intelligence; the review recommended that such an enhanced criminal record check should be made mandatory. The review found ‘no uniformity of practice among councils in relation to obtaining criminal record checks for safeguarding purposes’.
Mr Bailey described the fact that a check ‘can only show the position as at the date the certificate is issued’ as a vulnerability. In 2013, the DBS introduced an ‘Update Service’ for standard and enhanced certificates: “The principal purpose of the service was to enable a certificate holder to take their certificate from job to job within the same workforce unless an employer asked for a new certificate, or they needed a certificate for a different type of workforce.” The holder of a certificate can subscribe to this service costing £13 a year.
The Update service carries out a weekly check of the subscriber’s record of convictions held on the Police National Computer (PNC) and a check of information held by local police forces every nine months; and an employer can (if given permission by the holder) view online. An employer, however, is not automatically informed of a change occurring in someone’s status; although employers have told the DBS that they would like it to provide ‘push’ notifications. MR Bailey recommended ‘that the DBS carries out the work necessary to establish the feasibility and cost of redesigning the Update service’ to enable such notifications.
Mr Bailey, a former Norfolk Chief Constable, is the National Police Chiefs’ Council (NPCC) lead for child protection and abuse investigation. He concluded that ‘the disclosure and barring regime, operated by the DBS [Disclosure and Barring Service], is routinely helping employers and organisations that use volunteers to make safer employment decisions. It is therefore delivering its mission. However, there are areas where the regime can be improved by addressing gaps and weaknesses in the existing arrangements and by clarifying an important element of the regime, namely the definition of regulated activity’.
Visit https://www.gov.uk/government/publications/independent-review-of-the-disclosure-and-barring-regime.
