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Catholic Safeguarding Advisory Service (CSAS)Procedures Manual

Policy on Secure Storage and Retention of DBS Related Documentation

Contents

  1. General Principles for CSAS as a Registered Body
  2. Storage and Access
  3. Handling
  4. Usage
  5. Retention
  6. Disposal
  7. Acting as an Umbrella Body
  8. Retention of DBS Application Related Documentation

1. General Principles for CSAS as a Registered Body

As an organisation using the Disclosure and Barring Service to help assess the suitability of applicants for relevant roles within the Church, CSAS fully complies with the DBS Code of Practice regarding the correct handling, use, storage, retention and disposal of Disclosures and Disclosure information. It also complies fully with its obligations under the Data Protection Act and other relevant legislation pertaining to the safe handling, use, storage, retention and disposal of Disclosure information and this written policy is available to those who wish to see it on request.

For these purposes, "CSAS" includes its agents within the Safeguarding structure of the Catholic Church of England & Wales who act as countersignatories in processing Disclosure applications and process and retain information locally.

2. Storage and Access

Disclosure information must not be kept on an applicant's personnel file and should always be kept separately and securely, in lockable, non-portable, storage containers with access strictly controlled and limited to those who are entitled to receive it in the course of their duties.

3. Handling

In accordance with Section 124 of the Police Act 1997, Disclosure information must only be revealed to those who are entitled to receive it in the course of their duties. The Registered Body and its agents maintain a record of all those to whom Disclosures or Disclosure information has been revealed and recognise that it is a criminal offence to reveal this information to anyone who is not entitled to receive it.

4. Usage

Disclosure information must only be used for the specific purpose for which it was requested and for which the applicant's full consent has been given. No copy or representation of the Disclosure contents will be made or kept.

5. Retention

Once an appointment (or other relevant) decision has been made, Disclosure application information (copies of the paper Disclosure application form where applicable and copies of the original ID that has been verified) are to be retained for six months to allow for the consideration and resolution of any disputes or complaints. If, in very exceptional circumstances, it is considered necessary to keep Disclosure application information for longer than six months, the Registered Body will consult the DBS about this and will give full consideration to the Data Protection and Human Rights of the person before doing so. Throughout this time the usual conditions regarding safe storage and strictly controlled access must be applied.

CSAS and its agents must not keep any photocopy or other image of the Disclosure or any copy or representation of the contents of a Disclosure. However notwithstanding the above, we will keep a record of the date of issue of a Disclosure, the name of the subject, the type of the Disclosure requested, the position for which the Disclosure was requested, the unique reference number of the Disclosure and the details of the recruitment decision taken.

6. Disposal

Once the six months (or other agreed) retention period has elapsed, Disclosure information must be destroyed by secure means, i.e. by shredding, pulping or burning. While awaiting destruction, Disclosure information must not be kept in any insecure receptacle (e.g. waste bin or confidential waste sack).

7. Acting as an Umbrella Body

Before acting as an Umbrella Body (one which countersigns applications and receives Disclosure information on behalf of other employers or recruiting organisations connected to the Catholic Community in England and Wales) the Registered Body will take all reasonable steps to satisfy itself that the organisation will handle, use, store, retain and dispose of Disclosure information in full compliance with the DBS Code and in full accordance with this policy.

The Registered Body will request a copy of the organisation’s policy on the handling, use, storage, retention and disposal of Disclosure information.

If necessary, the Registered Body will provide a model policy for the organisation to use or adapt for this purpose.

Application Form for post (where applicable)

The role application form (where relevant) is to be retained by the parish, religious congregation or recruiting organisation in accordance with usual local Church recruitment practices.

Safeguarding Self Declaration

The Safeguarding Self Declaration Form is to be retained in accordance with the record retention schedule, by the Diocesan Safeguarding Co-ordinator or by the relevant person within the Religious Congregation, regardless of the appointment decision.

The Declaration, signed by the applicant, on this form clearly indicates the length of time that the form will be retained.

ID Verification Form

The ID verification Form, which the applicant completes for the purposes of identity verification at interview stage and is presented at that time by the applicant along with original documentary evidence of identity, is to be retained by the appropriate countersignatory or office, in accordance with the record retention schedule.

The Declaration, signed by the applicant, on this form clearly indicates the length of time that the form will be retained.

In the event of the application being withdrawn before completion, then the ID verification form can be destroyed by secure means as outlined in section 6 above.

ID Evidence Photocopies

The photocopies of original identity documentary evidence (taken originally at interview or ID verification stage for new employees and volunteers) are passed to the Safeguarding Co-ordinator or countersignatory upon conditional offer of appointment.

The photocopies of identity documents are to be retained by the countersignatory pending confirmation that the DBS Disclosure does not contain information that will prevent appointment to the role.

Upon receipt of the Disclosure Certificate outcome, assuming that there are no disputes raised about the accuracy of the Disclosure content, the photocopied identity documents are to be destroyed by secure means as outlined in section 6 above.

Registered Body handling of the Disclosure Certificate

Where the Registered Body or its agents need to see the original copy of the DBS Disclosure Certificate (e.g. to risk assess disclosure information), the original Disclosure Certificate must be returned to the applicant once the risk assessment process has concluded.