The recent announcement to increase DBS fees from £38 to £49.50, effective from December 2nd, 2024, has raised concerns for organisations across the UK.
It is crucial for organisations to plan ahead and consider the implications of the increased DBS fees. If you have staff members whose DBS checks are due for renewal in the next six months, it may be beneficial to process them before the price hike takes effect.
While the need for robust background checks to safeguard vulnerable individuals is undeniable, the rising cost presents a significant challenge, particularly for charities and smaller organisations.
They often rely on volunteers where a DBS check is free but full and part-time staff, however, will see a direct impact due to the increase. There are still administrative costs associated with volunteer applications and these could also now increase. Increased fees further strain the resources of these organisations, potentially impacting their ability to deliver vital services.
To review the necessity of the increased fees, we need to understand the core services DBS provide to analyse how the increased revenue could (should) be utilised. There are different levels of DBS, which is to ensure that information about an individual is only accessible when necessary and proportionate:
Why the apparent complexity?
We regularly ask the question, why is safeguarding often so overly complex. To that point, picking on the element above of 'minimal contact', if it is truly safety first then isn't the amount of time spent with vulnerable groups is irrelevant and should everyone who works with these groups therefore automatically require an enhanced DBS? Those hiring staff or taking on volunteers need to perform a rigorous risk assessment and to do that thoroughly all information needs to be disclosed. That enables them to properly assess the risk and make a decision. Gambling companies don’t take risks without all the available data they can use so why should we with people’s lives?
There is a great life lesson here of “think before you speak but read before you think” because there is actually a very good, valid reason for this system. The Rehabilitation of Offenders Act acknowledges that people with previous convictions should not be discriminated against when applying for jobs. The different levels of DBS checks are designed to help ensure that this is the case.
There’s plenty of evidence to support rehabilitation and past offenders becoming not just part of society but using their experience to become practitioners for the positive. For some roles, this valuable life experience helps the next generation learn and not follow the same path. This protection enables them to take the next step and not be discriminated against, which is vitally important.
The polarising view is that some individuals are likely to reoffend so granting them opportunity creates a significant risk. There’s a philosophical question that we’re not commenting on today of 'who has the greater right to protection, the individual at risk or the individual working with them?' However, what we are touching upon is:
Do different grades of DBS solve this problem effectively?
If not, how could the increased revenue be used to improve the DBS system?
Mandatory categories of disclosure: Certain information could always be on a DBS irrelevant of tier or role. For example, sex related offences could always be disclosed as that could be of interest to anyone, not just vulnerable groups they present the more obvious greatest risk to. The issue with that is these offences, whilst potentially worrying, are not directly relevant to working in finance, for example.
Mandatory disclosures based on role: Taking the above further, could DBSs be categorised based on roles. For example, all finance, law and security always disclose information that has an obvious and direct risk to the role such as fraud. Mandatory minimums can be created for each role and then a full disclosure exists to upgrade to if they so wish. With some roles already legally requiring an enhanced DBS this could create more risk with some information no longer being disclosed. Arguable, this also could also add more complexity as clear definitions of roles are required, which is almost impossible to suit all.
No quibbles disclosures: Where ambiguity creeps in is even though some roles legally require a DBS, they transcend all tiers of DBS depending upon the risk exposure. Therefore, should we remove these limitations, such as only a basic check when there is ‘minimal’ contact with vulnerable people or the type of setting. This is too complex for most organisations so enforcing and enhanced DBS in all instances of access to children, for example, is not only straight forward but also more robust. These are the most vulnerable group and deserve the most protection. The extra revenue could be used to support an education programme on risk assessment vs anti-discrimination behaviour.
Unified DBS Portal: Another area we commonly come across is the limitations on who can apply for a DBS and who you can apply for. Standard and Enhanced must be requested via a recognised organisation, which can create challenges. Equally organisations should be able to request a DBS for anyone they wish to, subject to the individuals approval. A recent example we came across was a water activity charity was not allowed to get a DBS for a professional photographer (despite permission) who was working directly with the children and the obvious risk.
Porting DBSs: When joining a new organisation governing bodies or local authorities don’t have to accept old certificates. They can, and in most cases it's policy, request a new one, remarkably, even if the individual already has a recent one. This is particularly a challenge for charities even when they’ve a new volunteer as they’re still required to pay the admin fee to the council or governing body. When it's a volunteer you also don’t get to see the details of the DBS and are only informed if there is a disclosure. The volunteer then chooses to disclose what it is (or not), which can hamper their ability to rigorously do their risk assessment.
The priority (and policy) should be based on the date of issue. If it was recent enough, there's visibility of who checked it or the new organisation can see any disclosures, that information should be portable and can be used by the charity or new organisation.
If the requestee for porting the DBS can also tag on a request for a reference about the individual this brings a now dimension. Greater human intervention and ability to spot patterns of behaviour adds another level of safety. Thus, eliminating the need to obtain a new DBS for each new organisation, reducing administrative burden, costs and increasing safety.
There is no single answer, so taking the best of the above:
These measures are just some examples that could reduce complexity, cost and improve safety, whilst not discriminating individuals.
The Cost of Safety
It's important to remember that the cost of a DBS check is a small price to pay for ensuring the safety of children and vulnerable adults. However, the increase in fees highlights the importance to advocate for a more streamlined and ‘value for money’ DBS system.
Maybe the extra revenue they're generating should be spent on a review of the DBS system?
Feel like you know your stuff when it comes to DBS checks? Try our quiz
It is crucial for organisations to plan ahead and consider the implications of the increased DBS fees. If you have staff members whose DBS checks are due for renewal in the next six months, it may be beneficial to process them before the price hike takes effect.
While the need for robust background checks to safeguard vulnerable individuals is undeniable, the rising cost presents a significant challenge, particularly for charities and smaller organisations.
They often rely on volunteers where a DBS check is free but full and part-time staff, however, will see a direct impact due to the increase. There are still administrative costs associated with volunteer applications and these could also now increase. Increased fees further strain the resources of these organisations, potentially impacting their ability to deliver vital services.
To review the necessity of the increased fees, we need to understand the core services DBS provide to analyse how the increased revenue could (should) be utilised. There are different levels of DBS, which is to ensure that information about an individual is only accessible when necessary and proportionate:
- Basic DBS check (was £18, post Dec 2nd £21.50)
- Standard DBS check (was £18, post Dec 2nd £21.50)
- Enhanced DBS check (was £38, post Dec 2nd £49.50)
- Enhanced DBS check with Barred Lists (was £38, post Dec 2nd £49.50)
Why the apparent complexity?
We regularly ask the question, why is safeguarding often so overly complex. To that point, picking on the element above of 'minimal contact', if it is truly safety first then isn't the amount of time spent with vulnerable groups is irrelevant and should everyone who works with these groups therefore automatically require an enhanced DBS? Those hiring staff or taking on volunteers need to perform a rigorous risk assessment and to do that thoroughly all information needs to be disclosed. That enables them to properly assess the risk and make a decision. Gambling companies don’t take risks without all the available data they can use so why should we with people’s lives?
There is a great life lesson here of “think before you speak but read before you think” because there is actually a very good, valid reason for this system. The Rehabilitation of Offenders Act acknowledges that people with previous convictions should not be discriminated against when applying for jobs. The different levels of DBS checks are designed to help ensure that this is the case.
There’s plenty of evidence to support rehabilitation and past offenders becoming not just part of society but using their experience to become practitioners for the positive. For some roles, this valuable life experience helps the next generation learn and not follow the same path. This protection enables them to take the next step and not be discriminated against, which is vitally important.
The polarising view is that some individuals are likely to reoffend so granting them opportunity creates a significant risk. There’s a philosophical question that we’re not commenting on today of 'who has the greater right to protection, the individual at risk or the individual working with them?' However, what we are touching upon is:
Do different grades of DBS solve this problem effectively?
If not, how could the increased revenue be used to improve the DBS system?
Mandatory categories of disclosure: Certain information could always be on a DBS irrelevant of tier or role. For example, sex related offences could always be disclosed as that could be of interest to anyone, not just vulnerable groups they present the more obvious greatest risk to. The issue with that is these offences, whilst potentially worrying, are not directly relevant to working in finance, for example.
Mandatory disclosures based on role: Taking the above further, could DBSs be categorised based on roles. For example, all finance, law and security always disclose information that has an obvious and direct risk to the role such as fraud. Mandatory minimums can be created for each role and then a full disclosure exists to upgrade to if they so wish. With some roles already legally requiring an enhanced DBS this could create more risk with some information no longer being disclosed. Arguable, this also could also add more complexity as clear definitions of roles are required, which is almost impossible to suit all.
No quibbles disclosures: Where ambiguity creeps in is even though some roles legally require a DBS, they transcend all tiers of DBS depending upon the risk exposure. Therefore, should we remove these limitations, such as only a basic check when there is ‘minimal’ contact with vulnerable people or the type of setting. This is too complex for most organisations so enforcing and enhanced DBS in all instances of access to children, for example, is not only straight forward but also more robust. These are the most vulnerable group and deserve the most protection. The extra revenue could be used to support an education programme on risk assessment vs anti-discrimination behaviour.
Unified DBS Portal: Another area we commonly come across is the limitations on who can apply for a DBS and who you can apply for. Standard and Enhanced must be requested via a recognised organisation, which can create challenges. Equally organisations should be able to request a DBS for anyone they wish to, subject to the individuals approval. A recent example we came across was a water activity charity was not allowed to get a DBS for a professional photographer (despite permission) who was working directly with the children and the obvious risk.
Porting DBSs: When joining a new organisation governing bodies or local authorities don’t have to accept old certificates. They can, and in most cases it's policy, request a new one, remarkably, even if the individual already has a recent one. This is particularly a challenge for charities even when they’ve a new volunteer as they’re still required to pay the admin fee to the council or governing body. When it's a volunteer you also don’t get to see the details of the DBS and are only informed if there is a disclosure. The volunteer then chooses to disclose what it is (or not), which can hamper their ability to rigorously do their risk assessment.
The priority (and policy) should be based on the date of issue. If it was recent enough, there's visibility of who checked it or the new organisation can see any disclosures, that information should be portable and can be used by the charity or new organisation.
If the requestee for porting the DBS can also tag on a request for a reference about the individual this brings a now dimension. Greater human intervention and ability to spot patterns of behaviour adds another level of safety. Thus, eliminating the need to obtain a new DBS for each new organisation, reducing administrative burden, costs and increasing safety.
There is no single answer, so taking the best of the above:
- Remove the need for multiple DBS checks based on organisation and base it on the most recent one with a UK wide policy defining what is recent.
- Allow porting of DBS checks with mandatory reference accompaniment.
- Reduce ambiguity but basing checks on simpler, binary rulesets such as ‘is there contact with children – Yes/No. Not time
- Remove limitations on who can request a DBS (assuming associated permissions) and the role they can request it for.
- Embark on training to demystify conscious and unconscious bias and discrimination.
These measures are just some examples that could reduce complexity, cost and improve safety, whilst not discriminating individuals.
The Cost of Safety
It's important to remember that the cost of a DBS check is a small price to pay for ensuring the safety of children and vulnerable adults. However, the increase in fees highlights the importance to advocate for a more streamlined and ‘value for money’ DBS system.
Maybe the extra revenue they're generating should be spent on a review of the DBS system?
Feel like you know your stuff when it comes to DBS checks? Try our quiz