Portability of CRB Checks- Latest Update- CRSC

The Government has been looking to address the issue of multiple CRB checks required by individuals who currently work with a number of different organisations.

Registered and Umbrella Body organisations have called for a solution which will allow the CRB Check to become a portable document, removing an element of the bureaucracy involved, whilst still maintaining a robust vetting service which creates the right balance of protection and privacy.

In February 2011, the Government’s remodelling review of the Criminal Records Regime (CRR) and the Vetting and Barring Scheme (VBS) review delivered a series of recommendations aimed at improving arrangements for the disclosure of criminal records.

Recommendations 2 and 3 of the review stated that there should be an online update service. The new service will allow the organisation, with the individual’s consent, to carry out an online status check to establish if further relevant criminal information has been identified since a CRB check was last carried out.

You may have heard this referred to as the ‘Criminal Record Status Check’ (CRSC); the final title will be subject to change before the service is launched.

The principle of the update service is to provide a proportionate and fair system that provides information where appropriate, and balances the need to protect and respect individuals’ privacy.

The opportunity to opt into the new online update service is voluntary and whilst there will be a charge for registering with the scheme, the decision on whether volunteers will have to pay for the new service is still under consideration.

The CRB is now working with the Home Office; the Independent Safeguarding Authority and other government departments to develop and deliver this new service with a proposed implementation date of early 2013.

BENEFITS OF THE SERVICE

• For Employees/Individuals– it will allow them to reuse their CRB check, taking it from employer to employer; in the vast majority of cases they will avoid the need to apply repeatedly for new CRB checks, meaning they don’t now need to keep filling out the application form and then waiting for their new certificate to arrive.
• For Employers and those responsible for taking on volunteers – they will be able to carry out an instant check of an existing disclosure certificate, which will confirm if the check in front of them is up to date. If it is – no need to apply for a new CRB check. They can proceed with all the other pre-employment checks they carry out. And this will work equally as well with existing employees – no need to request new CRB checks periodically – they can simply check the existing certificate.

HOW THE PROCESS WILL WORK – EMPLOYEES/APPLICANTS

• An applicant will apply for a Standard or Enhanced CRB check as normal. They should keep a record of the form reference number given on application.
• The individual can join the online update service before the application form has been received by the CRB. This must be done within 28 days.
• The Employee/Applicant will be charged for subscribing to the online service- FEE YET TO BE CONFIRMED.
• The applicant will be able to enter the form reference number, together with some other personal details, to apply to join.
• Payment will be required at this point and they will be given the opportunity to opt for auto annual renewal.
• The applicant will receive a unique ID number, which should be retained at this point as they will not receive any further communication from the CRB detailing this number. This number will be used by the individual to access their online account.
• The applicant will receive an email confirming their subscription when the certificate has been dispatched by the CRB.
• Once the individual receives their certificate they will be able to present this to their prospective employer.
• The applicant will be notified by email that their annual subscription to the service is up for renewal 30 days prior to expiry.
• If the applicant opted for auto renewals, they will be informed of when the payment will be taken automatically from the credit or debit card details used when joining the scheme.
• If the applicant did not opt for auto renewals they must access their online account prior to the expiry date and renew their annual subscription.
• The applicant will receive an annual statement which will give details of which employers have accessed their CRB online account
• Failing to renew means – The annual subscription will be automatically cancelled

HOW THE PROCESS WILL WORK – EMPLOYERS? ORGANISATIONS

• The individual will present their CRB certificate to the prospective employer.
• The Employer will need to gain permission from the Applicant that they can log on to the update service. This will be possible only if the Applicant provides a certificate, associated reference details and their personal data to the organisation.
• The Employer will be required to enter some details about themselves and the individual to log onto the online service.
• The employer will then be presented with a status update in relation to that individual’s criminal record.
• If new information is available, the employer will be advised to apply for a new CRB check to obtain the latest information.
• It is the employer’s decision to do this; the CRB can only provide guidance. If the employer decides not to ask the individual to apply for a new CRB check, they must accept the associated risks in doing so.
• The Employer will not be able to access the online system if they have not received the Applicants consent to do so.
• The Employer will not be able to access the Applicants online details should they leave the company.

QUESTIONS AND ANSWERS

• When will the new online update service launch?
  The proposed implementation date is early 2013.

• Until this new service is introduced, is it business as usual for the CRB?
  Yes, in the meantime it is business as usual for the CRB. Please continue to make your applications for CRB checks via the usual channels.

• Will the move to the new Disclosure and Barring Service have any effect on this new service?
  No, the timeline for transition to the new Disclosure and Barring Service (DBS) is November 2012. This new update service will be developed in parallel with the move to the new organisation.
• Why is the Applicant expected to pay for the service of an annual subscription in addition to the cost of a CRB check?
  Should an Applicant choose to subscribe to the service an annual fee will be required. The level of fee has not yet been agreed but will be lower than the fee for a CRB check.
  . This will ensure that CRB checks are, in effect, portable and so reduce the need for multiple checks.
  The subscription fee will be more cost effective than applying for multiple CRB checks.
• Can Applicants apply once they have received their completed certificate?
  Yes, but there is a time limit in which you can do this. Using your certificate number, you will have 14 calendar days, from the date of issue, to go online and join the new update service. You will be provided with a unique ID reference that you will be able to provide to organisations together with your completed certificate.
• Does this mean that Applicants may only ever need one CRB check?
  Yes – They may only require one if they are continuing to work in the appropriate sector for which the check was issued, and no new information comes to light. If they are working with children, they may use it to apply for another job working with children. Similarly, if they are working with vulnerable adults, they may apply for another job working with vulnerable adults using the same certificate. The organisation can carry out a status check to establish if any new information has come to light since your last certificate was issued. If they are moving to a workforce not covered by their current certificate or a different level of check is required, a new certificate will need to be sought.
• What information will the employer be able to see if new information is known?
  When the employer logs onto the online update service to request a status check, the check will highlight that ‘new information’ is known. It will not detail what it is, but the employer will be able to request a new CRB check to obtain full details.
• Who will be able to view the Applicants information?
  The Applicant will have to provide their consent, which in the majority of cases will be to the employer or organisation, to carry out an online status check. To see if any new information is available, they will need to provide them with a completed certificate. The Applicant will be able to view which organisations have performed an online status check on your certificate via your online account an annual statement.
• Will the update service notify the employer if the Applicant commits an offence or become barred?
  No. The update service will not notify the employer. The next time your employer logs onto the system to request a status check, the check will highlight that ‘new information’ is known. It will not detail what it is.
  The onus is on the employer to adopt appropriate HR/vetting processes and periodically to conduct status checks in line with the organisation’s re-checking policy.
  However, the police have common law powers enabling them to inform an employer where they suspect the commission of a crime or need to protect the public. The purpose of the update service is to provide a proportionate and fair system that provides information where appropriate, and balances the need to protect and respect individuals’ privacy.
• If a conviction is removed from the applicant’s criminal record, will a Status Check reveal this?
  No. If a conviction is removed from the Police National Computer this will not be revealed on a status check.
• Can Applicants refuse to join the service?
  The CRB will not mandate anyone to join the scheme.
• What if the Applicant were to lose their unique ID reference number, what should they do?
  They should contact the CRB on 0870 90 90 811 to request a new ID reference number.
• How secure is this process and will the Applicants details be safe?
  The online update service will be deployed onto the secure accredited CRB platform and will therefore inherit the security qualities it provides.
• Is anybody allowed to apply to subscribe?
  An individual can only join if they are applying for a CRB check, or are in receipt of a CRB certificate that has been issued in the last 14 days.
• If the Applicant already has several convictions; will they be able to join the scheme?
  Yes.
• If the Applicant fails to renew their subscription can the Employer still access their online account?
  No – once the annual subscription has expired and has not been renewed then the Employer will not have access to their employees account
• Can the Employer pay for their Employees annual subscription?
  Yes the Employer may choose to pay for their employees/applicants subscription; they must first seek the applicant’s permission to access their data online.
• If the Employer pays for their Employees subscription, can they apply on the Applicants behalf?
  The subscription is always made by the Applicant not the Employer, the information obtained by the Employer will be as a result of the Applicants authority.
• What happens if the Employee leaves the Organisation?
  The organisation should not access their former employees data, the former employee will receive an annual statement and will see which client organisations have accessed their account and on what date.
• Where can I find out more information?
  The CRB will be providing regular updates via the Website and other appropriate channels when there is further information to convey to Umbrella organisations and registered bodies.

Please note that the information above regarding the portability of CRB Checks is currently in development stages and this information is a proposal of the new service.