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Policy regarding the Security, Storage and Retention of Applicant/Staff Criminal Records Information

The following guidelines apply to all forms of criminal records check information, including applications, the outcomes of criminal records check requests and all related documentation. These guidelines are in line with the JDAM Security’s Policy on the Recruitment and Employment of Ex-offenders and must be adhered to at all times, failure to do so will be subject to formal investigation and may lead to disciplinary action.

1. Security

Criminal records check information received on behalf of JDAM Security must be kept securely and only those entitled to see it in the course of their duties should have access. It is anticipated that in the majority of cases access should be restricted to JDAM Security employees directly involved in the recruitment process.

Requests to access this information from any other party, internal or external, should be approved by HR for staff (and Student Recruitment, Admissions and International Relations for students).

In the case of Disclosure applications, the Disclosure and Barring Service (DBS) operates strict guidelines regarding access to this information, and passing on Disclosure information in circumstances which do not conform with these requirements could be considered a criminal offence.

2. Usage

Criminal records check information should only be used for the specific purpose for which it was requested and for which the applicant’s full consent has been given.

3. Storage

Disclosures and other confidential documents received in relation to appointee/staff will be stored in secure conditions centrally by HR, separately from the individual’s personal file in line with DBS requirements.

4. Retention

Once a recruitment decision (or other relevant decision, e.g. for regulatory or licensing purposes) has been made, the Disclosure and any related correspondence will not be retained for longer than is necessary for that particular purpose.

In general this will be for a maximum of 6 months following the date of the recruitment decision, to allow for any disputes about the accuracy of a Disclosure or a recruitment decision to be made and considered.

In the case of a dispute, Disclosure information may be retained for a longer period, but in general this should be for no longer than 6 months after resolution of the dispute. If in exceptional cases it is considered necessary to retain Disclosure information for a longer period, the DBS will be consulted.

5. Disposal

When the time has come to dispose of the criminal records check information, no photocopy or other image of the Disclosure may be made or kept.

However, the following information will be recorded by HR for appointee/staff checks prior to the criminal records check information being disposed of securely – the date of the criminal records check, the name of the subject, the type of check, the position in question, the unique number on the certificate, the name of the members of HR staff who dealt with the case, and the recruitment decision made.

6. Lost Criminal Records Checks

If a Disclosure or related documentation is lost, the JDAM Security will inform the DBS immediately.

7. Concerns re. Criminal Records Check activity

If any member of staff or applicant has concerns regarding the use of criminal records checks in the staff recruitment process, or any element of the storage, retention or disposal of this information, she/he may raise this in the strictest confidence HR.


Reference:

DBS Code of Practice