Lighthouse Hazlemere, Lighthouse High Wycombe and Lighthouse Administration
Criminal Records Bureau Disclosures (CRBD) Policy 2010

Version Date: May 2010

 

Lighthouse is an organisation operated by multiple charities. This document applies to:

1. Lighthouse Hazlemere
2. Lighthouse High Wycombe
3. Lighthouse Administration (operated by The Encounter Trust)

These charities share a common administration system and database.  Applicants may transfer between Lighthouses at any time.  All data including CRB Disclosure information is shared. 

Lighthouse Hazlemere (LHH), Lighthouse High Wycombe (LHHW) and Lighthouse Administration (LHA) will observe guidance issued or supported by the Criminal Records Bureau (CRB) and will comply fully with the CRB Code of Practice and Explanatory Guide.

LHH, LHHW and LHA will not unfairly discriminate against the subject of Disclosure information on the basis of conviction or other details revealed in accordance with the Lighthouse (LH) policy on the recruitment of ex-offenders (see appendix 1).

LHH, LHHW and LHA will handle, use, store, retain and dispose of Disclosure information in full compliance with the CRB Code and in full accordance with the Lighthouse (LH) policy on the handling and safe keeping of Disclosure information (see appendix 2). To this end we will not copy any completed application forms.

Each Lighthouse will appoint a CRB administrator who will ensure that all persons involved in checking CRBD applications for their Lighthouse are trained in and kept up to date on changes to CRB requirements.  LHH, LHHW and LHA are aware of the potential pitfalls of identity checks being carried out by connected persons and ensures that CRB identity checks are not undertaken by any such connected persons.

An Enhanced CRB Disclosure is required for all volunteers, including Trustees and other management committee members of Lighthouse, (otherwise known as LH) and The Encounter Trust.

All volunteers (aged of 17 or over during a Lighthouse Event) who apply to be a Lighthouse Team Member will be subject to a CRBD check. If the applicant refuses to complete a CRBD application, LH will be unable to proceed further with the applicant. In addition if an applicant fails to complete a CRBD after having a Trustee sign-off the previous year LH will be unable to proceed further with this applicant.

In exceptional circumstances e.g. where the applicant has applied too late or is unable to provide the appropriate supporting documentation LHH and LHHW may still offer the applicant a volunteer position but only after a careful risk assessment as per appendix 3. This is entirely at the discretion of the Trustees.

Volunteer positions will be conditional upon satisfactory CRB checks having been received.

In line with guidance from Criminal Records Bureau LHH,  LHHW and LHA do not accept existing CRB disclosures (CRBD) from other organisations.

Disclosures and the information they contain will only be available to those who need to have access in the course of their duties.

CRBD applications will be processed through Peters Research Ltd  (a "Registered Body" for this purpose). Peters Research Ltd and the CRB do not charge for Lighthouse volunteer positions.

We will issue to the applicant a covering letter, guidance notes and CRB application forms as provided by Peters Research Ltd. We will also advise each applicant of the existence of the CRB Code of Practice and make a copy available upon request.

In conjunction with Peters Research Ltd we will provide annual training for all checkers. Only when this training has been completed will they be considered an authorised checker.

We will provide Peters Research Ltd with a list of approved CRB checkers who have received the guidance notes, attending the training and acknowledged and accepted their responsibilities by signing a confirmatory letter.

We will check the applications and relevant proofs of identity in line with the guidelines provided by CRB and Peters Research Ltd. All relevant details will be recorded in Section X of the application form and where necessary on an additional information sheet. We only conduct ID checks on a face to face basis. If an applicant is unable or unwilling to comply with this policy they will be advised to use the “Veri-fy” service. Further details will be provided upon request.

Completed applications will be forwarded to LHA who will update the relevant database to show that a CRB application has been submitted and pass the forms to Peters Research Ltd for processing.

If there are any errors or omissions the form will be returned by Peters Research Ltd with a covering note to the LH CRB Administrator. It is the responsibility of each checker to contact the applicant to make the necessary amendments.

No copies of the application forms will be kept.

Peters Research Ltd will pass the CRB Disclosure (CRBD) confidentially to the Lighthouse CRB Administrator.

On receipt the LH CRB administrator will up date the LH database to show that the CRBD is satisfactory. In the event of it not being satisfactory the LH CRB administrator will contact the relevant LH chairman who will then review the volunteer’s application to see if the information on the CRBD is line with the information supplied at the time of application. If not, the LH chairman will contact the applicant to provide them with a final opportunity to supply information about any un-declared convictions. The LH chairman, in consultation with other trustees, will make the decision as to whether or not the applicant may be accepted.  If full information has not been provided, the applicant will be refused automatically.

At no time will Peters Research Ltd be involved in recruitment decisions.

We will file the disclosure securely in accordance with the CRB code of practice and in line with the LH policy on the handling and safe keeping of Disclosure information. This will be for no more than 6 months after which time it will be destroyed securely.

At an agreed date prior to each Lighthouse event, LHA will provide LHH and LHHW with details of all applicants who not have a completed CRB Disclosure.

 
Appendix 1

Lighthouse
Policy Statement on the Recruitment of Ex-offenders

As an organisation using Criminal Records Bureau (CRB) Disclosure service to assess applicants’ suitability for positions of trust, Lighthouse complies fully with the CRB Code of Practice and undertakes to treat all applicants for positions fairly. It undertakes not to discriminate unfairly against any subject of a Disclosure on the basis of a conviction or other information revealed.

Lighthouse is committed to the fair treatment of its staff, potential staff or users of its services, regardless of race, gender, religion, sexual orientation, responsibilities for dependants, age, physical/mental disability or offending background.

This policy statement on the recruitment of ex-offenders is made available to all Disclosure applicants at the outset of the recruitment process (advertised as available from www.lighthouseadmin.org or on request).

We actively promote equality of opportunity for all with the right mix of talent, skills and potential and welcome applications from a wide range of candidates, including those with criminal records. We select all candidates based on their skills, qualifications and experience.

A Disclosure is always requested as Lighthouse is working with children and young people.  All application forms will contain a statement that a Disclosure will be requested.  We ask all applicants to provide details of their criminal record on the application form provided.  This form will only be seen by those who need to see it as part of the recruitment process.

As a position with Lighthouse may lead to having sole charge of children, applicants are exempt from the “Rehabilitation of Offenders Act 1974”.  We therefore require details of both “spent” and “unspent” convictions as defined in the act.

We will ensure that all those in Lighthouse who are involved in the recruitment process fully understand how to identify and assess the relevance and circumstances of offences. We also ensure that they have received appropriate guidance in the relevant legislation relating to the employment of ex-offenders, e.g. the Rehabilitation of Offenders Act 1974.  In the first instance, we will ensure that all who are involved in the recruitment process have read and fully understood the document, “CIPD Employing Ex-offenders, a practical guide” available from http://www.crb.homeoffice.gov.uk/PDF/CIPD_Employing_ex-offenders%20guide.pdf

In any interview, we will ensure that an open and measured discussion takes place on the subject of any offences or other matter that might be relevant to the position. Failure to reveal information that is directly relevant to the position sought could lead to withdrawal of an invitation to participate.

We make every subject of a CRB Disclosure aware of the existence of the CRB Code of Practice and make a copy available on request.

We undertake to discuss any matter revealed in a Disclosure with the person seeking the position before declining the applicant a position at Lighthouse.
 
Having a criminal record will not necessarily bar an applicant from working with Lighthouse. This will depend on the nature of the position and the circumstances and background of the applicant’s offences.

 
Appendix 2

Lighthouse
Policy Statement: Secure Storage, Handling, Use, Retention & Disposal of Disclosures and Disclosure Information

General Principles

As an organisation using the Criminal Records Bureau (CRB) Disclosure service to help assess the suitability of applicants for positions of trust, Lighthouse complies fully with the CRB 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 1998 and other relevant legislation pertaining to the safe handling, use, storage, retention and disposal of Disclosure information and has a written policy on these matters, which is available to those who wish to see it on request.

Storage and access

Disclosure information will be kept securely, in lockable, non-portable, storage containers with access strictly controlled and limited to those who are entitled to see as part of their duties.

Handling

In accordance with section 124 of the Police Act 1997, Disclosure information is only passed to those who are authorised to receive it in the course of their duties. We maintain a record of all those to whom Disclosures or Disclosure information has been revealed and irecognise that t is a criminal offence to pass this information to anyone who is not entitled to receive it.

Usage

Disclosure information is only used for the specific purpose for which it was requested and for which the applicant’s full consent has been given.

Retention

Once a recruitment (or other relevant) decision has been made we do not keep Disclosure information for any longer than is necessary. This is generally for a period of up to 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 information for longer than six months, we will consult CRB about this and will give full consideration to the data protection and human rights of the individual before doing so. Throughout this time, the usual conditions regarding the safe storage and strictly controlled access will prevail.

Disposal

Once the retention period has elapsed, we will ensure that any Disclosure information is immediately destroyed by secure means, i.e. by shredding, pulping or burning. While awaiting destruction, Disclosure information will not be kept in any insecure receptacle (e.g. waste bin or confidential waste sack). We will not keep any photocopy or other image of the Disclosure or any copy or representation of the contents of a Disclosure. However not withstanding the above we will keep a record of the date of issue of a Disclosure, the name of the subject, the type of 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.

 

Appendix 3

 

Dear Trustees

Criminal Records Bureau Disclosure (CRBD) Application 

According to the Lighthouse database, the following person has applied to help at Lighthouse and/or Fresh Café, but does not have a completed Criminal Records Bureau Disclosure.

Name:   «title» «first_name» «surname»
Address:    «add_1»
«add_2»
«add_3»
«add_4»
«add_5»
«add_6»

Date of Birth:   «dob»  

Lighthouse site:  «event»

If there are any special circumstances, we have noted them below:

CRBD Notes:     «crb_notes»

The candidate offered the following referees whom we have contacted.  You may assume that the references were satisfactory unless we contact you to advise to the contrary.

«ref1_title» «ref1_first_name» «ref1_surname»«ref1_add1»«ref1_add2»«ref1_add3»«ref1_add4»«ref1_add5»«ref1_add6»Tel: «ref1_tel» «ref2_title» «ref2_first_name» «ref2_surname»«ref2_add1»«ref2_add2»«ref2_add3»«ref2_add4»«ref2_add5»«ref2_add6»Tel: «ref2_tel»

The candidate is currently allocated the following role(s) and age group.

«rolesrole_value»
«roles_1role_value»
«roles_2role_value»
«roles_3role_value»
Age Group: «allocated_age»

 

 

In accordance with the Lighthouse CRBD policy, we will write to the applicant to inform them that we will be unable to offer them a position as a Lighthouse helper this year.  Alternatively, if you want to bypass the CRBD process for this applicant, please countersign this letter and return it to the Lighthouse office.  Thank you.

Yours sincerely

 
Richard D Peters

 

Is the applicant known personally to a Trustee ?      Y/N

Referees contacted by Trustee?        Y/N

Comments:

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

Trustees decision:       Accept  /  Decline Applicant

Signature: _____________________________

Name:    _____________________________

On behalf of Lighthouse Hazlemere/High Wycombe Trustees