Safe recruitment policy template

1. What the regulation says

Regulation 19

Persons employed for the purposes of carrying on a regulated activity must:

be of good character,

have the qualifications, competence, skills and experience which are necessary for the work to be performed by them, and

be able by reason of their health, after reasonable adjustments are made, of properly performing tasks which are intrinsic to the work for which they are employed.

Where these requirements are not met, the registered person must:

take such action as is necessary and proportionate to ensure that the requirement in that paragraph is complied with, and

if the person is a health care professional, social worker or other professional registered with a health care or social care regulator, inform the regulator in question.

Regulation 19(3) requires that the information specified in Schedule 3 is available to be supplied to the Commission in relation to each person employed.

Schedule 3: Information required in respect of persons employed

The verbatim text of Schedule 3, paragraphs 1 to 9:

1. Proof of identity including a recent photograph.

2. Where required for the purposes of an exempted question in accordance with section 113A(2)(b) of the Police Act 1997, a copy of a criminal record certificate issued under section 113A of that Act together with, after the appointed day and where applicable, the information mentioned in section 30A(3) of the Safeguarding Vulnerable Groups Act 2006 (provision of barring information on request).

3. Where required for the purposes of an exempted question asked for a prescribed purpose under section 113B(2)(b) of the Police Act 1997, a copy of an enhanced criminal record certificate issued under section 113B of that Act together with, where applicable, suitability information relating to children or vulnerable adults.

4. Satisfactory evidence of conduct in previous employment concerned with the provision of services relating to (a) health or social care, or (b) children or vulnerable adults.

5. Where a person (P) has been previously employed in a position whose duties involved work with children or vulnerable adults, satisfactory verification, so far as reasonably practicable, of the reason why P's employment in that position ended.

6. In so far as it is reasonably practicable to obtain, satisfactory documentary evidence of any qualification relevant to the duties for which the person is employed or appointed to perform.

7. A full employment history, together with a satisfactory written explanation of any gaps in employment.

8. Satisfactory information about any physical or mental health conditions which are relevant to the person's capability, after reasonable adjustments are made, to properly perform tasks which are intrinsic to their employment or appointment for the purposes of the regulated activity.

9. For the purposes of this Schedule (a) "the appointed day" means the day on which section 30A of the Safeguarding Vulnerable Groups Act 2006 comes into force; (b) "satisfactory" means satisfactory in the opinion of the Commission; (c) "suitability information relating to children or vulnerable adults" means the information specified in sections 113BA and 113BB respectively of the Police Act 1997.

The full text of Regulation 19 is at https://www.legislation.gov.uk/uksi/2014/2936/regulation/19 and Schedule 3 is at https://www.legislation.gov.uk/uksi/2014/2936/schedule/3. Where this policy and the regulation or schedule diverge, the regulation wins.

2. Plain-English summary

Everyone you employ to provide a regulated activity must be of good character, suitably qualified and competent for the work, and capable in health (with reasonable adjustments). You have to operate effective recruitment procedures. For each employee you have to hold the Schedule 3 information (plus any other required-by-law records); volunteers get a partial carve-out, under Regulation 19(3A), from the Schedule 3 paragraph 7 full-employment-history requirement, not from the identity or recent-photograph requirement. Staff requiring professional registration must hold it.

For each employee you must hold the Schedule 3 information set, which is:

1. Proof of identity including a recent photograph.
2. A standard criminal-record certificate (Police Act 1997 section 113A) where the role and exempted question make that certificate required.
3. An enhanced criminal-record certificate (Police Act 1997 section 113B) where the prescribed purpose makes that certificate required, together with applicable suitability or barring information.
4. Satisfactory conduct evidence from previous employment in health, social care, or work with children or vulnerable adults.
5. Reason-for-leaving verification for any previous job that involved work with children or vulnerable adults.
6. Qualification evidence for the duties the person will perform, so far as reasonably practicable to obtain.
7. A full employment history plus a satisfactory written explanation of any gaps.
8. Health information relevant to the person's capability to do the job, after reasonable adjustments.

CQC reads "satisfactory" as "satisfactory in the opinion of the Commission". The provider must hold the information for each employee from the start of employment; CQC may ask to see it at inspection. The provider obtains the legally eligible and appropriate level of criminal-record check for the role. It does not treat standard and enhanced certificates as two checks that every worker must hold. Staff requiring professional registration (NMC, GMC, HCPC, GDC, GPhC, Social Work England, others) must hold current registration as a separate condition on top of the Schedule 3 set. Volunteers get a partial carve-out, under Regulation 19(3A), from the Schedule 3 paragraph 7 full-employment-history requirement (unless Regulation 4, 6 or 7 applies); the identity and recent-photograph requirement and the rest of Schedule 3 still apply where the role attracts them.

3. Purpose, fair and lawful recruitment

The purpose of this policy is to prevent unsuitable people from starting or continuing regulated-activity work, while giving every applicant a fair, lawful and accessible recruitment process. Each appointment must leave a complete decision trail showing what was checked, who verified it and why the person was judged suitable for the specific role.

The Service recruits fairly and lawfully:

• recruitment decisions are based on the person's ability to do the job; the Service does not treat anyone less favourably because of a protected characteristic, in line with the Equality Act 2010
• the Service makes reasonable adjustments at every stage so that disabled applicants are not disadvantaged
• adverts and job descriptions are clear about the role, the person specification, and the checks involved, including where a role is exempt from the Rehabilitation of Offenders Act
• applicant information is personal data; the Service holds, uses and retains it lawfully and securely under the UK GDPR and the Data Protection Act 2018, and keeps it only as long as needed

4. Scope

This policy applies to , when , at . It covers employees, and (where the Service uses them) volunteers, apprentices, agency and bank workers, and workers recruited from overseas.

Local adoption decisions

Before adoption, the provider completes the staff groups, locations and service types above and records:

• who may advertise, shortlist, interview, verify checks and approve a start
• the DBS eligibility and barred-list decision for each role, based on current DBS guidance
• acceptable identity, reference, qualification, right-to-work and professional-registration evidence
• the employment-gap threshold and escalation route for incomplete or conflicting information
• the risk-based DBS status-check or recheck process, including use of the Update Service where lawful and agreed
• the HR record system, retention schedule, assurance-calendar prompts and governance forum

5. Roles and responsibilities

• Registered Manager: accountable for the Schedule 3 record being complete for every employee in regulated-activity scope, for the provider's documented DBS status-check or recheck approach, and for the audit cadence below. Regulation 19 does not set a universal three-year DBS renewal interval.
• Nominated Individual: holds overall provider-side accountability for Reg 19 compliance across all sites and services.
• HR or recruitment lead: operates the recruitment process and the Schedule 3 evidence-gathering, captures the record, and surfaces any gaps to the Registered Manager before the offer is confirmed.
• : confirms qualification and competence sufficiency for the specific role.
• All staff: notify the Registered Manager of any change to their professional-regulator status, health condition relevant to their role, or barring status.

The provider replaces the example role names with its accountable local roles. The responsibilities above are the minimum control set.

6. The recruitment process

The Service follows clear, consistent stages for every appointment:

1. Advertise. An accurate advert and job description set out the role, the person specification, and the pre-employment checks.
2. Apply. A written application captures a full employment history and the information the Service needs to shortlist fairly.
3. Shortlist. Shortlisting is done against the person specification, on a consistent basis and by more than one person where possible.
4. Interview. A structured, values-based interview assesses suitability, competence, and approach to safe, person-centred care.
5. Conditional offer. Any offer is conditional on the pre-employment checks being satisfactory.
6. Pre-employment checks. Identity, right to work, references, DBS and the rest of the Schedule 3 set are completed (sections 7 and 9).
7. Start and induction. The person begins regulated-activity work only once the checks are complete and signed off, and completes induction and any required training before working unsupervised.

7. Right to work and overseas workers

• the Service confirms every new worker's right to work in the UK before they start, and keeps the evidence
• where the Service recruits a worker from overseas under the points-based immigration system, it holds a valid sponsor licence, issues a Certificate of Sponsorship, and confirms the worker's visa and its conditions before they start
• the Service gives overseas workers any extra support they need, for example a longer induction, support with English language, and help to understand UK care standards and the rights of people who use the service
• where the Service keeps a separate overseas-worker or sponsorship policy, it is read alongside this policy

8. Volunteers and apprentices

Where the Service uses volunteers or apprentices:

• they are recruited with the same care, and the Schedule 3 checks apply to the extent the role attracts them (for example a volunteer in a role involving regulated activity with children or vulnerable adults receives the appropriate enhanced DBS check). Where the person is a volunteer, Regulation 19(3A) removes the requirement to obtain the Schedule 3 paragraph 7 full employment history with written explanation of gaps, unless Regulation 4, 6 or 7 applies. The identity requirement, including proof of identity and a recent photograph, still applies
• they work within a defined role, are supervised, and are not given responsibilities beyond their training and checks

9. The Schedule 3 information set and checks

This procedure operationalises Reg 19(3) and walks every new employee through the eight Schedule 3 items plus the professional-registration check.

1. Role definition. Before recruitment opens, the hiring manager confirms the role's regulated-activity scope, whether the role is exempt from the Rehabilitation of Offenders Act for criminal-record-check purposes, whether the role involves regulated activity with children or vulnerable adults, and any professional-registration requirements.
2. Identity and photograph. At the point of offer, the recruitment lead collects proof of identity (photographic ID plus address proof) and a recent photograph.
3. Criminal-record check. The DBS eligibility decision is recorded first. The legally eligible and appropriate standard or enhanced check is then requested, with barred-list information where the role and law require it. The record captures the check type, workforce, certificate date and number, verifier, outcome and any risk decision. Any future status check or recheck follows the provider's documented risk-based process, current law and any commissioner or contract requirement. There is no universal three-year statutory default in this template.
4. Suitability information. Where the role involves regulated activity with children or vulnerable adults, suitability information relating to children or vulnerable adults is obtained alongside the enhanced check.
5. Conduct and reason-for-leaving. Two references are sought, at least one from the most recent employer in a health, social care, or vulnerable-people role; the reference covers conduct in the role and the reason the employment ended. Reasons-for-leaving are confirmed in writing where reasonably practicable.
6. Qualification evidence. Documentary evidence of any qualification relevant to the role is captured. Where the qualification is unavailable, the file records the steps taken to obtain it.
7. Employment history. A full employment history is captured, with a written explanation of any gap longer than the provider's stated threshold.
8. Health information. The new starter completes a health declaration covering any physical or mental health condition relevant to the role's intrinsic tasks. Where occupational-health advice is needed, the referral is recorded.
9. Professional registration. Where the role requires professional registration, the registration number is captured and verified against the live register. The renewal date is set on the assurance calendar.
10. Sign-off. The Registered Manager confirms the Schedule 3 set is complete (or, where any item is genuinely not reasonably practicable to obtain, the reasoning is recorded) before the new starter begins regulated-activity work.

Each step writes an audit-trail event against the person record. The completed Schedule 3 set is reviewed at the audit cadence below.

10. Recruitment complaints

An applicant or worker who wishes to raise a concern or complaint about the recruitment process can do so to . The Service handles it under its complaints policy, fairly and without it affecting any current or future application. A person may also ask for feedback on a recruitment decision.

The provider names the contact before adoption.

11. Training requirement

All staff with recruitment or HR responsibilities complete <named training, e.g., safer recruitment + DBS process awareness> at induction and at <interval, e.g., every two years>. Records are kept in .

The provider completes the training, interval and register fields before adoption.

12. Audit

Compliance with this policy is monitored by <named role, typically the Registered Manager or quality lead> on <frequency, typically quarterly>, through a per-employee Schedule 3 file audit. A practical sample is N records from the active staff list plus every new starter since the last audit. Audit findings are recorded in the provider's audit register and reviewed at on <frequency, typically quarterly>.

The provider's DBS status-check or recheck dates and professional-registration renewal dates are surfaced on the assurance calendar so overdue checks are visible before they become Regulation 19 gaps.

The provider completes the angle-bracket placeholders before adoption.

13. Records and evidence fields

The Schedule 3 record for each employee is held in , in the person's confidential file. For each required check, the record includes:

• the requirement and why it applies to the role
• evidence received, its source and the date received
• who verified the evidence, when and against which source
• status: satisfactory, incomplete, conditional or not applicable
• any discrepancy, risk assessment, exception and Registered Manager sign-off
• any expiry, professional-registration renewal, DBS status-check or risk-based recheck date
• the final suitability decision, restrictions and date approved for unsupervised work

Recruitment complaints, induction and competence actions are cross-linked to the person record. Audit findings are linked to the audit register and any resulting improvement action or workforce risk.

The retention period is . Unsuccessful applicants' personal data is kept only as long as needed and then securely destroyed under the UK GDPR and the Data Protection Act 2018.

CQC may request to see the Schedule 3 record at inspection; the record must be available to be supplied to the Commission per Reg 19(3).

14. Accessible information and specialist services

The Service makes its recruitment information and this policy available in accessible formats on request. A service specialising in the care of autistic people or people with a learning disability recruits staff with the values, skills and training needed to communicate and work with them, and shows how it does so.

15. Related policies in this pack

This policy should be read with:

• Staffing Policy
• Good Governance Policy
• Safeguarding Adults Policy
• Fit and Proper Persons (Directors) Policy
• Training, Competency and Mandatory Training Policy
• Supervision, Appraisal and Staff Support Policy
• Confidentiality, Information Governance and Data Protection Policy

16. Sources and further reading

This template is based on CQC's guidance for providers and managers, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and other topic-specific legislation and guidance listed below. It is a starting point for adaptation, not a substitute for legal, clinical, HR, safeguarding or specialist professional advice.

• CQC Regulation 19: Fit and proper persons employed
• DBS eligibility guidance
• DBS Update Service guidance
• DBS barring referral guidance
• Professional regulator registers (NMC, GMC, HCPC, GDC, GPhC, Social Work England, others)
• ACAS recruitment guidance
• Equality Act 2010 (https://www.legislation.gov.uk/ukpga/2010/15)
• UK GDPR and Data Protection Act 2018 (https://www.legislation.gov.uk/ukpga/2018/12)
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 19 (https://www.legislation.gov.uk/uksi/2014/2936/regulation/19) and Schedule 3 (https://www.legislation.gov.uk/uksi/2014/2936/schedule/3)

17. When to seek further advice

Seek specialist advice where the issue involves serious harm, safeguarding, deprivation of liberty, restraint, children, professional misconduct, controlled drugs, radiation, termination of pregnancy, infection outbreak, water safety, employment dismissal, DBS barring referral, or regulatory enforcement.

18. Document control

This sample policy template was issued by Verivius. It is a template, not a substitute for legal advice or the provider's own policy-development process. Where this template and live law or regulator guidance diverge, the live source wins.