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Disclosure and Barring Service (DBS) Policy and Guidance 2023-24
Last updated: 01/09/22
What do I need to bring to registration for id verification?
How do I track the progress of my application after it has been submitted?
What do I need to do with my DBS certificate after receiving it?
What does Central do with the information detailed on the DBS certificate?
What happens if I don’t receive my certificate from the DBS after completing the application?
What happens if I don’t engage in this process by the end of the autumn term?
Who sits on the DBS panel and what decisions can the DBS panel make?
This policy and guidance is intended for prospective and current students who may require a Disclosure and Barring Service (DBS) check and, where appropriate, to ascertain whether you are barred from working with children or vulnerable adults. Other relevant policies also include the School’s policy in respect of applicants with criminal records which can be found in the Admissions Handbook and the School’s Safeguarding Policy.
This policy applies to all current or prospective students registered, on or applying for, any programme involving activity with children, young people or vulnerable adults. Those programmes currently are:
BA (Hons) Contemporary Performance Practice
Drama Applied Theatre and Education
Writing for Performance
MA Applied Theatre
MA Drama and Movement Therapy
The policy also applies to all current or prospective students on any programme (including those stated above) wishing to undertake placement learning or work-based learning activities where they will be engaged in activity with children or vulnerable adults.
In the law of England a wide definition is applied to meet the standard of vulnerable adult. Section 59 of the Safeguarding Vulnerable Groups Act 2006 states that a person is a vulnerable adult if, having attained the age of 18, s/he is in residential accommodation, is in sheltered housing, receives domiciliary care, receives any form of health care, is detained in lawful custody, by virtue of an order of a court, is under supervision per Criminal Justice Act 2003 sections regarding community sentences, receives a welfare service of a prescribed description, receives any service or participates in any activity provided specifically for persons who has particular needs because of his age, has any form of disability or has a prescribed physical or mental problem. (Dyslexia, dyscalculia and dyspraxia are excluded disabilities), has payments made to him/her or to an accepted representative in pursuance of arrangements under Health and Social Care Act 2012, and/or requires assistance in the conduct of own affairs.
Current or prospective students who are barred from undertaking activity involving children or vulnerable adults, or those that have any type of disclosure but are not undertaking regulated activity, should consult the policy in respect of applicants with criminal records in the Admissions Handbook.
2. What is the Disclosure & Barring Service?
The DBS is an executive agency of the Home Office and provides wider access to criminal record information through its checking service. The DBS searches police records and, in relevant cases, information held within the Disclosure & Barring Service, and issues a detailed DBS certificate directly to the applicant. DBS checks are only available where an organisation is entitled to ask exempted questions under the Exceptions Order to the Rehabilitation of Offenders Act (ROA) 1974. The Exceptions Order acts as the gateway for access to the DBS checking service and lists those occupations, professions and positions considered to be exempt from the ROA.
3. What is a Disclosure & Barring Service Check?
A DBS check provides details of a person’s criminal record including all convictions, cautions, reprimands and warnings held on the Police National Computer (PNC) and all information held by local police forces to help prevent unsuitable people from working with vulnerable groups, including children. If we have asked you to obtain a DBS check, this will be what is called an Enhanced Disclosure. This provides details of your criminal record, including all convictions, cautions, reprimands and warnings held on the Police National Computer (PNC) and all information held by local police forces. If your programme or placement involves working unsupervised with children or vulnerable adults, the Enhanced Disclosure will also check the DBS’s Children’s and Adults’ barred lists of those considered unsuitable for or banned from this type of work. Some institutions such as prisons, young offender institutions or other secure facilities may require additional security and criminal record checks to those of the enhanced disclosure.
If you are being asked to submit to a DBS check then you are either applying for a programme where such placements or work-based learning activity are a mandatory part of the programme, or you have elected to undertake an optional placement or work-based learning activity where you will be in an unsupervised environment with children or vulnerable adults. As such, under the law, the School is required to obtain a DBS check.
5. Can I refuse to apply for a DBS Check?
Yes, but if you do, the School will not be able to allow you to undertake the placement or work-based learning requirements of your programme of study. For students applying to the programmes stated above, this is likely to mean that you are ineligible for registration/ unable to continue on that programme. No student will be permitted to attend a placement involving regulated activity without a satisfactory DBS check being received or alternative measures being put in place by the DBS Panel.
6. What if I already have a DBS Check?
In order to discharge our responsibilities, and to ensure that the information we have is as up-to-date as possible, you must apply for a new Enhanced Disclosure through Central, or we must be able undertake a status check on an existing Enhanced Certificate via the DBS Update Service. There are no exceptions to this rule.
If you are registered with the Update Service you will be making an annual payment direct to the DBS. If not then your DBS was not registered with them and you’ll need to apply for a new DBS check through Central.
To undertake a status check on an existing Enhanced Certificate via the DBS Update Service, we would be required to:
See the original, hard copy of your existing Enhanced Certificate
Check your ID to confirm your identity
Have your written consent to access the information on your Certificate
Ensure that we are legally entitled to the same level of DBS Certificate
Check that your existing Certificate only contains the exact workforce that we are entitled to
know about, for the DBS role you would be assigned by Central
7. What is the DBS barred list?
The two DBS barred lists are lists that affect individuals who may not have a criminal record
disclosures, but of whom information may exist that would prevent them from working with either
children or vulnerable adults. These may be circumstances where an organisation has referred
someone to the DBS if they:
dismissed them because they harmed a child or adult;
dismissed them because they might have harmed a child or adult otherwise;
were planning to dismiss them for either of these reasons, but the person resigned first.
An applicant to, or student of, the programmes listed above found to be on either list will in all
likelihood be unable to be admitted to, or able to continue with, the programme. An applicant to, or
student of, programmes not listed above but wishing to undertake a placement or work-based
learning involving regulated activity and found to be on either list will not be permitted to undertake
the placement.
Visit the Gov.UK page Report someone as unfit to work with children or vulnerable adults for more information on Barred Lists.
8. What is regulated activity?
Any activity which involves contact with under 18s or vulnerable adults (as defined by section
59 of the Safeguarding Vulnerable Groups Act 2006) and is of a specified nature (e.g. teaching,
training, care, supervision, advice or treatment), frequency (i.e. once a month or more often),
intensity (i.e. taking place on more than two days in any 30-day period) and/or overnight (i.e.
activity that occurs at any time between 2am and 6am and the activity gives the person the
opportunity to have face-to-face contact with under 18s or vulnerable adults);
And/or any activity allowing contact with under 18s or vulnerable adults (as defined by section
59 of the Safeguarding Vulnerable Groups Act 2006) and is in a specified place (e.g. schools,
care homes, prisons etc.), frequency, intensity or overnight. Regulated activity also includes any
activity that involves, on a regular basis, the day-to-day management or supervision of a
person carrying out regulated activity.
The programmes listed in Section 1 all comprise regulated activity.
9. How do I complete a DBS check?
Central’s DBS checks are managed online by our application provider, OnlineDisclosures, to make the process as smooth, and as accessible as possible for applicants. These are the simple steps that complete the application process:
Online registration with First Advantage / OnlineDisclosures (takes approx. 3 minutes)
Completing the DBS application via the online portal (takes approx. 10 minutes)
Online verification of ID documentation from a member of Central staff. Students will be
asked to upload their ID documents as part of the online registration task
Online payment of DBS check fee, if relevant, to be made within 21 days of verification (takes
approx. 5 minutes)
On completion of all of these steps, your application will be checked by the OnlineDisclosures
Countersignatory Team and, if everything is correct, submitted to the DBS.
10. Getting started with OnlineDisclosures
Please refer to our Getting started Guide to registering with Online Disclosures and completing your application for Central specific information and tips. Further instructions are provided throughout each step of the online application.
Click through to find the guide to Getting Started with your OnineDisclosures DBS Check.
There is a detailed applicant guide available on the homepage of the First Advantage
OnlineDisclosures website if you require more information on how to complete a particular
section of the online form.
Or for instructions on how to complete the Application form view the Full Applicant User Guide
The actual check of your criminal record by the DBS takes approximately 14 – 60 days. However, some applications going to the London Metropolitan Police have taken much longer than the 60 day service level target. For this reason, please ensure you can complete your DBS verification at Registration or at one of the mop-up sessions and ensure pay within the 21 day timeframe to avoid delay.
11. Who are OnlineDisclosures?
Feedback from students in previous years has been that DBS paper application forms were confusing and time consuming. To make the process as quick, simple and as accessible as possible (and to reduce our impact on the environment), Central has engaged an online application provider, First Advantage OnlineDisclosures. They are one of the UK’s largest criminal record checking providers and you can find out more about their processes – including their Accessibility Statement and Privacy Policy.
12. How much does a DBS Check cost?
The cost of an Enhanced DBS check is £47.54. Students are responsible for paying this fee, unless they are eligible for a waiver. The fee is payable online once your ID documentation has been verified by Central staff and acceptable payment methods are credit or debit card or Paypal. From the point of ID verification, you will have 21 days to pay and once payment has been received, your application will then be submitted to the Disclosure and Barring Service for checking.
13. Am I eligible for a DBS Check fee waiver?
Central offers DBS check fee waivers for applicants who qualify, in order to ensure that this expense does not cause a barrier to you accessing your programme. If any of the following apply, you will be eligible for a DBS check fee waiver:
Home Students Only
You can check whether you would qualify for a Criminal Record DBS check fee waiver by entering your home postcode as UK Government data from these postcodes indicates areas where there are significant barriers to social mobility.
If your home postcode is listed as a number 1 or 2 in any of the following three columns listed below, you will be eligible for a Criminal Record check fee waiver:
Income (column H);
Education and Skills (column N);
IDACI: Income Deprivation Affecting Children Index (column X).
International and Home Students
Rather than focusing on income alone, we can also consider a range of factors to benefit more of our students. So if one or more of the below criteria applies to you, you can also claim a DBS check fee waiver if you can evidence that:
Your household income is under £25,000 per year
You are Care Experienced (Care Leaver/in the care of your Local Authority)
You have Caring Responsibilities (Young Carer/ Carer)
If your evidence is not provided in English, then it must be accompanied by an official translation into English.
We are only able to offer waivers to candidates who apply at least one week before teaching begins on their programme and before submitting their online application form for verification since there is a different process for fee waiver DBS applications.
In order to be considered for a DBS check fee waiver, you need to email [email protected] with a clear and evidenced outline on how you meet the criteria above. If you are eligible for a waiver, a member of the DBS team will get back to you by email to confirm details on the next steps. Please be aware that if the fee for your first DBS check is waived, the school will not cover the cost of a repeat check in the event that you lose your first certificate.
14. What is the process for Trans, Non-binary and Gender Diverse applicants?
The DBS offers a confidential checking process for such applicants who do not wish to reveal details of their previous identity to the institution who required them to complete a DBS check. For more information about the this process, email [email protected] or see the DBS Transgender Applications guidance.
15. What do I need to bring to registration for id verification?
In order to prove your identity, you must provide the three documents, which you confirmed in your online application you would present to us for verification. The documents needed will depend on the ID route you took, although applicants must try to provide documents from ‘Route 1’ first as detailed below. You will be guided through the routes and acceptable documentation in your online application.
Students will be asked to upload their three documents as part of the online registration task. An example of a Route 1 would typically include all of the following:
- One document from Group 1 (for example; a passport or a birth certificate (UK/EU) or a UK (EU) current driving licence (full or provisional)
- In addition to two further documents from either Group 1, or Group 2a or 2b (for example; a passport, a birth certificate (UK/EU), a UK (EU) current driving licence (full or provisional), Bank or building society statement, a Credit card statement or P45 or P60 statement for example.
At least one of the documents must show your current address (such as a bank statement or utility bill)
We understand that not all applicants will have the documents above and may need to take Route 2a or 2b. For full details of the different ID routes and for a full list of acceptable documents visit the Gov.UK website.
We also appreciate that some students may not yet have accommodation confirmed and are therefore unable to provide a current address, if this is the case please let us know on arrival and we can take you through the next steps.
16. How do I track the progress of my application after it has been submitted?
Once the fee for your check has been paid you will receive regular updates from OnlineDisclosures by email confirming which stage of the process your application is up to (providing you elected to receive email updates at the point of application). You can also log in to OnlineDisclosures at any time to check the status of your application.
17. What do I need to do with my DBS certificate after receiving it?
Your certificate is yours to keep and present to Placement Hosts as required. Central will be able to view the outcome of your check directly via OnlineDisclosures and we will only need to see the hard copy certitficate if there are any disclosures.
18. What does Central do with the information detailed on the DBS certificate?
If you do not have a criminal record your Certificate will come back with no information on it, we’ll
simply check the Certificate and download the Disclosure number and issue date to be secured in a
secure electronic database. Some Placement hosts ask for a letter confirming that your certificate is
clear. These can be downloaded from the Online Disclosures portal and we will ask your permission
before sharing this with the host. Letters that are downloaded will be deleted after a maximum of 6
months.
If you do have a criminal record (caution, warning, reprimand or conviction) this will be detailed on your DBS Certificate. In this case we will ask you for permission to take a copy of your hard copy certificate so that we are able to share the information with relevant persons which in the first instance is the DBS Panel. Disclosure information is stored electronically with access strictly controlled and limited to those who are entitled to see it as part of their duties (please see information on Privacy below).
19. What happens if I don’t receive my certificate from the DBS after completing the application?
OnlineDisclosures will automatically contact the DBS on your behalf if your application hasn’t been processed within 60 days of submission. It is your responsibility to monitor the email address you provided to OnlineDisclosures for important communications relating to your application. If your Certificate has not arrived in the post, over 14 days after the DBS completed your check and issued it, the DBS will be able process a request for a certificate reprint if all of the following points apply:
- Your DBS certificate was issued over 14 days ago, but you haven’t received it. You can find out the date your certificate was issued on through online tracking system;
- The reprint request has been made within 3 months (93 days) of the date of issue of your certificate;
- The address you request your certificate to be re-sent to matches the address on your DBS application.
Visit the DBS certificate reprint guide for full details of how to request a reprint.
20. What happens if I lose my certificate after receiving it?
Once you receive your Disclosure Certificate, please ensure that you keep it safe. If you lose your
Disclosure Certificate after it is issued and are not eligible for a reprint, you will be required to
complete the process again and pay for an additional check (even if you were eligible for a fee waiver
in the first instance).
21. How long is a DBS Check valid for?
Each DBS check will show the date on which it was issued. There is no official expiry date for a DBS check. Please note that students on programmes requiring a DBS check must provide an updated DBS check in order to re-enrol after a Break in Study - this is a mandatory condition of return to study for these programmes. The School will cover the cost of your second check.
22. What is the DBS Update Service?
The Update Service is a facility which enables an individual to have their DBS Certificate kept up-to date and to take it with them from role to role (within the same workforce) where the same type and level of check is required. Registration costs £13 per year and you can register for the update service using your DBS certificate number. You can register as soon as your application has been submitted to the DBS and within 19 days of the certificate being issued – you will not be eligible for the Update Service after this point. Visit the Gov.UK site DBS Update Service page for more information.
It is compulsory that Drama and Movement Therapy students register for the Update Service and, as this is a requirement of the programme, you will receive information about reimbursement for the initial fee following Registration.
23. What happens if I don’t engage in this process by the end of the autumn term?
We need, and appreciate, your cooperation in making this process as smooth as possible for everyone involved. It is your responsibility to engage with the DBS check process in full and to meet the associated deadlines. Being unaware of the process, personal feelings such as embarrassment, or concerns over the confidentiality of criminal convictions are not considered valid explanations and we encourage you to get in touch with us on [email protected] if you have any questions or concerns.
Most students should be able to have their DBS application verified through the academic registration process. However, those unable to do so will be invited to attend an alternative session (scheduled to take place during the first week of term).
Students who are unable to attend this alternative DBS verification session will be required to
complete the process via the Programmes Office and Student Centre (timings will be advertised to you
nearer the time). This should give those finalising accommodation sufficient time to do so and to
obtain the necessary proof of address.
Students will be issued with an informal warning from the Programmes Office Manager, and invited to attend a meeting to give explanation if they do not undertake the following steps by the advertised deadlines:
- Register with OnlineDisclosures and complete the online application form
- Provide suitable documentation for verification
- Pay the DBS check fee (if relevant)
Following an informal warning, students who are unable to complete the process if full, without
explanation, will be referred to the Academic Registrar and Director of Academic Services for
disciplinary action. As per Central’s published regulations, students in this position may be required to
suspend their studies, excluded or de-registered from the programme.
In addition to applying for a UK DBS Enhanced Disclosure, students who have been out of the United Kingdom for more than three consecutive months in the previous five years or have never lived in the UK prior to Registration will be required to undertake a police report or criminal record check (in some countries this is called a Certificate of Good Conduct) from the country in which they have lived since the age of 13.
This is common practice across Universities in the UK and there are no exceptions to this rule. To be clear, you need to undergo this check this even if you know you do not have a Criminal Record.
Please remember – this process can take up to 8 weeks therefore we urge you to apply for this well in advance to avoid delays to your Registration. Please be aware that in most cases you may need to apply for the check whilst still in your country of residence and before coming to the UK.
25. How do I request an overseas criminal record check?
The cost of an international criminal record check varies between countries and many countries have provided information on how to apply for certificates of good conduct and/or criminal records checks, and these can be found on the Gov.UK Criminal records checks for overseas applicants webpage.
We also advise applicants to confirm with the relevant embassy the process which applies to the country they have been resident in.
Some countries require more than one form to be filled in and/or for the applicant to supply copies of their ID. All requirements will be detailed within the country’s application form.
If the report is not in English then it must be accompanied by an official translation into English.
For ease, overseas criminal record checks can also be carried out by OnlineDisclosures but please be aware that they will charge VAT in addition to the cost of the check. A complete list of all available checks and ’s current prices and turnaround times are available in the Overseas Criminal Record Check information pack.
If you would like OnlineDisclosures to organise your check, download your country-specific application form.
Submitting your overseas criminal record report
In most cases the School will then receive your certificate directly from and there is nothing else that you will need to do but some countries will send the certificate directly to you, in which case we will contact you to view it.
If you receive your report email it to [email protected], quoting your student ID number in the email. If the report is not in English then it must be accompanied by an official translation into English.
If you applied through First Advantage OnlineDisclosures, the registration team will advise you on how to pay for your check.
26. What if I have a previous conviction?
Where it is revealed that an applicant has a criminal record a DBS Panel will be convened to decide whether the nature of the criminal record is such that the individual should not be offered the place on the programme, or may not be able to offer certain placement opportunities as appropriate.
The School actively promotes equality of opportunity for all with the right mix of talent, skills and potential, and welcomes applications to work or study at the School from a wide range of candidates, including those with criminal records. This means that having a criminal record will not necessarily prevent an individual from studying at the School. This will depend on the nature of the programme of study, the outcome of any DBS check, and the circumstances and background of the offences.
The School is committed to the fair treatment of its students and applicants, and no individual will be unjustifiably discriminated against on the basis of gender, race, nationality, ethnic or national origin, religious or political beliefs, disability, marital status, family circumstance, sexual orientation, spent criminal convictions, age or for any other reason.
27. How will the DBS panel consider my conviction?
When considering a criminal conviction, the DBS Panel will take into account factors such as; the nature of the offence(s), the time that has passed since the offence was committed and any additional information provided by other sources, such as the Probation Service, Social Services or senior prison officers, in the form of independent references or reports, as well as the potential impact on fellow students, staff and others with whom the student will have contact. Based on this information the Panel will determine whether any actions or adjustments may need to be taken as a result of the disclosure.
Please be assured any information received in connection to the investigation of a criminal conviction is treated in the strictest confidence and you can contact [email protected] in the first instance to make an appointment to discuss the matter in confidence.
28. Who sits on the DBS panel and what decisions can the DBS panel make?
The DBS panel comprises of:
- The Academic Registrar and Director of Academic Services (Chair)
- The Head of Student Experience (or their nominated deputy)
- The relevant Programme Leader and/or Admissions Tutor
- The Placements Officer
In the most serious cases, actions and adjustments that the Panel might take as a result include:
- Requiring suspension pending further clarification;
- Exclusion from the programme (if on the barred list and activity with children or vulnerable adults is a compulsory component of the programme);
- Require alternative placement arrangements or additional measures put in place.
Failure to disclose information to the School that jeopardises the functioning of a placement opportunity or brings into disrepute the School’s reputation with a placement provider may be pursued via the School’s Student Code of Conduct and could lead to exclusion. Please refer to Central Student Code of Conduct for more information.
Please remember: it is a criminal offence for a barred individual to undertake regulated activity.
Where a student or applicant fails to reveal information that is directly relevant to the programme or
placement sought, this could lead to withdrawal of an offer or exclusion from study at the School.
29. If I have a conviction where can I access external support?
If you would like further advice about disclosing your criminal record to a university, please contact NARCO Resettlement Advice Service. NARCO is a charity and a champion of social justice, providing advice, support and information for people with a criminal record on university entry.
You can call them on: 0300 123 1999, email at [email protected] or visit their Applying to University guidance webpage.
30. Relationship with placement providers/hosts
This Policy has been devised to be compliant with all necessary legislation. Placement Providers must inform the School when agreeing to be a placement provider if they are unable to accept students with any or a type of disclosure(s). The School will then use this information to manage a student’s placement learning, ensuring that they are not placed with a provider that would be uncomfortable with their presence.
However the School does NOT routinely provide information to providers on whether a student has a disclosure or the nature of that disclosure and would only do so with the explicit written consent of the student. The responsibility for DBS checking rests with the School. Further information on disclosure may be found in section 124 of the 1997 Police Act.
Providers that are unable to accept students on the basis of the School’s own decision making process should consider whether they should be a placement provider to the School, or they must make it explicitly clear that they wish students to provide a copy of the enhanced disclosure to them in order to approve their presence on a placement in advance of the commencement of the placement.
Providers who would use information additional to the DBS check, to which the School would not have access, to determine acceptability of a person for placement should discuss this with the School in advance of becoming a placement provider. Such institutions if hosting a placement may have security and criminal records checks in addition to the DBS enhanced disclosure. Students wishing to attend secure facilities such as prisons or young offenders institutions must discuss with their tutors in advance if they believe the additional checks will reveal further information not disclosed through the enhanced DBS check.
Failure to disclose information in advance of the placement may be pursued by the School through the student code of conduct.
The School has identified its legal obligation as its lawful right to process information about students’ criminal convictions.
The School undertakes to handle disclosure and other information regarding criminal records in
accordance with the DBS code of practice and its own Data Protection Policy.
- Disclosure information is stored electronically and in accordance with section 124 of the Police Act 1997 access is strictly controlled and limited to those who are entitled to see it as part of their duties. This is the Academic Registrar and Director of Academic Services, Head of Student Experience and Placements Officer.
- The School maintains a record of all those to whom Disclosures or Disclosure information has been revealed however, it is a criminal offence to pass this information to anyone who is not entitled to receive it and 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.
- Once a recruitment (or other relevant) decision has been made, the School will keep a record of the date of issue of a Disclosure, the name of the subject, the type of Disclosure requested, the unique reference number of the Disclosure and the details of the recruitment/registration decision taken until after the relevant exam board (i.e. once the student has completed their studies).
- Throughout this time, the usual conditions regarding the safe storage and strictly controlled access will prevail.
- Once the retention period has elapsed, the School will ensure that any Disclosure information is immediately destroyed by secure means, i.e. electronic data will be permanently deleted from the Schools IT network.
- The School will not keep any photocopy or other image of the Disclosure or any copy or representation of the contents of a Disclosure.
Further information can be found in the School’s student privacy notice and in its Data Protection Policy.
Privacy Policy of First Advantage OnlineDisclosures
The General Data Protection Regulation (GDPR) came into force on 25 May 2018. These new data
protection regulations replace the previous Data Protection Act 1998 (DPA) and set guidelines for the
processing and collection of personal information.
The DBS processes personal information in order to fulfil its day-to-day duties. It does this in line with
GDPR. When handling your data the DBS will:
- make sure you know why we need this information
- only ask for information that we need
- ensure only those appropriate have access to it
- store your information securely
- inform you if the information will be shared with a third party
- ask you to agree to us sharing your information where you have a choice
- only keep your information for as long as we need to
The DBS has added a new page to their website, called ‘Your data and how we use it’ which covers why they need your personal data, what they will do with it, and what you can expect from them. We strongly encourage all students to make themselves familiar with the information on this page.