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1.4.7 Safer Recruitment Model Policy and Procedures (produced by the Hillingdon Safeguarding Children Partnership Board)

Please also see Guidance for safer working practice for those working with children and young people in education settings (May 2019)


In April 2016 a link was added (above) to Guidance for safer working practice for those working with children and young people in education settings May 2019 (Safer Recruitment Consortium).



Caption: Contents table
Part One
1. Introduction
2. Purpose
3. Guidance for Managers who Recruit to Safeguarding Roles
Part Two - The Policy and Procedure
4. Scope
5. Defining the Role
6. Advertising the Vacancy
7. Application Form
8. Selection Process
  8.1 Shortlisting
  8.2 Self Disclosures
  8.3 Interviews
  8.4 Other Possible Interviews
  8.5 Tests/Presentations
  8.6 Document Inspection
  8.7 Interview Panel Decision Form
9. Recruitment of Ex-offenders
10. Offer and New Starter Process
11. Vetting and Barring Scheme
12. Portability of DBS Checks
13. References
14. Medical Checks
15. Temporary Staff Provided by Recruitment Agency
16. Overseas Candidates
17. Risk Assessments - Starting Staff Before Full Checks are Complete
18. Withdrawing the Offer
19. Induction Process
20. Monitoring/Audit Systems
21. Probation/Monitoring New Starter Performance and Conduct
22. Code of Conduct
23. Whistleblowing and Complaints Procedure
24. Managing Allegations
25. Professional/Regulatory Bodies
26. Single Central Records
27. Information for Potential Employees
Part Three
28 Partnership Endorsement
  Appendix 1 - Summary and Checklist
  Appendix 2a - Application Form
  Appendix 2b - Recruitment Monitoring Form
  Appendix 2c- Application Guidance Notes
  Appendix 3 - Shortlisting Form
  Appendix 4 - Self Disclosure Form
  Appendix 5 - Document Inspection Form
  Appendix 6 - Interview Panel Decision
  Appendix 7 - Personal File Checklist
  Appendix 8i -Employer Reference Request Form
  Appendix 8ii -Employer Reference Sensitive Posts
  Appendix 8iii - Character Request
  Appendix 9 - Risk Assessment Forms
  Appendix 10 - Probation Report
  Appendix 11 - Code of Conduct for Council Employees

1. Introduction

Caption: Introduction

An Introduction to the Safer Recruitment model policy and procedures

  1.1 This policy provides guidance for all managers in all agencies involved in the recruitment of staff and/or volunteers to work with children and/or vulnerable adults to ensure they meet their obligations under safeguarding and attain a safer, more robust recruitment process.
  1.2 Safeguarding seeks to ensure that the most exposed groups; children, young people and vulnerable adults are protected. The aim of Safeguarding is to ensure people live free from harm, abuse and neglect and in doing so this protects their health, wellbeing and human rights.

As the Bichard Inquiry Report into the deaths of Holly Wells and Jessica Chapman points out;

'...for those agencies whose job it is to protect children and vulnerable people, the harsh reality is that if a sufficiently devious person is determined to seek out opportunities to work their evil, no one can guarantee that they will be stopped. Our task is to make is as difficult as possible for them to succeed...' [1]

  1.4 It is therefore vital that managers understand there is a risk that abuse could happen in their organisation and there is a need for a culture of openness, transparency and vigilance to be created. Additionally, those who raise concerns should be left in no doubt that support in raising concerns will be offered and the commitment to take action is assured.

[1] Bichard Inquiry report, 2004 p12 para 79

2. Purpose

2.1 Everyone has a responsibility to be aware of safeguarding issues and this policy aims to proactively safeguard and promote the welfare of children, young people and vulnerable adults so that the need for action to protect children from harm is reduced2.

Safeguarding is defined as :

  • Agencies working with children, young people and vulnerable adults taking all reasonable measures to ensure that the risks of harm to the individual's welfare are minimised; and where concerns arise all agencies take all of the appropriate actions to address those concerns by working to agreed local policies and procedures and working in partnership with other local agencies.
2.3 This model policy and procedures seeks to embed safer recruitment practices throughout the borough's organisations and ensure managers, employees and candidates for employment are aware of the minimum standards used for recruiting and selecting staff.

This will create a safer 'Offender-aware' culture by reinforcing the issues of safeguarding children, young people and vulnerable groups and:

  • Increasing the awareness of Safeguarding issues;
  • Highlighting the policies and procedures in place to Safeguard;
  • Taking concerns seriously and providing a method of reporting concerns;
  • Where to get information from;
  • Act as a deterrent to offenders.
2.5 This policy reinforces the Code of Conduct and Whistleblowing policies which all employees are expected to be familiar with. All successful candidates for paid or volunteer employment will be made aware of these policies when their placement commences.
2.6 It is important that we provide staff and volunteers with opportunities to reflect on practice and to feel able to self-report and challenge others- working towards staff thinking 'what if I'm right?' rather than 'what if I'm wrong?'
2.7 This policy provides the minimum standards organisations must adopt for posts that involve working with children, young people and/or vulnerable adults. Throughout this policy there are links designed to make it easier for you to find the detailed guidance you require. For Partner organisation the links will tie into the appendices, where sample templates should be used.

2 (Working together to safeguard children; HM Government, April 2010) (now archived)

3. Guidance for Managers who Recruit to Safeguarding Roles

3.1 This document provides the minimum standards for recruitment that managers must adopt to ensure that candidates for both paid and unpaid (i.e. volunteer) employment are the right people, and that they are suitably checked to ensure the risks for employing them to work with vulnerable groups is limited. This policy also provides standard templates, guidance, step by step guides and clear procedures for reporting allegations to make it easy and consistent to use.
3.2 Managers must not allow staff to commence working unsupervised in a safeguarding role until the necessary background checks are completed. As set out at paragraph 17 of this policy; should managers wish to start an employee in a limited capacity before full checks are completed a risk assessment as described in this paragraph must be carried out, before that decision can be made.
3.3 This is a policy that has been endorsed by the London Borough of Hillingdon and its partner organisations at the highest levels, and it is vital the procedures are followed to protect those in the Borough from harm. If managers are unsure of how to use this policy, or if further advice and guidance is required on the recruitment and selection of staff they should contact their HR/Personnel department.
3.4 Managers should also be aware that in addition to penalties such as fines of up to £5000, monitoring and auditing will also take place to ensure compliance with procedures. It is therefore vital managers comply with the Safer Recruitment policy. Organisations in the voluntary sector that do not have access to an HR department can access advice and guidance from the Hillingdon Association of Voluntary Services (HAVS) on 01895 442722.
3.5 This policy provides the minimum standards organisations must adopt for posts that involve working with children, young people and/or vulnerable adults. A summary and recruitment checklist is set out at Appendix 1 - Summery and Checklist.
3.6 Throughout this policy there are on line links designed to make it easier for you to find the detailed guidance you require. For partner organisation the links will tie into the appendices, where sample templates are set out for your use.

4. Scope

4.1 This policy applies to all successful candidates for employment and employees of the Council, and partner agencies that operate within the London Borough of Hillingdon, specifically those who work with children, young people and /or vulnerable adults. This policy seeks to promote the rigorous processes and procedures the council and its partner agencies use to recruit and select employees and actively discourage anyone who considers Hillingdon to be vulnerable.
4.2 'Children' are defined as those under the age of 18, and 'vulnerable adults' are broadly defined as " as people over the age of 18 years with a mental or physical disability who are unable to take action themselves to safeguard their own well being, rights and other interests, and are at risk of significant harm or exploitation".
4.3 This policy does not apply to staff based in schools, who have their own recruitment policy; 'Safer Recruitment & Selection policy and procedure for support staff and Teachers other than Head teachers and Deputy Head teachers'.

5. Defining the Role

5.1 The recruiting manager has the responsibility to ensure each job is accurately and realistically defined every time a post goes out to advert.
5.2 The criteria for short listing and interviewing will be based on the job description, person specification and competencies. It is therefore vital these documents are meticulous.
5.3 Managers must be clear whether a Disclosure and Barring Service (DBS) check is required for a particular post and at what level. A list of categories that represent the professions, offices, employments, work and occupations that are known as the exceptions to the Rehabilitation of Offenders Act 1974 are available by clicking here: DBS website.
5.4 If you are unsure whether a post requires a DBS check you must check with your HR department in the first instance. Voluntary sector organisations can contact HAVS. Further advice can also be obtained by emailing providing as much detail about the post as possible.

6. Advertising the Vacancy

6.1 Adverts must include the level of DBS disclosure that is required for the post. This will help candidates make informed decisions on whether they wish to apply for a post.
6.2 The application pack must also contain a statement of safeguarding.

7. Application Form

7.1 Application forms must be used, in preference to CV's (Curriculum Vitae). CV's only contain information applicants want you to know, which may exclude other relevant information. Application packs must contain guidance stating this, and instructions on how to complete the application form. This ensures that the data being supplied is consistent and information the organisation requires. It also makes discrepancies or anomalies easier to spot. (see Appendix 2a - Application Form: Specimen application form used by the London Borough of Hillingdon as at December 2008 ).

Application forms must require as a minimum the following information:

  • Personal details and National Insurance number;
  • Relevant academic/professional/vocational qualifications, date and awarding body;
  • Full chronological history of full or part time employment since leaving secondary school, including:
    • Voluntary work, education and training;
    • Reasons for leaving jobs;
    • Any gaps which must be clearly accounted for;
  • Two referees, one of which must be the current or most recent line manager.
7.3 The Rehabilitation of Offenders Act 1974 does not apply to posts which involve working with, or to have access to children, young people and/or vulnerable adults or their records. Therefore any convictions, cautions, bind-overs that would normally be considered 'spent' must be declared when applying for this type of post.
7.4 Applicants with professional qualifications and registration to regulatory bodies must provide details of registration; this should be verified by the said body, such as the GMC or HCPC.

8. Selection Process

Caption: Section 8



  8.1.1 Managers must short list having regard to the extent to which candidates meet the person specification and competencies that were available with the job details.
  8.1.2 To create the shortlist the interviewing panel must score each applicant against the person specification for the job using a short listing form see specimen at Appendix 3 - Shortlisting Form.
  8.1.3 Managers must scrutinise applications, identify any inconsistencies and be cautious about missing or vague information. At the interview, managers must take the opportunity to investigate gaps in the employment history and/or any disclosures of criminal history. These questions are not scored, but answers need to be considered as they may have a bearing on the appointment.

The Recruiting manager must give consideration to:

  • The interview panel; which must consist of at least two people who are directly employed by the organisation and at least one of whom has received the minimum level of safeguarding training, as identified by the relevant safeguarding board, and are aware of the safeguarding agenda;
  • The assessment criteria and method of assessment (including presentations) which must be considered based on the requirements of the person specification;
  • The content and number of questions, the evidence looked for in the answer, who will ask each question and what weighting (if any) will need to be decided;
  • The pass mark required, (as decided by the interviewing panel);
  • The timescale for making a decision and who will give feedback to the candidates at the end of the process;
  • Whether candidates could visit the working environment as part of the process. This can assist candidates in understanding the working context and environment. During any visit all candidates must be afforded the same opportunities.


Self Disclosure

  8.2.1 Interview invitation letters must include a self-disclosure, (Appendix 4 - Self Disclosure) form. These give candidates an opportunity to share relevant information at an early stage, and allow information to be discussed and considered before any DBS checks come back. This is also a method of deterring unsuitable candidates.
  8.2.2 Offences that are declared must be individually explored. The contents of self-disclosure forms must not be used to shortlist unless it is obvious an offence will have an effect on the candidate's ability to carry out the role. If a candidate who declares a self-disclosure is successful the recruitment process can be continued if appropriate and comparisons made with the DBS check once received.




There are a number of processes that the interview must follow, these are:

  • Introductions;
  • Information gathering; The interview questions and responses recorded;
  • Information giving Candidates have the opportunity to ask questions and find out about the job and their prospective employer. Probe gaps/frequent changes in employment/vagueness/areas of concern.
  • Close;
    • Explain the next stage in the process, i.e. informing the candidate of the outcome and when;
    • Ensure identification and qualifications have been verified as original documents and that they are bona fide using the document inspection form (Specimen at Appendix 5 - Document Inspection Form), and take photocopies;
    • Confirm the process for taking up references, obtaining medical clearance and Disclosure and Barring Service (DBS) checks, where appropriate. Managers must make it clear any offer of employment to a candidate would be subject to these being satisfactory.


Other Possible Interviews

  8.4.1 Personal (Warner) interviews are increasingly being used, alongside the formal interview process, in residential social care settings.
  8.4.2 Personal interviews ask questions that probe candidates about their personal life, attitudes and motivations, in order to establish a fuller picture of the character of the applicant, and their suitability to work with the client group. Questions may, for example focus around attitudes to control and punishment of children and the stability of the candidates' emotional and sexual relationships.
  8.4.3 The questions are asked at a post-interview session on a one to one basis with the interviewer and the candidate. An additional person should also be present, so that candidates' responses can be fully recorded.
  8.4.4 Careful training in the use of appropriate questions and techniques used during the interview is essential, and so this type of interviewing would not be considered part of the "minimum standards" applied in safe recruiting.



  8.5.1 Where ever appropriate, the recruitment and selection process should not just consist of an interview. A variety of selection and/or presentation processes can be adopted providing qualified examiners are used when required
  8.5.2 Other more basic testing of skills can be devised by Managers and can prove a very useful tool as long as they relate to the person specification.
  8.5.3 Advice must always be sought from HR regarding the use of tests.


Document Inspection

  8.6.1 For every candidate interviewed, managers should complete a document inspection form (Specimen at Appendix 5 - Document Inspection Form). The form ensures compliance with Asylum and Immigration legislation to ensure a candidates eligibility to work, and also provides sufficient information for a DBS check to be completed. At least 3 documents must be inspected for the DBS form.
  8.6.2 When completing the form, managers need to ensure original documents are inspected.


Interview Panel Decision Form

  8.7.1 The interview should be scored using an interview score sheet (Specimen at Appendix 6 - Interview Panel Decision). Score sheets must be retained for a minimum of six months after the interview date.

9. Recruitment of Ex-offenders

9.1 The Council and its partners promote equality for all and welcome applications from a diverse selection of candidates. Criminal records will be taken into account for recruitment purposes only when the conviction is relevant. Having an 'unspent' conviction will not necessarily be a bar to employment. This will depend on the circumstances and background to the applicant's offence(s).
9.2 Candidates are required to complete self-disclosures (Specimen at Appendix 4 - Self Disclosure Form). For further information click: Recruitment of ex-offenders.

10. Offer and New Starter Process

Caption: Section 10
10.1 The appointment of all new starters is subject to the receipt of satisfactory DBS, references and medical checks where appropriate. The Personal file Checklist (Specimen at Appendix 7 - Personal File Checklist) must be used to track and confirm checks are obtained. Checklists must be retained on file.


Disclosure and Barring Service (DBS) checks

  10.2.1 DBS checks must be carried out on positions that involve regular contact with children, young people or vulnerable adults/vulnerable groups.
  10.2.2 It is not acceptable to carry out DBS checks on candidates applying for posts which do not require that level of background check.
  10.2.3 Managers must ensure when completing 'Section X' of the DBS form (Evidence of identity seen by the employer/volunteering organisation/registered body) that original documents are provided and photocopies retained for the personal file. Using the Document inspection form (Specimen at Appendix 5 - Document Inspection Form) will ensure relevant and sufficient documents are inspected and enough evidence of identity for the DBS are provided. Further guidance on acceptable documentation is available on the DBS website.
  10.2.4 Currently DBS checks must only be submitted for the candidate selected for appointment. DBS checks that are undertaken by other organisations should not be used (portability - see paragraph 12).
  10.2.5 DBS checks must be validated at least every three years. Employees must be made aware of their obligation to inform their manager of any cautions or convictions that arise between these checks taking place.


Dealing with convictions


If a DBS is returned with details of convictions HR advice must be sought. Consideration will be given to the Rehabilitation of Offenders Act and also:

  • The nature, seriousness and relevance of the offence;
  • How long ago the offence occurred;
  • One-off or history of offences;
  • Circumstances surrounding the offence;
  • Changes in circumstances;
  • Country in which the offence occurred;
  • Decriminalisation and remorse.


Retaining information provided by the DBS

  10.4.1 The DBS advice 'Disclosure documents' must be destroyed six months after they are no longer needed. The information recorded must be:

Record of receipt Information on decisions made Reference number Date of issue Standard or Enhanced check

Caption: Section 10 part 2
  10.4.2 Information must be readily available for inspectors, to ensure the correct recruitment procedures are being followed. For further information your HR or DBS Disclosure unit should be contacted.
  10.4.3 Details of discussions with staff about criminal or other declarations must be retained on personal files.

11. Vetting and Barring Scheme

11.1 From October 2009, every employee and candidate recruited to work with children, young people or vulnerable adults will have their Disclosure and Barring Service (DBS) status checked. This will determine whether or not they can be employed or be taken on as a volunteer, and may affect what activities they can undertake. These checks will take place in the same way as DBS checks, and at present no additional forms are envisaged.
11.2 Employers will also be required to carry out an online check that a prospective employee is a member of the scheme and hence not barred and therefore able to work with children, young people and/or vulnerable adults

The scheme will be based on two barred lists:

  • People barred from working with children and/or young people;
  • People barred from working with vulnerable adults.
11.4 Individuals will be barred either automatically if they are convicted or cautioned for certain offences or following a decision by the DBS.
11.5 Further information is available from the Disclosure and Barring Service (GOV.UK) website.

12. Portability of DBS Checks

12.1 Portability should not be used by organisations. The DBS no longer facilitates portability and organisations that choose to accept a previously issued Disclosure do so at their own risk. Further guidance on Portability is available from the DBS website.
12.2 For clarity - portability refers to the re-use of a DBS check (Disclosure), obtained for a position in one organisation and later used for another position in another organisation.

13. References

Caption: Section 13
13.1 When the offer of appointment is made, references must be sought. In situations where the applicant has limited work experience, e.g. a school leaver, a Character Reference Request may be sought. A minimum of two satisfactory references are required, these must be obtained directly by the organisation. At least one reference must be from the candidates' current or most recent employer.

References provide factual information to support appointment decisions, requests must include information on

  • The candidate's suitability for the post;
  • The qualities and experience the candidate(s) have;
  • Details of any disciplinary offences against children or if there have been any child protection concerns (if the post involves working with vulnerable groups) and their outcomes;
  • Reason for leaving;
  • The referee's relationship to the candidate;
  • Whether the referee is satisfied that the candidate is suitable to work with children, and if not the referees concerns and why they think the candidate is not suitable.
13.3 Open references or testimonials provided by the candidate, i.e. "to whom it may concern" must not be accepted. Open references/ testimonials may be forged or the result of a "compromise agreement".

Specimen reference requests as used in London Borough of Hillingdon can be found at Appendix 8i -Employer Reference Request Form, Appendix 8ii -Employer Reference Sensitive Posts and Appendix 8iii - Character Request.


Receipt of references

  13.5.1 On receipt, references must be scrupulously checked to ensure all questions have been answered satisfactorily. References must be checked against application forms to verify dates of employment. Managers are advised to read between the lines and verify the authenticity of the referee and if the content is ambiguous or unguarded, seek expansion by telephone. Where further information is required the manager may choose to telephone referees to confirm their views on the candidate and to ensure the information provided is accurate. Details of any contact with referees must also be kept i.e. telephone calls.
  13.5.2 Where a cause for concern arises managers must contact HR for further advice.
  13.5.3 Any information about past disciplinary action or allegations must be considered in the circumstances of the individual case. Cases in which an issue was satisfactorily resolved some time ago or an allegation determined to be unfounded or did not require formal disciplinary sanctions, and in which no further issues have been raised, are less likely to cause concern than more serious or recent concerns, or issues that were not resolved satisfactorily. A history of repeated concerns or allegations over time should give cause for concern.
  13.5.4 The recruiting manager will need to ensure references are signed by the author.

14. Medical Checks

14.1 Organisations may require new employees to complete medical questionnaires and/or undergo a medical assessment for new employees. The purpose is to confirm a candidate's suitability and ability to undertake the role they are to be appointed to.
14.2 Any information supplied by the medical unit must be acknowledged and acted upon before any offer of employment is confirmed.

15. Temporary Staff Provided by Recruitment Agency

15.1 Organisations that use temporary staff provided by a recruitment agency must still be satisfied that the prospective worker has undergone the necessary reference and criminal record checks.
15.2 If there is a contract in place with a specific recruitment agency then it is possible to insert a requirement that the agency fully vets all staff before they are put forward for an assignment into that contractual agreement.
15.3 Alternatively if that contractual assurance is not in place organisations should ensure that they carry out reference checks and DBS checks on temporary staff in the same way as they do on permanent staff.

16. Overseas Candidates

Caption: Section 16
16.1 Candidates are required to ensure they are eligible to work in the UK. Organisations may choose to pay for work permits if appropriate (i.e. hard to fill posts).
16.2 The DBS are able to provide an 'Overseas information service' which will provide employers with details of the information that applicants may be able to obtain form their country of origin.
16.3 With references special efforts need to be taken to ensure sources are reliable, employment history is break-free or explained, and supplementary references must be obtained in order to produce a proper historical work/training history.
16.4 Wherever possible additional checks must be undertaken to verify a candidate's background. Professional bodies such as the Health and Care Professions Council (HCPC) have separate registration processes for overseas workers.
  16.4.1 The Recruiting Manager must take care to ensure sufficient breadth and depth of information is available to make a safe decision.

17. Risk Assessments - Starting Staff Before Full Checks are Complete

17.1 Where there are gaps in information, concerns or matters of judgement, the Recruiting Manager will undertake a risk assessment (Specimen at Appendix 9 - Risk Assessment Forms) to determine whether the appointment should proceed or the offer is withdrawn. Consideration will need to be given to the information available and whether further information/advice is required, whether the safety risk is small or can be mitigated by temporary work restrictions. Advice from HR must be sought on potential employment rights matters (for example; where a temporary contract may be considered).
17.2 The Recruiting Manager will be held accountable for this decision and must 'sign off' the documentation to clear the appointment for processing. Where concerns arise these need to be discussed with HR before any appointment is confirmed.

18. Withdrawing the Offer

18.1 Once an offer of employment has been made it can be rescinded providing the checks outlined in any offer letter are not satisfactory. This is superseded by any legal requirements such as the right to work. It is recommended you contact your HR department before any offer of employment is withdrawn.
18.2 Where it is appropriate, any concerns must be reported to the designated Local Authority Designated Officer (LADO), in accordance with the Whistleblowing policy.

19. Induction Process

19.1 The introduction of a new member of staff to the organisation begins at the recruitment stage, when messages about being a 'Safe Organisation' are first given. This must be continued through the selection process and when the new person starts work as part of induction.
19.2 Staff need to feel confident that they can raise issues or concerns about the safety or welfare of children, young people and/or vulnerable adults, and that they will be listened to and be taken seriously. That can be achieved by maintaining an ethos of safeguarding and promoting the welfare of children, young people and vulnerable adults.

All new staff, regardless of previous experience should have an induction. The induction process should:

  • Provide training and information about policies and procedures;
  • Support individuals in a way that is appropriate for the role for which they have been engaged;
  • Confirm the conduct of staff and standards of behaviour the organisation expects and the methods in which issues can be reported;
  • Provide opportunities for a new member of staff or volunteer to discuss any issues or concerns about their role or responsibilities; and
  • Enable the person's line manager or mentor to recognise any concerns or issues about the person's ability or suitability at the outset and address them immediately.
  • Information about, and written statements of:
    • Policies and procedures in relation to safeguarding and promoting welfare e.g. child protection, anti-bullying, antiracism, physical intervention or restraint, intimate care, internet safety and any local child protection/or and safeguarding vulnerable adults procedures;
    • Safe practice and the standards of conduct and behaviour expected of staff and how and with whom any concerns about those issues should be raised; and other relevant personnel procedures e.g. disciplinary, capability and whistleblowing.
19.4 Individual supervision, one to one sessions between manager and employee, and appraisal sessions should be diarised.

20. Monitoring/Audit Systems


Organisations must ensure monitoring systems and quality assurance are embedded to ensure that policies are followed through into practice. This will be done in the following ways:

  1. Formal audits of sufficient quality and quantity conducted regularly, allowing ample time for improvements to be made post audit, with results recorded and reported effectively;
  2. Managers monitor the day to day work environment;
  3. Employees demonstrate their commitment to providing a protective environment for children, young people and vulnerable adults. For example, they monitor the supervision of children, young people and vulnerable adults and demonstrate good practice in relation to physical contact with children and vulnerable groups; there are clear, appropriate and rigorously enforced policies and procedures in place concerning the transportation of children, young people and vulnerable adults, ensuring that safeguarding principles are strictly adhered to;
  4. Service providers who supply drivers for the transportation of these client groups are under contractual obligation to provide drivers and escorts that are appropriately vetted; e.g. DBS checked;
  5. Guidance on safe working practices is provided for each member of staff and includes clarity in relation to such areas as:
    1. Non-routine events, such as school trips;
    2. Child injury/illness;
    3. Internet use;
    4. The use, supervision and handling of text and photographic media.
20.2 The standard of recruitment will be audited by external regulators where appropriate, and also independent multi-agency audits commissioned regularly.

21. Probation/Monitoring New Starter Performance and Conduct

21.1 All new staff (either paid or volunteer) or staff who change posts in an organisation should be closely monitored and there should clear and timely performance management measures in place.
21.2 Where formal employment terms and conditions allow, a new starter should be subject to a probationary period. The probationary process ensures that following an appointment, employees are given the necessary support and guidance to enable them to reach the required standard by the end of the probationary period.
21.3 The probationary period can also ensure a successful induction of employees into their new role. Managers are responsible for monitoring their employee's conduct and performance closely and agreeing a strategy to overcome any shortcomings in a formalised setting, if appropriate.
21.4 Organisations need to ensure they where they have a probationary policy that this provides a process for dealing with employees who are unsuccessful in their probationary period.
21.5 Probationary periods can usually extend up to a maximum of one year, with employment not normally being confirmed until the end of the probation period Appendix 10 - Probation Report provides examples of a probationary report that could be used by organisations.

22. Code of Conduct

22.1 The Council and partner organisations are committed to the highest standards of honesty and accountability. The Code of Conduct (see Appendix 11 - Code of Conduct for Council Employees) provides the values and framework within which local government employees are required to work and summarises what is expected of employees during their employment. This is in accordance with the Model Code of Conduct issued by the then Officer of the Deputy Prime Minister (ODPM).
22.2 In many cases the Code is based on legal obligations, contract of employment, standing orders and financial regulations. Other codes of conduct and rules are produced by professional and technical bodies, and when not in conflict with the organisations rules, they must be followed.
22.3 It must be a condition of employment that employees read, understand and adhere to their organisations code of conduct. Failure to adhere should lead to action in line with the disciplinary policy and may in some cases lead to legal action.
22.4 Codes of conduct cannot cover every eventuality and are neither an exclusive nor exhaustive list of acceptable conduct at work. If employees are unsure whether particular conduct or behaviour is acceptable at work, they must seek guidance from their manager.

23. Whistleblowing and Complaints Procedure

23.1 Candidates and employees may at one time or another have concerns about what is happening at work. Usually these concerns are easily resolved. However, when they are about unlawful conduct, financial malpractice, health and safety risks to the public or to other employees, damage to the environment, possible fraud or corruption, sexual or physical abuse of clients, or any other unethical conduct, it can be difficult to know what to do.
23.2 Employees should feel confident about raising serious concerns by providing clear avenues through which concerns can be raised, and reassuring those who raise concerns that they will not be victimised.
23.3 Those who raise concerns will receive a response and be informed about how their concerns are being dealt with. As an example the LBH Whistleblowing Procedure can found be at the Hillingdon website.

24. Managing Allegations

24.1 Despite best efforts to recruit safely there will be occasions when allegations of abuse against children, young people and vulnerable adults are raised. In cases relating to children instances the London Safeguarding Children Procedures, Allegations against Staff or Volunteers, who Work with Children Procedure will be applied to situations where allegations of this nature are made.

These procedures should be applied when there is an allegation or concern that any person who works with children, young people and/or vulnerable adults, in connection with their employment or voluntary activity has:

  • Behaved in a way that has harmed a child or vulnerable adult;
  • Possibly committed a criminal offence against or related to a child;
  • Behaved towards a child or children in a way that indicates that they are unsuitable to work with children and or vulnerable adults.
24.3 These behaviours should be considered within the context of the 4 categories of abuse (i.e. physical, sexual and emotional abuse and neglect). These include concerns relating to inappropriate relationships between members of staff and children or young people, and also include allegations made against staff in their private lives. (All references in this document to members of staff should be interpreted as meaning "all paid or unpaid staff ").

Each partner agency within the Hillingdon Safeguarding Children Board is to identify a named senior officer with overall responsibility for :

  • Ensuring that the organisation deals with allegations in accordance with the All London Safeguarding Children Procedures;
  • Resolving any inter agency issues;
  • Liaising with the Hillingdon Safeguarding Children Board about these matters.

In accordance with the procedures, the Local Authority in Hillingdon has designated an officer (currently the Service Manager of Safeguarding Children and Quality Assurance) to:

  • Be involved in the management and oversight of individual cases;
  • Provide advice and guidance to employers and voluntary organisations;
  • Liaise with the police and other agencies;
  • Monitor the progress of cases to ensure we have dealt with this as quickly as possible consistent with the thorough and fair process.

A local authority designated officer (LADO) has also been appointed for schools to help manage the process of to help manage allegations of abuse against staff and teachers within the school setting.

24.7 In all cases where there is an allegation against an adult working within the children's workforce, a complex strategy meeting will be convened.
24.8 This meeting will be chaired by an independent reviewing officer (IRO) who will ensure that the appropriate investigations are carried out whether via the criminal processes or through internal disciplinary procedures; or through a child protection enquiry. (Section 47, Children Act 1989).
24.9 The independent reviewing officer will be responsible for ensuring that the outcomes of these allegations are properly recorded and that due consideration is given to whether a referral needs to be made to the Disclosure and Barring Service (DBS) in terms of suitability to continue working with children or vulnerable adults.
24.10 It may also be necessary to refer the matter to the relevant professional body of the individual. A decision to do so will be made based on the merits of the case. If the professional body is to be advised of an allegation then the individual must be made aware of that action before doing so.

A regular quarterly report will be made to the Hillingdon Safeguarding Children Board to highlight the numbers of allegations that have been completed in relation to those adults who work with children from each of the Partner Agencies. Information will be recorded and kept centrally within the Safeguarding Children and Quality Assurance Service, in the Local Authority in accordance with Data Protection Act 1998.


The following documents should be consulted in relation to the Management of Allegations against staff who work with Children and Vulnerable Adults:

  1. The London Safeguarding Children Procedures Third Edition 2007 (Chapter 15);
  2. Safeguarding children and safer recruitment in education (DFES 2006);
  3. Working Together to Safeguard Children 2010 (now archived).

All these documents are available on the Hillingdon Safeguarding website.

25. Professional/Regulatory Bodies

25.1 Candidates, employees and volunteers are expected to co-operate with Professional/regulatory bodies. Where professional qualifications are required for a position, managers should ensure that copies of relevant qualifications as outlined in the person specification are retained on the employee's personal file.
25.2 Where membership of regulatory bodies is required, employees are required to ensure these are kept up to date. Where concerns arise employees have a responsibility to disclose this to their manager and discuss where appropriate, this may include adjustments to a post on a temporary basis. (See also paragraph 20.10)
25.3 If difficulties or concerns arise your HR department should be contacted.

26. Single Central Records

26.1 Records and Personal files must be easily accessible and available for inspection. Files may be kept 'off the premises', however in some circumstances prior agreement may be required.

All agencies that interact with schools must keep and maintain a paper or electronic record of the checks which have been carried out on:

  • All staff employed at the school;
  • Supply staff employed by the school;
  • Supply staff engaged through an agency (see 6. below);
  • All others who have regular contact with children at the school including:
    • Volunteers;
    • Governors who also work as volunteers;
    • Others brought into school to provide additional instruction to pupils e.g. sports coaches, artists etc.;
    • 'Contractors'.
26.3 The SCR must be complete for all persons listed above engaged at the school at 1 January 2007 and all new persons from that date on an ongoing basis - irrespective of how long they are actually at the school (i.e. you must include agency supply staff even if they only come once).
26.4 People can be removed from the SCR when they have left employment or ceased to come into school - however they must be placed back on the list if they come back.

27. Information for Potential Employees

27.1 The Council and its partner organisations will take every step possible to protect those that are most vulnerable. We expect our staff and candidates to be vigilant and understanding of the risks that children and vulnerable adults face and report anything suspicious. This can be done anonymously using a Whistleblowing or Complaints procedures provided.
27.2 We ask that those candidates who have been successful in applying for a post be patient and wherever possible assist in reducing the time taken to complete the necessary checks required for the level of the post.

All posts are subject to the receipt of references, medical checks and DBS checks where appropriate. Candidates can assist by:

  • Providing a completed application form providing details of any gaps between employment;
  • Provide full and concise information when requested to do so;
  • Chase references;
  • Return any documentation on a timely basis, (including acceptance of the Conditional offer of employment & Contract of employment);
  • Notify their HR advisor of any previous or ongoing action of allegations that are relevant to safeguarding;
  • Raise any concerns they may have in relation to safeguarding via the organisations Local Authority Designated Officer (LADO).

28. Partnership Endorsement

As the partner organisations of the Hillingdon Safeguarding Children Partnership Board / and or the Hillingdon Safeguarding Adults Partnership Board, we will promote best practice in safer recruitment throughout the organisations we represent.

We will ensure that the minimum recruitment standards, as set out in the LONDON BOROUGH OF HILLINGDON SAFER RECRUITMENT- MODEL POLICY & PROCEDURES, are met in the recruitment policies, procedures and practices in the organisations we represent.

In summary we will ensure that our recruitment process, when recruiting to any safeguarding roles, includes the use of:

  • Clear, well defined job descriptions;
  • Full and complete application forms from potential candidates;
  • "Self - disclosure" forms for the purpose of disclosing convictions early in the recruitment process;
  • Full face to face interviews, conducted by staff trained in recruitment and safeguarding awareness;
  • Fully recorded document inspections;
  • New Disclosure and Barring Service (DBS) checks on recruitment; and every subsequent three years;
  • A minimum of two checkable references, with one from the most recent employer, obtained directly by the recruiting organisation;
  • Medical checks to ensure candidate's ability to undertake the role;
  • Checks to ensure overseas candidates are eligible to work in the UK;
  • An appropriate and monitored new starter process and well defined induction;
  • A clear code of conduct which is communicated to new starters.

And that the organisations we represent, where we interact with schools:

  • Maintain a record of checks carried out on staff or volunteers who have regular contact with schools.

And that our organisation has a policy and procedure to enable:

  • Staff to raise any concerns over possible malpractice within the organisation in a safe environment without fear of victimisation;
  • Allegations of abuse against staff to be investigated appropriately and in accordance with current best practice guidance.

We will encourage staff and volunteers in our organisations to attend any training provided in relation to safe recruitment and actively promote and encourage best practice.