Privacy Notice
Royal Greenwich is committed to ensuring that your personal data is securely kept and processed in compliance with the relevant data protection legislation.
This section explains how the Council’s DBS application process complies with the appropriate data protection legislation and fulfils the Council’s obligations as a DBS registered body.
Lawful purpose(s) for the Council to collect your data:
Personal Information
The information which you supply to us will be used to complete your application to receive a DBS certificate, which the Council is legally permitted to do by the legislation outlined below:
Disclosure Information
The role to which you are applying has been identified as requiring a Disclosure and Barring (DBS) Check according to the following legislative criteria:
Basic checks - this is suitable for any role. This level of certificate will only show any unspent cautions and convictions according to the terms of the Rehabilitation of Offenders Act 1974.
Standard checks – To be eligible for a standard level DBS certificate, the position must be included in the Rehabilitation of Offenders Act (ROA) 1974 (Exceptions) Order 1975.
Enhanced checks – To be eligible for an enhanced level DBS certificate, the position must be included in both the ROA Exceptions Order and in the Police Act 1997 (Criminal Records) regulations.
Enhanced checks with children’s and/or adults’ barred list check(s) – To be eligible to request a check of the children’s or adults’ barred lists, the position must be eligible for an enhanced level DBS certificate as above and be specifically included in the Police Act 1997 (Criminal Records) regulations as able to check the appropriate barred list(s).
As your role is included in the above legislation the Council is legally able to request a full criminal history from the Disclosure and Barring Service (DBS) through a DBS Certificate. Please note that if any criminal records information is disclosed on the certificate this will not only include any unspent convictions or cautions but will also reveal those which might otherwise be considered ‘spent’. This is with the exception of a basic check. If your role is eligible for an enhanced check in addition to the above information regarding spent and unspent convictions, the certificate, if applicable will also include additional information requested from the relevant police forces.
Barring Information
If you are applying for a Regulated Activity Role, or a Role covered by the relevant section of the Serious Organised Crime and Police Act 2005, in addition to a standard or enhanced DBS check, the council also has a legal obligation to check you against the relevant barred lists to see whether you are held on those lists.
All the above information is gathered in accordance with the relevant legislation to ensure that it is appropriate, suitable and in the public interest to employ a candidate to a role.
The next section provides further information regarding the handling of your data.
Access and Storage:
Personal Information
Counter-Signatories in the Council will need to check your personal information to ensure that it meets the DBS’ requirements. Once your personal information has been verified by a Counter-Signatory the application form will be submitted to the DBS so that they can carry out the DBS check and produce the necessary DBS certificate. If the application is processed successfully the DBS will retain your application form.
Copies will be taken of your identity verification documents. These are kept in case there is any query from the DBS. They will be stored in a locked cabinet to which access is limited. Copies of identity documents taken solely for the purpose of your DBS application will be kept until the Disclosure Certificate has been seen, after which they will then be securely destroyed.
Disclosure Information
The DBS will only provide a Disclosure Certificate to you, the DBS applicant. You will need to bring in your certificate and present it either to the relevant officer of the Agency and Recruitment Team and/or your Manager/or the relevant school as appropriate. If any disclosure information has been revealed this will be communicated to your manager. Your manager may feel it necessary to discuss the disclosure information with a Human Resources Advisor in HR Professional Services and any other manager who has a legitimate reason to review the disclosure information. A process will be followed to review the disclosure information to reach a decision as to your offer of employment or continued employment. Please see the Council’s DBS Policy and Rehabilitation of Offenders Policy for further information.
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Usage
Any Disclosure Information which may be received is used for the purpose either of making a recruitment decision i.e. deciding whether it is appropriate to employ any worker or member of staff or to decide whether it is suitable to continue employing someone. This is done in order to ensure that the public, who the Council serves, and in particular vulnerable individuals and groups within the community, are protected at all times.
Retention
If the DBS certificate does disclose any information, once a recruitment (or other relevant) decision has been made, the disclosure information will not be kept for any longer than necessary. This is generally for a period of up to six months, to allow for the consideration and resolution of any subsequent disputes or complaints. If, in very exceptional circumstances, it is considered necessary to keep disclosure information for longer than six months, the Council will consult the DBS about this and full consideration will be given to the data protection and human rights of the individual before doing so. Throughout this time, the usual conditions regarding the safe storage and strictly controlled access will continue to apply.
Disposal
Once the retention period has elapsed, the Council will ensure that any disclosure form is immediately destroyed by secure means, i.e., by shredding. While awaiting destruction, disclosure information will not be kept in any insecure receptacle (e.g. waste bin or confidential waste sack). The Council will not keep any photocopy or other image of the disclosure or any other copy or representation of the contents of a disclosure.
The next section provides further information about the records which the Council will keep regarding disclosure information.
Record Keeping
Counter-signatories will ensure that the following information is recorded on i-Trent for monitoring and record purposes only. Schools will also record this on their single central record:
· The name of the Disclosure subject (the applicant)
· The post for which the Disclosure subject applied
· The date the Disclosure certificate was issued
· The type of Disclosure check sought (standard or enhanced)
· The unique Disclosure reference number
Access will be limited to those with a genuine need to access that data.
If it has been necessary to complete a Disclosure Review Form, a version will be kept on the employee’s personal file. The requirement to minimise the data retained will be balanced with the need of the Council to keep accurate and clear records e.g. the form retained on file will include the reason where relevant why the applicant was considered unsuitable for appointment but will not include details of any criminal history which may have been disclosed.
By signing in and continuing to use this site, you confirm that you have read and understood this statement
For further information regarding the Council’s approach to data protection please see the HR Professional Services Privacy Notice on the Council’s website or contact the Agency & Recruitment Team (dbs-admin@royalgreenwich.gov.uk)
This section explains how the DBS’s own processes comply with relevant data protection legislation:
The Disclosure and Barring Service (DBS) have also produced a number of service specific privacy policies including one for Basic/Standard/Enhanced DBS checks. These notices explain to applicants how the DBS itself will use their personal data and will also inform them of their rights under GDPR. These privacy notices can be accessed through the DBS website
Please read the below statement to confirm:
DBS Privacy Policy- Basic/Standard/Enhanced DBS check declaration
By signing in and continuing to use this site, I confirm I have read the Basic/Standard/Enhanced Check Privacy Policy produced by the DBS for applicants and I understand how the DBS will process my personal data and the options available to me for submitting an application.
External ID Checks - Terms and Conditions for End Users
When establishing the true identity of an applicant an external ID verification check may be used as an alternative to Route 1/1a. This will require us to provide an applicant’s details (as presented on the application form) to our chosen supplier Experian, who will compare the data obtained from the applicant against a range of independent, external data sources.
Please take a moment to read the Experian Terms and Conditions with regards to the core terms concerning the nature and use of the services, confidentiality, data protection, compliance and audit.
Policy on the Recruitment of Ex-Offenders
The Royal Borough of Greenwich aims to promote equality of opportunity and welcomes applications from a diverse range of candidates.
Criminal records will be taken into account for recruitment purposes only when the conviction is relevant. Unless the nature of the work demands it, applicants will not be asked to disclose convictions which are ‘spent’ under the Rehabilitation of Offenders Act 1974. Having an ‘unspent’ conviction will not necessarily bar someone from employment. This will depend on the circumstances and background to the offence(s). However, any ‘unspent’ convictions, which are not declared and subsequently revealed, may result in dismissal.
Under the Rehabilitation of Offenders Act 1974, a conviction will become ‘spent’ (i.e. treated as if it had not occurred) where the individual has not, after a specified period of time, committed another serious offence.
Rehabilitation periods vary depending on the type and length of conviction originally incurred.
The authority has a legal obligation to protect vulnerable customer and client groups from people who have committed serious offences, and as such meets the requirements in respect of exempted questions under the Rehabilitation of Offenders Act 1974. All applicants who are offered employment in a post that falls into this category will be subject to a criminal record check from the Disclosure & Barring Service (DBS), before the appointment is confirmed. This will include details of cautions, reprimands, final warnings and convictions, including ‘spent’ convictions. Where the post is subject to Enhanced Disclosure, other relevant non-conviction information, such as police enquiries and pending prosecutions will be included.
Royal Greenwich is committed to compliance with the Disclosure and Barring Service Code of Practice.