DBS Checks in the Financial Sector: A Guide to the Different Levels

by Sarah Thompson, business development manager at uCheck

Disclosure and Barring Service (DBS) checks play an important role in many organisations’ safeguarding policies, helping them to recruit safely and guard against unsuitable candidates attempting to enter the workforce.

The financial sector is no exception. With lots of positions carrying a high degree of responsibility, DBS checks are vital in ensuring the people entering these professions are suitable to do so.

Whether you’re responsible for obtaining DBS checks for employees in your organisation or you’re looking to work in the financial community, it’s important to understand the eligibility criteria for the different types of DBS check.

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The following guide explains everything you need to know.

Basic DBS checks

A basic DBS check is the lowest level of check available. There are no eligibility requirements for a basic DBS check, meaning that anyone can apply for one. Unlike the higher levels of DBS check, individuals can apply for this type of check for themselves.

A basic DBS check will show any unspent convictions the applicant has, and can provide an extra level of reassurance for organisations when employees aren’t eligible for higher-level checks.

The process for obtaining basic disclosures changed at the beginning of 2018. Previous to this, they were processed and issued by Disclosure Scotland. However, the DBS took over this function for people living in England and Wales in January 2018.

Scotland has different legislative criteria to England and Wales in terms of how long it takes convictions to become spent, and so the changes were put in place to address the discrepancy.

Anyone who works in England or Wales should apply for their basic check through the DBS, whilst those who work in Scotland should apply to Disclosure Scotland. If you apply through an umbrella company, the company will submit the application to the appropriate governing body based on the applicant’s location.

Standard DBS checks

A standard DBS check is likely to be the most relevant type of check for most people working in the financial community.

This type of check will show any spent or unspent convictions, cautions, reprimands or warnings the applicant has, as long as they’re not protected.

Individuals cannot apply for a standard DBS check – only employers can obtain standard checks on behalf of their employees.

To be eligible for a standard DBS check, a role must be listed in the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975. This piece of legislation includes a list of professions that require the post-holder to have a standard DBS check.

The list includes:

Chartered accountants and certified accountants: People in these roles must undergo a standard DBS check on entry into the profession.

Financial services positions: This means any position that requires approval from the Financial Conduct Authority because it involves carrying out a ‘controlled function’. Examples of controlled functions include:

  • Being a director of a regulated firm
  • Overseeing a regulated firm’s systems and controls
  • Being responsible for compliance with the FCA’s rules

Different controlled functions will apply to different companies, depending on the activities or services they provide. Having a standard DBS check is a necessary part of meeting the FCA’s regulatory requirements for those undertaking a controlled function.

For more information about which financial services roles require a standard DBS check, see the FCA’s website or contact them directly.

Enhanced DBS checks

An enhanced DBS check is the highest level of DBS check available.

This type of check will show the same information as a standard DBS check, as well as any information the applicant’s local police force holds and deems relevant.

For certain roles, an enhanced DBS check will also include a check of the children’s and/or adults’ barred list. This will show whether the applicant has been barred from working with children and/or vulnerable adults.

Like standard DBS checks, employers must apply for enhanced DBS checks on behalf of their employees. Individuals are not eligible to apply.

Any employee who engages in regulated activity with children and/or vulnerable adults will be eligible for an enhanced DBS check. As a rule of thumb, this means that any employee who has regular unsupervised contact with children and/or vulnerable adults is likely to be eligible for an enhanced check.

DBS checks in the financial sector

When determining what sort of DBS check an employee is eligible for, it’s important to consider their individual roles and responsibilities.

If an employee isn’t eligible for a standard or enhanced check, a basic DBS check can give your organisation an extra degree of confidence in them.

If you need more information, see the DBS’ eligibility guidance or contact them directly.

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