GP mythbuster 2: Disclosure and barring service (DBS) checks for primary healthcare staff

Primary healthcare services need to have procedures to make safe recruitment decisions.

This is to:

• prevent unsuitable people from working with vulnerable groups 
• safeguard people from abuse.

We look at whether there are suitable procedures for completing Disclosure and Barring Service (DBS) checks and that these checks are being carried out appropriately.

Primary health care services should:

• assess the different responsibilities and activities of staff to determine if they are eligible for a DBS check and to what level
• have processes for undertaking DBS checks at the appropriate level for staff who need them.
• recognise that the requirement for checks depends on the job that people do and not the individual person.

Who needs a DBS check?

Whether someone needs a DBS check and at what level depends on the roles and responsibilities of their job. This is based on the level of contact with patients, particularly children and vulnerable adults.

To find out who is eligible for a check, you can:

• use the NHS Employers DBS check eligibility tool
• contact the Disclosure and Barring Service.

Clinical staff (including GPs, nurses and healthcare assistants)

All clinical staff require a DBS check.

GPs should have had criminal records checks completed as part of their Performers List checks. You may use these checks rather than obtaining an additional DBS check when a GP begins working for the practice. If so, you should be able to demonstrate you have contacted NHS England:

• to gain assurance that a DBS check has been completed
• the date it was completed
• any information of concern identified in the DBS check has been risk assessed appropriately.

Non-clinical staff

There is no general requirement for non-clinical staff (for example reception or administrative staff) to have a DBS check. This depends on their specific duties and responsibilities. You should consider each case individually. For example, for non-clinical staff:

• access to medical records alone does not require a DBS check
• roles including chaperone duties may require a DBS check due to the nature of these duties and the level of contact with patients.
• staff who supervise a baby or child while their parent or carer is having an appointment require a DBS check.

So, practices may not be breaching regulations if certain non-clinical staff have not received DBS checks. If you decide not to carry out a DBS check for any role you need a clear rationale for the decision. This should include an appropriate risk assessment.

Renewing DBS checks

A DBS check has no official expiry date. Any information included will be accurate at the time the check was carried out.

Employers must decide if and when a new check is needed. You should be able to provide evidence you have considered where new checks are needed. This includes carrying out risk assessments to support the decision.

If someone has signed up for the DBS update service you can check whether their certificate is up to date online.

When we inspect

We may not look at every regulation at every assessment. Where we identify concerns regarding the fitness of staff, we assess against:

• Regulation 19 (Fit and proper persons)

We assess whether the provider has obtained the information listed in the Health and Social Care Act 2008 (regulated Activities) Regulations 2014 Health and Social Care Act 2008 (regulated Activities) Regulations 2014 schedule 3. This includes a copy of an appropriate DBS certificate.

We will assess the system and process for obtaining and renewing the DBS check and look at any risk assessments.

If outside organisations complete any pre-employment checks for your staff, we expect to see evidence of these. They will include DBS checks and also:

• professional registration
• references
• qualifications.

Further Information

DBS checks for CQC registration

Primary care first contact practitioners (FCPs)