Safeguarding checks

What is a safeguarding check?

The term ‘Safeguarding Check’ refers to the whole process of someone applying for all the vetting checks required for them to undertake their role or duties within the Chaplaincy.

What is a vetting check?

A ‘Vetting Check’ is the certificate received when someone applies for a criminal record check in any given country. They are sometimes also referred to as police clearances.

Who needs a safeguarding check?

A Chaplaincy Roles Checklist (PDF) can be found here. This is a list of chaplaincy roles with indicators to show for each role who needs to complete a Confidential Declaration Form (CDF), who needs to complete a Safeguarding Check and what level of Safeguarding Training is required.

Please note that this is a general guide and that the same role can have a different role title from chaplaincy to chaplaincy.  Contact the Diocesan Safeguarding Team for further guidance.

Which safeguarding checks do the Diocesan Safeguarding team complete?

The Diocesan Safeguarding Team complete the Safeguarding Checks for Clergy, Readers, Postulants, Ordinands, Churchwardens and Safeguarding Officers.  Chaplaincies are responsible for completing Safeguarding Checks for lay chaplaincy roles.

Who is an Occasional Helper?

‘Occasional’ refers to a role that is undertaken for less than three days in a thirty-day period and does not include any overnight (between 2am and 6am) activities with the opportunity for face-to-face contact.

‘Helpers’ are defined as those who assist in activities (e.g. Sunday School), but they do not have direct responsibility for children, young people and/or vulnerable adults, and who are under the supervision of an activity leader.

Occasional Helpers who work with children, young people and/or vulnerable adults will need to complete a Safeguarding Check to include vetting checks for all countries visited for over six months (as a total of all visits above one month in duration) within the last ten years.

If an Occasional Helper's role frequency increases or they become an activity leader with responsibility for children, young people and/or vulnerable adults, a full Safeguarding Check must be completed (to include vetting checks back to the age of 16).

For detailed guidance for each country, we have found both the Canadian and the UK Government websites to be useful. We have also made our own list of countries where we know checks cannot be obtained ( please the following section). We would advise that all three places are checked before any guidance is sent out.

Canadian Government Website

Although used for Canadian Immigration, this website has a useful drop-down list of all countries which has been separated out into guidance for citizens, non-citizens, in-country and out-of-country applications. This means it can be used as guidance for those outside of Canada. We have found that it seems to be updated more frequently than the UK Government Website, so we would suggest this as a first point of reference.

UK Government Website

This is the official UK Government Guidance. It is useful as a second point of reference together with the information found in the Canadian guidance and often has useful email and telephone contacts.

Unobtainable Vetting Checks

On some occasions, a country may be listed on the above websites, but we know from experience that it is not possible to obtain a vetting check. For these cases, we have made a separate list which we keep updated as new information becomes available - please refer to the list of countries in the section below.

Switzerland, the Netherlands and the UK

For all three of these countries, the application process requires extra guidance. In the case of Switzerland and the Netherlands, vetting checks require a confirmation from the employer before the application form can be sent off.

In both instances ‘the employer’ refers to the organisation for whom the applicant is currently undertaking work (either on a paid or voluntary basis). For our purposes, this will be the Chaplaincy. The Safeguarding Officer should therefore complete any sections required by ‘the employer’ on behalf of the Chaplaincy.

Switzerland

There are two vetting checks available in Switzerland, it is the Special Excerpt that is required. In order to apply for a Swiss Special Excerpt, the applicant will need to:

1. Request an Employer’s Confirmation from the Safeguarding Officer.
2. Complete the online application for a Special Excerpt.

The Safeguarding Officer should refer to this guidance for a step-by-step guide to completing the employer’s confirmation.

The Netherlands

The Netherlands vetting check is called a VOG and the application form can be found on their website. In order to apply for a Netherlands VOG, the applicant will need to:

1. Ask the Safeguarding Officer to complete Section 2 of the application form and provide a brief job description which should be attached to the application form.

The Safeguarding Officer should refer to this guidance for a step-by-step guide to completing Section 2 of the application form.

The UK

The eligibility guidance and application process is different for applicants who have previously spent more than 6 months located in the UK. The process for this vetting check is completed by the applicant, the Chaplaincy and the Diocesan Safeguarding Team. As such, there is separate guidance for this in Section 3.

Sending out the guidance

After establishing the countries that will require vetting checks, the Safeguarding Officer will need to send the applicant the guidance for each one.

3.1 Overview

Unlike other vetting checks, the UK DBS has several different parts to it which need to be completed by:

• The Applicant.
• The Safeguarding Officer (on behalf of the Chaplaincy) and/or the nominated person for recruitment in the Chaplaincy.
• The Diocesan Safeguarding Team.

Full details are given in the Step-by-Step Guide, but a summary of the process is below together with who needs to complete that part:

1. The Safeguarding Officer initiates the check process
2. The Applicant completes the Confidential Declaration Form.
3. If the Applicant has indicated on the CDF that they have lived in the UK in the past 10 years and require a UK DBS check, the Safeguarding Officer sends the completed CDF to the Diocesan Safeguarding Team.
4. The DST sends the Applicant the DBS Guidance and User ID.
5. The Applicant logs on with the User ID and completes the online application.
6. The Applicant chooses 3 pieces of ID documentation (2 forms of ID and 1 proof of address) and photocopies them,
7. The Applicant shows the original documentation and the photocopies to the nominated person for verification.
8. The nominated person completes the document verification form and sends form and the verified photocopies to the DST.
9. The DST send off for the DBS check.

3.2 Eligibility

The eligibility criteria for a DBS vetting check is unfortunately a lot more complicated than for other overseas vetting checks. The criteria can be found in full on their website but we have tried to summarise it below.

The information has been laid out below in more detail but if you want to quickly check an applicant’s eligibility you can do so using either the DBS Eligibility Tool or the Safeguarding Questionnaires.

IMPORTANT NOTE: It is not legal for the Diocesan Safeguarding Team to apply for a certain type of DBS vetting check ‘just in case’ someone might increase their role duties or frequency in the future, so it is important to answer the questions according to the role and frequency the applicant is currently undertaking.

Types of DBS vetting check

There are four types of DBS vetting check that are offered by DBS – Basic, Standard, Enhanced and Enhanced plus Barred List Check. For our purposes, the Enhanced and Enhanced plus Barred List Check are the only two that the Diocesan Safeguarding Team request, depending on the role and the frequency that the role is being carried out.

Type of role

There are several different options that need to be considered when putting someone through for a DBS vetting check, most of these are relation to the duties of the role that are being carried out and the frequency of that role.

Some of the questions that need to be considered are as follows:

1. Which workforce will the applicant be working with?

• Child
• Adult
• Child and Adult

For further details please see this page of the DBS website.

2. What specific duties will they be carrying out?

• Will they be working directly with one (or both) of the above people groups or are they supervising someone who does?

Will the role include any sort of health care or relevant personal care e.g. toileting or feeding where the person is unable to do this for themselves?

3. How frequently will the applicant be undertaking the role?

If working with children will the person be working:

• on more than 3 days in a 30-day period?
• overnight between the hours of 2 am and 6 am with the opportunity for face-to-face contact with children?

If the applicant is conducting any form of health or personal care, they only need to do it once to be eligible for an Enhanced with Barred List Check.

If working with vulnerable adults:

is the applicant undertaking any of the duties listed in this document?

It is important to note that they only need to do any one of these activities once.

4. Are they in Regulated Activity?

A person is considered to be in Regulated Activity if they are carrying out their role frequently (as defined above) or extensively.

If you need further guidance about what qualifies as ‘Regulated Activity’ please see the DBS Guidance Leaflets. (These are from a UK perspective, but the information can still be useful.)

3.3 Step-by-Step Guide

This is a guide to the end-to-end process of completing a DBS vetting check. The person responsible for each stage of the process is in brackets.

1. Initiate the check and inform the Diocesan Safeguarding Team - (Safeguarding Officer)

As soon as the Chaplaincy becomes aware that the applicant will require a UK DBS vetting check, they should email the Diocesan Safeguarding Team at europe.safeguarding@churchofengland.org with the following:

1. The applicant’s completed Confidential Declaration Form.
2. Either a printout of the results from the online DBS Eligibility Tool showing clearly which DBS vetting check they are eligible for or a copy of the relevant Questionnaire.

2. Hand out the DBS Guidance – (Diocesan Safeguarding Team)

The Diocesan Safeguarding Team will then email the applicant with their unique User ID Number together with all the guidance required for completing the vetting check including:

1. Guidance for completing the online application.
2. Guidance about the 3 pieces of ID documentation.
3. Guidance for verifying the ID documents.

3. Complete the Online Application and Document Verification – (Applicant)

When the applicant receives this email they will need to complete the online DBS application using their unique User ID Number.

They will then need to photocopy 3 pieces of identity documentation and then take both the originals and the copies to either one of:

1. A Safeguarding Officer.
2. A Churchwarden.
3. A Reader.

If none of the above is available, then a Member of Clergy.

The person completing the document verification must have completed a safeguarding check themselves.

For more information about what documents can be accepted, please see the UK Enhanced DBS Check ID Documents List.

4. Document verification – (Chaplaincy)

When one of the above persons has received the documentation, they must ensure that:

1. The person presenting themselves is the same person that the documents belong to.
2. The photocopies are true versions of the originals.
3. The documents are valid.

For the complete guidance please see this document but please note that we do have to make adaptations in order to account for the fact that the diocese is largely based in Europe and not in the UK.

The Chaplaincy will then need to:

1. Sign and date each copy as ‘a true version of the original’
2. Send the verified copies by email to europe.safeguarding@churchofengland.org.

5. Send off for the vetting check – (Diocesan Safeguarding team)

Once the Diocesan Safeguarding Team receive the documentation, we will compare it to the information given in the online application and if it matches up, we will then send off for the vetting check.

A note about results

If you reside outside of the UK the results of the DBS vetting check along with the original certificate will be sent to the Diocesan Office. The Diocesan Safeguarding Team will then return this to the applicant by post.

3.4 Questionnaires

We are aware that the online DBS Eligibility Tool does not directly reference church roles so it may be easier in some cases to use the Questionnaires instead.

4.1 Introduction and the unobtainable vetting checks list

We have become aware that sometimes, despite what the UK or Canadian Government guidance may say, it is not always possible to obtain a vetting check from certain countries.

In such cases, it may be necessary to first request a safeguarding reference and then to issue the person with an exemption from having to obtain a vetting check from that country. This must be assessed on a case-by-case basis.

Before going any further with this guide, we would advise that the Safeguarding Officer double-checks the Unobtainable Vetting Checks List. The Unobtainable Vetting Checks List is a list of countries where we know it is either not possible to obtain a vetting check or it can only be obtained from within the country itself.

4.2 When to consider issuing an exemption

Here are two types of exemptions:

Exemptions for unobtainable vetting checks

There are several occasions when a vetting check might be unobtainable:

• It is not listed on either of the suggested websites.
• It is listed but there is advice in the Unobtainable Vetting Checks List to suggest it is not obtainable.
• The applicant has made every reasonable attempt but is unable to meet the criteria.
• In a small number of cases it may be theoretically possible to obtain a vetting check but due to the political situation in the country or the circumstances under which the applicant left it may be inadvisable to do so.

Temporary exemptions as an interim measure

There are occasions when a vetting check is obtainable but not immediately.

Example One:

The vetting check is only available by visiting a specified office in the country that the vetting check is for.  If the applicant still visits that country, they would then be able to obtain the vetting check upon their next visit.

Example Two:

Fingerprints are not available in the country of the chaplaincy in the specified format required for the vetting check.  If the applicant still visits the country that the vetting check is for, they would then be able to give fingerprints during their next visit.

Example Three:

A vetting check (such as the FBI Check and the Military Service Records Check) takes a number of weeks to arrive which results in a long delay to completion of the Safeguarding Check.

It is possible that these and similar situations may then prevent an individual from starting in their role and the chaplaincy are in urgent need of volunteers to begin their duties.

In such circumstances, but only when necessary, a Temporary Exemption can be issued.

4.3 Levels of vetting check

It is sometimes the case that when one level of vetting check is difficult to obtain there may be a lower level that can be applied for instead. The Safeguarding Officer will need to have a look at each country’s local government website to see if there are other options available.

We would advise that:

• The applicant attempts to obtain the highest level of vetting check (this sometimes involves having fingerprints taken).
• If this is not possible, they should provide evidence to demonstrate their attempt.
• Check to see if a lower level of vetting check is obtainable.
• If all reasonable attempts have been made and evidence has been provided to demonstrate this, then a safeguarding reference can be requested in lieu of a vetting check.

4.4 References

If every reasonable attempt has been made to obtain a vetting check but it has not been possible to obtain one, the Safeguarding Officer will need to follow the steps below in order to obtain appropriate safeguarding references in lieu of a vetting check.

1. Ask the applicant for the name, email address and contact telephone number of someone who knew them well during the time they were in the country and who would be willing to provide a character-safeguarding reference.
2. Send the Safeguarding Reference Form to the referee, ask them to complete it and return it to the Chaplaincy.
3. Once the form has been received from the referee, contact the referee by telephone and cross-check two or three of their answers for verification purposes.
4. Remember – this is in place of a vetting check so the more information that can be obtained the better. The Safeguarding Officer will need to satisfy themselves that as far as possible there was no bad conduct by the person during the time they were in that country.
5. Complete an Exemption Form evidencing the steps taken to obtain a vetting check and outlining the results of the safeguarding references sought.
6. The Exemption Form will then need to be signed off by the Safeguarding Officer and the Chaplain (or Incumbent).

If the applicant no longer knows anyone who knew them during their time in that country, two personal references should be sought from:

1. A current employer or previous church.
2. A current personal contact.

The referees can be the same as those sought during the Safer Recruitment process, but the Safeguarding Reference Form must be used.

Please note that the exemption and safeguarding reference process should only be used as a last resort.

4.5 Diplomats and military personnel

In some cases, the applicant will only have been resident in a country as either a diplomat or as part of their deployment with the military. In these instances, their records will not be available from that country and vetting checks cannot be obtained. In lieu of a vetting check a military record or diplomatic record should be provided instead.

UK military

In the case of those in the UK Military the applicant can request a copy of their own military record using this link.

Non-UK military

For other countries the Safeguarding Officer will need to look on that country’s government website for details of obtaining military records.

Diplomats

In the case of diplomats, the Safeguarding Officer can ask the applicant to obtain a copy of their diplomatic records.

What to check for

Once the diplomatic or military records have been received the Safeguarding Officer should check:

• The locations the applicant was deployed to are the same as they have declared on their Confidential Declaration Form.
• There are no criminal convictions or offences.
• The applicant was honourably discharged (in the case of ex-military personnel).

If the appropriate records are obtained (along with all other required vetting checks), then the Safeguarding Check can be completed without the need for an exemption.

If the records cannot be obtained, safeguarding references should be sought, and the same process followed as above.

4.6 Step-by-step guide for issuing exemptions

Step 1

In the first instance, the Safeguarding Officer should check the UK and the Canadian Government Websites to see if there are any other levels of vetting check available.

Step 2

The Safeguarding Officer should also check the Unobtainable Vetting Checks List.

Step 3

If the Safeguarding Officer is satisfied that:

1. The vetting check in question is listed as being unobtainable; or,
2. The applicant has made every reasonable attempt to obtain a vetting check but has been unable to do so;

then the Safeguarding Officer should follow the process (4.4) for obtaining safeguarding references.

Step 4

Once the reference process has been completed, the Safeguarding Officer should complete the Exemption Form with all of the appropriate evidence.

Step 5

The Safeguarding Officer should sign off the Exemption Form together with the Chaplain (or Incumbent).

Step 6

All exemptions should be recorded in the comments section of the Chaplaincy Safeguarding Log.

4.7 Step-by-step guide for issuing temporary exemptions

Step 1

If the Safeguarding Officer is satisfied that:

• The vetting check in question is obtainable but there are appropriate reasons for the delay in obtaining it; and
• The chaplaincy is in urgent need of an individual to begin their duties;

then the Safeguarding Officer should follow the process (4.4) for obtaining safeguarding references.

Step 2

Once the reference process has been completed, the Safeguarding Officer should complete the Temporary Exemption Form with all of the appropriate evidence.

Step 3

The Safeguarding Officer should sign off the Temporary Exemption Form together with the Chaplain (or Incumbent).

Step 4

All Temporary Exemptions should be recorded in the ‘Comments / Details of Blemish’ section of the Chaplaincy Safeguarding Log. The Log should be updated upon receipt of the vetting check certificate.