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Improve CRB Portability and Reduce Duplicate Checking of Individuals

Comment 5th August 2010

We welcome the government’s initiative in reviewing the Independent Safeguarding Authority’s Vetting and Barring Scheme. While it is important that those working with vulnerable people be vetted and CRB disclosures may be a reasonable means to this legitimate aim, due to the lack of portability of CRB disclosures and the loss of risk assessment being at the heart of the process this has lead to the simultaneous requesting of multiple CRB disclosures of individuals. The considerable time and expense of these multiple disclosures for an individual provide no benefit for the vulnerable people and we would welcome the intention of scaling back these checks to "common-sense levels."

There are several concerns with the current use of Criminal Records Bureau disclosures in relation to protection vulnerable adults and children which have arisen out of adjustments to legislation such as the Protection of Children Act. These adjustments have created an ever increasing administrative burden and cost with little benefit to the vulnerable person and little value for the taxpayers’ money. It is unclear if current proposed full implementation of the Vetting and Barring Scheme will address these concerns and we hope that they will be considered when reviewing the Vetting and Barring Scheme.


The original intended purposes of Criminal Records Bureau and their private partner Capita has been lost. Just as a British passport is a universal form of evidence of citizenship and right to work in the UK for all places of employment, CRB disclosures were intended to bring together the necessary checks for an individual to work with vulnerable adults into a single, independently verifiable, portable document that the worker could take from one organisation to another.


This disclosure bringing together, police record checks and checks of relevant barred lists was to be sought when a candidate entered into working with vulnerable people with risk assessment being at the heart of how frequently rechecking was necessary.


However as “CRB no longer facilitates portability, organisations that choose to accept a previously issued CRB check do so at their own risk” the ability to verify a disclosure independently was lost and true portability with it.


Instead it has now become an common practice that it is necessary to request a new disclosure on start of any new form of employment such as registering with agencies, transferring from an agency to direct employment with an agency’s customer, taking a second job, or volunteer work, each organisation requiring their own disclosure to be requested, plus each requesting a new disclosure annually if ongoing, all checks at £36+ each.


When registering with an agency, even if a worker holds a fully enhanced disclosure issued just days prior to registering but requested by another organisation, due to the constraints (perceived or otherwise) on the agencies’ customers and a lack of verifiability and thus portability, a new disclosure is required before the worker can be placed. After a few weeks of ongoing placement with an organisation if it is decided that an agency worker will be taken on permanently by the agency’s customer, again due to lack of verifiability and thus portability, the organisation requests its own disclosure.


This results in considerable time that the worker although successful in seeking employment may be forced to wait unemployed at a time of economic downturn due to bureaucratic waste. With considerable expense to the worker and as many charitable organisations for vulnerable people are funded by the government ultimately the taxpayer, these un-needed extra disclosures are a clear expense to the people with no benefit.


As an agency that specialises only in the supply of locum workers to organisations that work with vulnerable adults and children every candidate registering must have an enhanced disclosure with ISA adult and children barring list checks.


However on review of 225 CRB disclosure applications for enhanced CRBs with barring checks applied for and disclosures received between may 2009 and may 2010, the average application time was over 40 days in process with CRB and less than 30% percent of disclosures were issued within CRB’s aim “to process 90% of Standard checks in 10 days and 90% of Enhanced checks in 4 weeks”





Time to Process

CRB target    

90% of applications 

28 days


30% of applications 

28 days


Based on 225 applications

40 days


The majority of this time is stage four processing, the time during which information is requested from the local police departments for each area that the applicant has lived in for the last 5 years. It is not surprising that these checks are time consuming particularly given how much of the police’s time is taken checking and rechecking information for individuals over and over again.


CRB is aware of these delays but rather than addressing frequent rechecking putting high demand on the system, CRB created the POVA First service (now renamed ISA Adult First) where for yet a further additional fee some of the disclosure information could be shared before information was received from the local police departments.

Why does this matter?

We recognise the importance of insuring all individuals working with vulnerable people should have a regular CRB check however the lack of portability has lead to several checks per individual per year being requested. We would like to see proper risk assessment and proper “common-sense levels” of checking performed as how does excessive checking protect the vulnerable?


For these reasons we agree with the REC as they have written on their website “Due consideration must also be given to the re-introduction of a portability service for disclosure checks.“

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