Safer Recruitment

1. Purpose

Many of our learners have been harmed, exploited or let down by adults. Safer recruitment deters unsuitable people from applying, helps us spot them if they do, and builds a culture where concerns about adults are acted on. This policy follows Keeping Children Safe in Education 2026 (KCSIE) Part Three and our contracts with commissioning local authorities. Where it is stricter than KCSIE, we follow this policy.

2. Scope

This policy covers everyone who works in or for Care Cove Alternative Provision, whoever commissions a learner's place: employed and sessional staff; supply staff from First Class Teachers; counsellors from My Solution Wellbeing; coaches from Dreams Are Real CIC and Dream Chasers Basketball Club; members of the Social Work Management Committee (SWMC); volunteers; students; and contractors, transport providers and visitors. It includes internal candidates and people we already know. Knowing someone, including through the Dreams Are Real CIC coaching and volunteer network, is never a substitute for a check.

3. Law and guidance

• KCSIE 2026, Parts Three and Four.

• Safeguarding Vulnerable Groups Act 2006: regulated activity, the children's barred list and the duty to refer to the Disclosure and Barring Service (DBS).

• Crime and Policing Act 2026: volunteers in regulated activity need an Enhanced DBS check with barred list whether or not they are supervised.

• Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975: our roles are exempt, so candidates declare convictions and cautions that are not protected (filtered).

• Immigration, Asylum and Nationality Act 2006; Teaching Regulation Agency (TRA) prohibition orders; section 128 of the Education and Skills Act 2008; Equality Act 2010; UK GDPR and the Data Protection Act 2018.

4. Roles and responsibilities

5. Before we advertise

5.1 Job description and person specification

Every post has a job description and person specification approved by the Director. Each includes a safeguarding statement (the post holder safeguards and promotes the welfare of children, reports concerns to the DSL immediately and follows the Staff Code of Conduct), essential criteria on safeguarding understanding and boundaries, and the checks, qualifications (QTS) or registration (BACP or UKCP) the post needs.

5.2 Adverts

Every advert, on every platform, carries this statement:

"Care Cove Limited is committed to safeguarding and promoting the welfare of children and young people and expects all staff and volunteers to share this commitment. All posts are subject to an Enhanced DBS check with Children's Barred List, satisfactory references, verification of identity and right to work, and an online search in line with Keeping Children Safe in Education. We welcome applications from all sections of the community and are committed to a workforce that reflects the young people we serve."

The application pack includes this policy, the Safeguarding and Child Protection policy, the self-declaration form and the list of checks. It states that we search online on shortlisted candidates and that it is a criminal offence for a person barred from regulated activity with children to apply.

5.3 The panel

• Every panel has at least two people, at least one of whom has completed safer recruitment training in the last three years. The Connect training matrix shows who is trained.

• Panels for teaching posts include a teacher with QTS.

• Members declare any connection to a candidate, including through Dreams Are Real CIC. Where there is one, another person takes their place and the conflict is recorded under the Conflicts of Interest policy.

6. Applications, shortlisting and self-declaration

• We accept only our own application form, never a CV in its place, so we have full employment and education history, gaps, referees and declarations.

• Two people shortlist against the person specification and record reasons, noting anything to explore: gaps, unexplained moves, inconsistent dates and reasons for leaving.

• Shortlisted candidates complete a self-declaration of their criminal record and any information that would make them unsuitable to work with children: convictions and cautions that are not protected, any barring, prohibition or section 128 direction, any current police investigation and any professional sanction. The form explains filtering.

• Only the Director sees declarations. A conviction does not automatically rule someone out. The Director considers relevance, seriousness, age and pattern, discusses it with the candidate and records the decision. Failing to declare relevant information may lead to the offer being withdrawn or to dismissal.

7. Online searches

We search publicly available information on every shortlisted candidate, as KCSIE expects, to find anything suggesting they are unsuitable to work with children or that contradicts their application.

• The Administrator runs the same searches for every candidate (name, previous names, home area and any social media names on the form) using public search engines and public profiles only. Nobody sends friend requests, uses fake accounts or asks for passwords.

• Only relevant findings are recorded: violent, sexual, discriminatory or extremist content, comments about children, conduct that would breach the Staff Code of Conduct, or anything that conflicts with the application. Information about protected characteristics, private life or lawful opinions with no bearing on suitability is not recorded or passed to the panel.

• The record shows the searches run, the date and the searcher. Any finding is put to the candidate, who has a fair chance to respond before any decision.

8. References

• We take two references on every shortlisted candidate, including internal candidates, before interview, so any concern can be explored at interview.

• One must be from the current or most recent employer, from someone with authority (a head teacher, line manager or HR officer), not a colleague. If the candidate worked with children in the past but not now, we also take a reference from the most recent employer where they did.

• We request references directly from referees on our own form, using a checked work email address, never through the candidate. We do not accept open references or testimonials.

• The form asks about dates and role, reasons for leaving, suitability to work with children, disciplinary action, and any substantiated allegations or concerns about conduct towards children.

• The Director or Head of AP phones each referee to verify the reference and follow up anything vague or inconsistent, and records the call.

• Without two satisfactory references, we do not appoint.

9. Interview and selection

• At least one stage is face to face, with structured, values-based questions. Every interview explores attitudes to safeguarding, boundaries, handling a disclosure and de-escalation through scenarios, for example: "A colleague you like keeps messaging a learner after hours. What do you do?"

• The panel explores every gap of more than one month, reasons for leaving, discrepancies, reference concerns, online search findings and declarations, and records the explanations.

• If an activity with learners is part of the process, staff supervise throughout and the candidate is never alone with a learner.

• Each member scores against the person specification. The decision and reasons are recorded.

10. Conditional offer and pre-appointment checks

The offer is in writing and conditional on every check in Appendix A. The Administrator submits the Enhanced DBS application the day the offer is accepted. No start date is confirmed until the Director signs off the SCR entry.

10.1 Identity and right to work

Shortlisted candidates bring their documents to interview. Original photographic ID and proof of address are seen in person and a certified copy kept, with evidence of any name change. At the same stage, and always before anyone starts, the Administrator checks their right to work by a manual check of original documents from the Home Office lists, a Home Office online check using the person's share code, or a certified identity service provider check for British or Irish passport holders. A copy is kept with the date and checker, and any time-limited permission gets a follow-up date on Connect.

10.2 Enhanced DBS with children's barred list

• Every role needs an Enhanced DBS check with children's barred list check, applied for through our DBS umbrella body.

• Nobody has any contact with learners, supervised or not, until we have seen the original certificate. This is either a new certificate, or an existing Enhanced certificate for the child workforce that includes the barred list, where an Update Service status check done with the person's written consent shows no change. KCSIE allows a supervised start with a separate barred list check while a certificate is awaited; we do not use this option.

• If a certificate contains information, the Director discusses it with the person, completes a written risk assessment and records the decision. We do not keep copies of certificates; any copy needed for a decision is destroyed within six months.

10.3 Prohibition and section 128

The Administrator checks TRA Teacher Services for prohibition for anyone doing teaching work, including supply teachers, and in practice for every employed member of staff and tutor. Section 128 checks are done for everyone in a management or governance role: the Director, Head of AP, DSL, any future senior post and every SWMC member.

10.4 Overseas checks

Anyone who has lived or worked outside the UK for three months or more in the last five years provides a criminal record certificate or certificate of good conduct, or equivalent, from each country, following Home Office guidance. Teachers who taught abroad also provide a letter of professional standing. If a certificate cannot be obtained, the Director completes a written risk assessment and seeks extra references, and the person does not work with learners until the Director is satisfied.

10.5 Qualifications and registration

Original certificates are seen and copied for every qualification essential to the role. QTS is verified on TRA Teacher Services. Counsellors' BACP or UKCP registration is checked directly on the register, with number and renewal date recorded; Connect alerts us before it lapses. The Clinical Advisor is checked on the Nursing and Midwifery Council register and SWMC social workers on the Social Work England register.

10.6 Medical fitness

After the offer only, the person completes a health self-declaration, with an occupational health referral where a reasonable adjustment may be needed.

11. When a check is outstanding

Connect shows each person's clearance status and will not allow anyone to be rostered to unsupervised contact while a critical check is outstanding. On top of that control:

Non-critical items are limited to:

• Nurture UK training for someone joining after a cohort has started. Our fallback applies: Thrive training before any contact, a place on the next cohort, no unsupervised work until then, and the alternative agreed in writing with the commissioning local authority's contract manager.

• Team Teach training for a new starter; until trained they take no part in physical intervention.

• Emergency first aid training for a new starter, while a qualified first aider is on site.

• An occupational health appointment after a satisfactory health declaration.

The Director records the status, reason and review date on Connect and reviews it at least weekly. If in doubt, an item is critical.

12. Agency and partner organisation staff

We use partner staff only under a signed agreement and with the commissioning local authority's written consent where our contract requires it.

12.1 First Class Teachers

• Before the first booking, the agency confirms in writing that it has completed identity, right to work, references, Enhanced DBS with barred list, prohibition, overseas and qualification checks, giving the DBS certificate number and date. If the certificate disclosed information, we ask for a copy and the Director decides.

• We then carry out our own checks as well: QTS and prohibition on TRA Teacher Services, and DBS by Update Service status check or sight of the original. No agency worker has any contact with learners until the agency's written confirmation is on the SCR and our own checks are complete.

• On arrival for every booking, reception checks photo ID against the agency's profile before the person enters learner areas. They sign in and get a lanyard and a safeguarding briefing (DSL and Deputy, reporting, the Respect Code, phones, emergencies). We ask for named, returning staff.

12.2 My Solution Wellbeing counsellors

Before deployment, the Administrator checks BACP or UKCP registration on the register, My Solution Wellbeing confirms its checks and each counsellor's current Level 3 safeguarding training in writing, and we verify the Enhanced DBS with barred list ourselves. Before the first session, each counsellor is inducted into our procedures: they tell the DSL within the session about any disclosure or rising risk, and explain the limits of confidentiality at the first therapy session. Connect records their registration and monthly clinical supervision of at least 1.5 hours.

12.3 Dreams Are Real CIC and Dream Chasers coaches

Coaches have the same checks as staff and we see the evidence ourselves. Because the Director is also a director of the CIC, the Head of AP signs off their SCR entries. Care Cove staff stay with the group and meet the ratio on their own.

13. Volunteers, students and work experience

Volunteers go through the same recruitment, checks and induction as staff, including Enhanced DBS with children's barred list whether or not they are supervised (KCSIE 2026 and the Crime and Policing Act 2026). They never count towards ratios, never work unsupervised and are on the SCR.

Students aged 16 or over on college, university or professional placements need written confirmation of checks from their education provider and an Enhanced DBS with barred list check if the placement is regulated activity. Their ID is checked on arrival; they are inducted, always supervised, never counted in ratios and on the SCR.

Under-16s cannot get a DBS check. As our learners are secondary age, placing an under-16 with them is rarely appropriate and needs the Director's written approval and risk assessment. If agreed, they are directly supervised at all times, never alone with a learner and have no access to learner records. Students aged 16 or 17 not in regulated activity follow the same rules.

14. Contractors, transport and visitors

• Contractors work outside AP hours or away from learner areas where possible. Otherwise reception checks ID against the booking, and they sign in, wear an escorted lanyard and are escorted. Contractors working regularly in learner areas need an Enhanced DBS check (with barred list if the work is regulated activity), confirmed in writing by their employer.

• Transport operators confirm in writing that drivers and escorts hold Enhanced DBS with barred list checks, recorded on Connect (see the Transport and Escorting policy).

• Food Fusion delivers to reception and has no access to learner areas.

• Visitors follow the Site Security, Visitors and CCTV policy: ID checked, photo sign-in showing DBS status, lanyard and escort. Nobody works unobserved with a learner.

15. The Single Central Record

The SCR is held in Care Cove Connect and maintained by the Administrator. It covers employed staff, supply staff, counsellors, coaches, SWMC members, volunteers and students. For each person it records name, role, employer and start date; every Appendix A check with its date and who did it (including DBS number, issue date, barred list result and Update Service checks); QTS and registration numbers and expiry dates; any agency or partner confirmation; training dates; and clearance status.

Each month the Administrator checks every entry for completeness and for expiries in the next three months, confirms leavers have been removed, and sends a signed exception report to the Director, who reviews it and makes sure every gap is closed. The check and its outcome are recorded on Connect. When the Administrator is not available, the Director carries out the check. The SWMC audits the SCR termly, the annual independent external safeguarding audit reviews it, and it is available to the commissioning local authority at any time.

16. Induction and probation

16.1 Induction

Before any contact with learners, every new adult completes, with sign-off on Connect: Care Cove induction (values, model, site, emergencies) led by the Head of AP; KCSIE safeguarding training and Part One; Prevent levels 1 to 3; boundaries, low-level concerns and whistleblowing; and GDPR and Connect training. They read the key safeguarding, conduct, behaviour and phones policies, sign the staff acceptable use agreement, and learn who the DSL and Deputy are and their role in filtering and monitoring. Other training follows the dates in our contracts with commissioning local authorities. New starters shadow a colleague before taking a key learner caseload.

16.2 Probation

Employed staff serve six months' probation, with reviews by the Head of AP (the Director for senior posts) at six weeks, three months and before six months, covering safeguarding practice, boundaries, recording, relationships and training. Any concern about conduct towards a learner goes through the Managing Allegations Against Staff and Low-Level Concerns policy, not just probation.

17. Ongoing suitability, DBS renewal and disqualification

• Renewal. Every adult on the SCR has a new Enhanced DBS with barred list check at least every three years, as our contracts with commissioning local authorities require; Connect alerts the Administrator three months ahead. Update Service subscribers also have a status check at least annually, with consent recorded. If a status check shows new information, the person stops all contact until a new certificate has been seen and assessed.

• Duty to tell us. Everyone on the SCR tells the Director immediately (the SWMC Chair if it concerns the Director) if they are arrested, charged, cautioned, convicted, under police investigation or subject to a court order; barred, prohibited or subject to a section 128 direction; or if their registration is suspended or lapses. This includes events outside work.

• Annual declaration. Each September, everyone on the SCR confirms in writing that nothing affecting their suitability has changed.

• Response. The Director assesses any information with the DSL and may remove the person from contact meanwhile, as a neutral act. Allegations follow the Managing Allegations Against Staff and Low-Level Concerns policy, including LADO contact within one working day and telling the commissioning local authority's contract manager.

• Referrals. The Director refers to the DBS when we remove someone from regulated activity, or would have done had they not left, because they harmed a child or posed a risk of harm; to the TRA for serious teacher misconduct; and to the relevant professional regulator.

• Disqualification. The Childcare (Disqualification) Regulations 2018 apply to childcare for under-eights, not to our secondary-age provision. If someone also works in a Care Cove early years or childcare service, that service's arrangements apply there.

18. Records and retention

Unsuccessful candidates' forms, notes and search records are kept for six months, then securely destroyed. Personnel files are kept for the length of employment plus six years, and right to work copies for employment plus two years. Allegation records follow the Managing Allegations Against Staff and Low-Level Concerns policy. Only the Director and Administrator can access recruitment records, and Connect's audit log records every access. Candidates receive a privacy notice.

19. Monitoring and review

The Director reports SCR completeness, DBS renewals and training compliance to the SWMC, which audits the SCR and a sample of recruitment files termly. The annual independent external safeguarding audit covers safer recruitment. This policy is reviewed annually, or sooner after an incident, a change in law or guidance, or a contract change.

20. Related policies

• 01 Safeguarding and Child Protection
• 03 Managing Allegations Against Staff and Low-Level Concerns
• 04 Whistleblowing
• 05 Prevent and Counter-Extremism
• 06 Online Safety and Acceptable Use
• 16 Transport and Escorting
• 17 Data Protection, Retention and Information Sharing
• 18 Equality, Diversity and Inclusion
• 21 Staff Code of Conduct
• 27 Work Experience and Vocational Placements
• 28 Site Security, Visitors and CCTV
• 31 Conflicts of Interest
• 32 Disciplinary, Capability and Grievance
• 33 Staff Supervision, Appraisal and Training
• 41 Volunteers and Student Placements

Appendix A: Pre-appointment checks

Every check is critical and must be complete before any contact with learners.

Document control and ratification

This policy is signed off by the Designated Safeguarding Lead and the Head of Alternative Provision, and ratified by the Social Work Management Committee. It is reviewed every year, or sooner after an incident or a change in law, statutory guidance or contract requirements, and it is available to any commissioning local authority on request.