Policy on the Secure Storage, Handling, Use, Retention and Disposal of Disclosures and Disclosure Information
As an organisation using the Disclosure and Barring Service (DBS) to help assess the suitability of applicants for positions of trust, Laleham Church Playgroup complies fully with the DBS Code of Practice regarding the correct handling, use, storage, retention and disposal of Disclosures and Disclosure information.
It also complies fully with its obligations under the Data Protection Act 1998 and other relevant legislation pertaining to the safe handling, use, storage, retention and disposal of Disclosure information and has a written policy on these matters, which is available to those who wish to see it on request.
Storage and access
Disclosure information is kept securely, in lockable metal cabinet, non-portable, with access strictly controlled and limited to those who are entitled to see it as part of their duties. (Manager/Deputy Manager).
Handling
In accordance with Section 124 of the Police Act 1997, Disclosure information is only passed to those who are authorised to receive it in the course of their duties. We maintain a record of all those to whom Disclosures or Disclosure information has been revealed and it is a criminal offence to pass this information to anyone who is not entitled to receive it.
Note: When required by statutory duty to retain Disclosures for inspection purposes, the Disclosure will be destroyed immediately following the inspection.
Usage
Disclosure information is only used for the specific purpose for which it was requested and for which the applicant’s full consent has been given.
Every Term the DBS for each member is check by the Manager on the Update Service to check that the member of staff is still suitable to work with children. Before this is carried out at each Supervision/Appraisal (three times a year) consent is requested on the supervision/Appraisal form to agree that the Manager can check their DBS.
Retention
Once a recruitment (or other relevant) decision has been made, we do not keep Disclosure information for any longer than is necessary. This is generally for a period of up to six months, to allow for the consideration and resolution of any disputes or complaints. If, in very exceptional circumstances, it is considered necessary to keep Disclosure information for longer than six months, we will consult the DBS about this and will give full consideration to the data protection and human rights of the individual before doing so. Throughout this time, the usual conditions regarding the safe storage and strictly controlled access will prevail.
The DBS number is kept on record and kept securely in a locked metal cabinet in a file so that the manager can use this information, with permission from the staff member, to check the DBS termly with the Government Update Service.
Disposal
Once the retention period has elapsed, we will ensure that any Disclosure information is immediately destroyed by secure means, e.g. by shredding, pulping or burning. While awaiting destruction, Disclosure information will not be kept in any insecure receptacle (e.g. waste bin or confidential waste sack). We will not keep any photocopy or other image of the Disclosure or any copy or representation of the contents of a Disclosure. However, not withstanding the above, we may keep a record of the date of issue of a Disclosure, the name of the subject, the type of Disclosure requested, the position for which the Disclosure was requested, the unique reference number of the Disclosure and the details of the recruitment decision taken.
Signed by: …………………………………………. Date 12th March 2024
On behalf of Laleham Church Playgroup