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DCC: Due Diligence Check

Who can request Disclosures?

Any organisation offering a role as part of their operations that is exempted from the Rehabilitation of Offenders Act (1974) is eligible to ask somebody who is or would be undertaking that role to obtain a Disclosure. This could include roles that are extra curricular, such as computer professionals mentoring under 18's in their lunch break or staff recruiting in schools etc.

Managers who directly manage people in such roles are also eligible, as are the organisation seniors who would have the authority to undertake the role, even if it was not within their normals duties, i.e. charity trustees and sports club commitee members etc.

For most organisations exempted roles are those which involve regular contact with under 18's or adults who are deemed unable to care for themselves due to physical or mental infirmity, be it permanent (e.g. due to age or a congenital condition) or temporary (e.g. illness).

The organisation must be in a position to prevent the subject taking the role; or in the case of regulators withold endorsement of their taking the role, if the Disclosure is not satisfactory.

This can cause probelms for organisation principals (where no "higher authority" exists) who have to be checked by a peer or a junior who agrees to take responsibility for reporting to external authorities, should they feel the Disclosure is not satisfactory for the role.

It also excludes the self-employed from checking themselves, as does the requirement that the subject and requester are different people - not just different entities (a director cannot be checked by "the company" - it has to be by another employee)

Other eligible roles are concerned with the judiciary, police, chartered accountancy, medical practioners, FSA regulated roles, certain postal worker roles and the security industry. Many of these have their own regulatory organisations who undertake the checks e.g. The Security Industries Authority, so working with children or vulnerable adults is the by far the most common justification for using the Disclosure service.