Become a Registered Body
Organisations wishing to use the Disclosure Service can register directly with the CRB and/or SCRO to become a Registered Body in their own right. Registration costs £300 for the CRB or £150 for Disclosure Scotland, plus £5 for each counter-signatory who registers with each bureau.
It should be noted that unless organisations intend to submit 120+ applications per annum the CRB would prefer that they access the service through a Registered Umbrella Body. Their concern is that organisations who submit fewer applications are not able to develop sufficient competence in the application process which could compromise the service; and to this end they have a program running to de-register organisations who make less than 120 applications per annum. (With the changes to the service expected in 2008 as a result of the Protection of Vulnerable Groups Act 2006, the number of Disclosure applications made by current service users is expected to decrease significantly and many will then dip below the 120 threshold)
Having become a Registered Body an organisation will need to establish pocesses and policies for handling applications. These would include
Processes for :-
|Incorporating the requirement for Disclosures into the recruitment process and terms of employment|
|Applicants need to be told from the start that a Disclosure will be required and for most existing staff retaining their role being dependent on a satisfactory Disclosure is a change to their terms and conditions of employment|
|Distributing application forms to identified personnel|
Packs also need to include :-
|Tracking the return of forms|
|People are often wary of Disclosures, form-phobic or just plain busy, so keeping track of who still hasn't returned their form and issuing reminders is a key process.|
|Checking and correcting application forms|
|The CRB form is not the friendliest and their guidance notes (16 pages) can be confusing, so there are often errors or omissions on the completed form. If these are not corrected the CRB will reject the form or worse, start processing it and then ask for more information, which can add weeks of delay.|
|Getting the applicant to provide adequate documentation that is in date is not easy and checking it properly is not trivial. Any documents being processed need to be stored securely and returned quickly (to the right person)|
|Tracking applications at the CRB|
|The new CRB online tracking service works well, but does not give any reasons for delays. Overdue applications still need to be investigated and expedited or they can take many months to come through.|
|Assessing the relevance and seriousness of Disclosure content|
|The current system requires organisations who request Disclosures to assess any content themselves, which needs a consistent process that is compliant with HR legislation.|
To support these processes Registered Bodies also need to provide applicants with written policies for :-
- The employment of ex-offenders
- The use, dissemination and storage of Disclosure information
- The assessment of Disclosure content
Once the policies are in place and processes are defined, the Registered Body needs to appoint and train staff to undertake the process.
For larger organisations the dilemma is whether to :-
- allocate resource centrally, providing IT systems for a small number of people to become efficient, competent and consistent, but also a recognisable cost-centre;
- delegate the tasks to local offices where they can be absorbed in the general administration overhead, but where the policies and processes will be applied with little control and inconsistently, which could expose the company.
Lastly, for Registered Bodies who handle any significant volume of applications, a process management system would need to be developed or purchased with all the associated costs and training.