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DCC: Due Diligence Check

I already have a Disclosure, do I really need another one?

Unfortunatley in most cases the answer is - yes.

Until April 1st 2006 the CRB endorsed the practice of organisations accepting Disclosures originally obtained for another role provided :-

  • They were are the correct level for the new role with the relevant records having been checked
  • They were "clear" in all sections checked
  • They could be verified with the original Registered Body; which meant they were less than 6 months old

In 2004 the introduction of POVA checks meant that regulated organisations neeed to check the POVA list each time they placed a new employee, which meant they could not accept existing Disclosures, and in February 2006 the CRB reversed their position and withdrew their endorsement of the practice entirely.

The key factor in this decision was that the CRB checks the computer records within a few days of receiving the application form but, for Enhanced Disclosures, checking the police intelligence can take months, so by the time the Disclosure is issued the original checks can be so far out of date as to be unreliable.

With a Disclosure obtained for another organisation there is no way of telling how long it took to be issued and therby how long ago the POVA and POCAL checks were made.

Consequently, since the practice is not endorsed by the CRB, most users of the Disclosure Service feel duty bound not to accept existing Dislcosures, although doing so is not specifically banned.

Even those that are willing to accept existing Dislcosures find that most Registered bodies follow the CRB line and will not verify.

Only where the organisation is simply checking that a Disclosure has been done (rather than making an employment decision - usually where the holder woks for a sub-contactor) are they likely to accept an existing Disclosure, but then there is a doubt whether they should be seeing it anyway.