Introduction
If you work in the charity sector or for an overseas aid organisation, understanding DBS check eligibility is essential.
Whether your staff or volunteers are paid or unpaid, the right level of background screening ensures you're not only compliant with the law but also safeguarding vulnerable adults appropriately.
This guide walks through the eligibility criteria for online DBS checks, the meaning of regulated activity, and how organisations can ensure proper employee screening across various roles.
Index
Which organisation provide Criminal Record Checks in the UK?
Three organisations provide background checks in the UK:
- Disclosure and Barring Service (DBS) – for England, Wales, the Channel Islands, and the Isle of Man
- Disclosure Scotland (DS)
- Access Northern Ireland (ANI)
Depending on where the suitability decision is made, you must apply through the corresponding body. For roles based overseas but recruited in the UK, the relevant body is determined by where the decision to hire is made.
For Basic checks, individuals apply based on where they live. For Standard and Enhanced DBS checks, the decision-maker's location governs which check is applicable. Understanding these regional requirements is key to maintaining accurate and legal employee screening processes.
What Is Regulated Activity?
Regulated activity is work that individuals barred from working with vulnerable adults must not undertake. Defined under the Safeguarding Vulnerable Groups Act 2006, it applies regardless of whether the individual is paid or unpaid.
Regulated activity covers:
- Healthcare by or under supervision of a registered healthcare professional
- Personal care, including physical assistance or prompting with eating, drinking, hygiene, or dressing
- Social work services
- Managing finances or legal affairs under formal arrangements
- Transporting adults for healthcare or personal care appointments
Those performing regulated activity are eligible for Enhanced DBS checks with a check of the Adults' Barred List. These checks are vital tools for background checks and provide organisations with the security and confidence they need to protect those in their care.
Online DBS Checks for Charity Roles
Charity staff and volunteers can undergo online DBS checks for faster processing and digital verification. But eligibility depends on the nature of their role.
Trustees: If overseeing staff engaged in regulated activity, they can be asked to undergo an Enhanced DBS check. If trustees themselves engage in regulated activity, the Adults' Barred List check applies.
Retail Staff: Typically only eligible for Basic checks unless working directly and regularly with adults in regulated environments. Most charity shop workers fall under Basic checks unless their work involves supervision or assistance of vulnerable adults on a regular basis.
Fundraisers: Generally not eligible for Enhanced checks unless providing regulated care or supervision. Roles such as event marshals might be eligible for higher-level checks if they meet regulated activity definitions.
Drivers and Delivery Personnel: Only eligible for Enhanced checks if their work involves conveying or caring for vulnerable adults under formal organisational arrangements.
Employee Screening for Overseas Aid Workers
If an individual is being hired for overseas work and the suitability decision is made in England or Wales, they may be eligible for an Enhanced DBS check. If they have lived or worked abroad, a certificate of good conduct or police certificate should also be requested.
This ensures a thorough approach to employee screening, especially when DBS checks cannot access international criminal records. It’s essential that all aid workers are appropriately screened, regardless of whether their activities take place inside or outside the UK.
Example: A UK-based charity hiring doctors to work overseas can request Enhanced DBS checks with Adults' Barred List checks because healthcare is a regulated activity.
Definition of a Volunteer
For DBS purposes, a volunteer is someone who:
- Spends time doing something to benefit a third party
- Receives no payment (except travel or approved out-of-pocket expenses)
If the above criteria are met, charities can apply for free Enhanced DBS checks.
However, volunteers gaining experience for qualifications or future employment are not eligible for free checks. In these cases, organisations must pay the standard application fee. Understanding the scope of this definition is key to reducing the cost of background checks and ensuring compliance.
What Level of DBS Check Is Needed?
The type of background screening depends on the duties:
- Basic DBS Check: For retail staff, general volunteers, or those not engaging in regulated activity
- Standard DBS Check: For individuals in positions of trust, but not in regulated activity
- Enhanced DBS Check (with or without Barred List): For roles involving regulated activity with adults
Use the DBS eligibility tool to determine which check applies. This ensures that the correct background checks are requested, helping organisations avoid unnecessary costs or legal missteps.
Scenario-Based Eligibility Examples
Scenario 1: Charity Shop Volunteers and Sheltered Housing A volunteer from a sheltered housing scheme assists in a charity shop twice a week. Their supervisor is eligible for an Enhanced DBS check with a Barred List check, as they are supervising a vulnerable adult in a regulated activity.
Scenario 2: Overseas Volunteers A UK charity recruits UK-based doctors to work abroad. The doctors can receive Enhanced DBS checks with a Barred List check. If recruited overseas, a certificate of good character is also recommended.
Scenario 3: Drivers for Charities Drivers transporting vulnerable adults for medical appointments meet the threshold for regulated activity. If the role involves only delivery or companionship, it does not qualify for Enhanced DBS checks.
Scenario 4: Workshop Leaders A museum workshop for adults with dementia that runs weekly is eligible for Enhanced DBS checks. The instructor is providing teaching in a setting that qualifies as work with adults.
Charity Roles and DBS Check Eligibility
Not every charity role qualifies for a higher-level DBS check. Here's a quick overview:
- Retail workers – Basic DBS check
- Fundraisers – Basic unless involved in regulated activity
- Drivers – Enhanced if driving vulnerable adults to healthcare or personal care
- Workshop facilitators – Enhanced if working regularly with vulnerable adults
- Faith-based roles – Depends on activities; pastoral care may qualify for Enhanced
- Telephone helpline workers – Enhanced only if providing advice to at-risk adults regularly
- Online moderators – Enhanced if overseeing chat rooms used by vulnerable adults and doing so frequently
Final Thoughts
Charities and aid organisations must take employee screening seriously, especially when working with vulnerable adults. Regulated activity requires Enhanced DBS checks and sometimes barred list checks. Roles vary, so always assess tasks, frequency, and supervision before applying.
With the convenience of online DBS checks, staying compliant is easier than ever. Protect your organisation, staff, and those you serve by ensuring the correct level of background checks are in place.
For help with your application or to begin the online DBS check process, contact our team today. We’re here to support your safeguarding responsibilities and help you navigate the complex world of regulated activity and employee screening.
