Introduction

As an organisation using AccessNI to help assess the suitability of applicants for positions of trust, Concern Worldwide (UK) complies fully with AccessNI’s Service Level Agreement regarding the correct handling, use, storage retention and disposal of Disclosure Applications and Disclosure information (“Disclosure”) for individuals resident in Northern Ireland. 

In addition, as an organisation using the Disclosure and Barring Service (DBS) checking service to help assess the suitability of applicants and individuals for positions of trust resident in England and Wales, Concern Worldwide (UK) also fully complies with the DBS Code of Practice regarding the correct handling, use, storage, retention and disposal of certificates (“Certificates”) and Certificate Information. 

We also comply fully with obligations under the UK General Data Protection Regulation (UK-GDPR), Data Protection Act 2018 and other relevant legislative requirements pertaining to the safe handling, use, storage, retention and disposal of Disclosure Information and DBS Certificate Information. 

Consent 

As we do not receive a copy certificate from AccessNI or DBS written consent will be obtained from the Applicant when requesting and retaining a (copy of a) Disclosure certificate. 

Storage and Access 

Disclosure and DBS Certificate Information is kept securely, both in electronic and paper format. The former is held on our own secure IT systems, where technical and organisational arrangements are in place to protect data, and the latter in lockable, non-portable, storage containers. In both instances, access is strictly controlled and limited to those who are entitled to see it as part of their duties. 

Handling 

In accordance with section 124 of the Police Act 1997, Disclosure and Certificate 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 Certificate Information has been revealed. We recognise it is a criminal offence to pass this information to anyone who is not entitled to receive it. 

Usage 

Disclosure and Certificate Information is only used for the specific purpose for which it was requested and for which the applicant’s full consent has been given. 

Retention 

Once a recruitment (or other relevant appointment, regulatory or licensing) decision has been taken, we do not keep Disclosure or Certificate Information for any longer than is necessary.  This retention period allows for the consideration and resolution of any disputes or complaints and/or the completion safeguarding audits.  Throughout this time, the usual conditions regarding safe storage and strictly controlled access will prevail. We comply with AccessNI’s and DBS’s Service Level Agreement to return the original Disclosure certificate to the applicant once a decision, recruitment or otherwise has been made and will be retained no longer than the agreed period. 

Disposal 

Once the retention period has elapsed, we will ensure that any Disclosure or DBS Certificate Information is immediately deleted or destroyed by secure means, for example by deletion from our IT systems or the shredding, pulping or burning of paper records. While awaiting destruction, Disclosure and Certificate Information in paper format will not be kept in any unsecured receptacle (e.g. waste-bin or confidential sack). We will not keep any photocopy or other image of the Disclosure or Certificate Information or any copy or representation of the contents of a Disclosure or Certificate Information or any other relevant non-conviction information supplied by police. However, despite the above, we may keep a record of the date of issue of a Disclosure or Certificate, the name of the subject, the type of Disclosure or Certificate requested, the position for which it was requested, the AccessNI or DBS unique reference number of the Disclosure or Certificate, and the details of the recruitment decision.