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Our work to strengthen safeguarding

About our safeguarding project

Our safeguarding project is looking at the arrangements that the Accredited Registers and statutory regulators have in place to make sure their registrants have appropriate criminal records checks.

What are criminal records checks?

Criminal record background checks are an important part of keeping patients and the public safe. They are carried out by different agencies, depending on where in the UK the work is being carried out:

Employers carry out most of these checks. Some regulators and Accredited Registers do criminal records checks for self-employed registrants.

Our work to date

So far, we have focused on the arrangements for the Accredited Registers. Accredited Registers are organisations that hold voluntary registers of people working in health and care roles that are not required by law to be registered. To be accredited by us, they must meet our Standards for Accredited Registers. More about Accredited Registers can be found here.

Accredited Registers have found it hard to access criminal record checks for their registrants. This has meant a gap in checks for registrants who are self-employed.

In March 2022 we launched a pilot scheme to better understand the circumstances in which Accredited Registers can make these checks. Following this, we consulted publicly on whether to widen these checks in future.

You can read more about this and our work on safeguarding arrangements for Accredited Registers here.

Government review

In February 2022 the Government announced its Independent Review into the Disclosure and Barring Regime. The purpose of the review was to provide assurance to Ministers about the effectiveness of the disclosure and barring regime in safeguarding children and vulnerable adults. It included reviewing the definition of ‘regulated’ activity, used to determine who is eligible for a higher-level DBS check, and eligibility gaps for disclosure checks for the self-employed. The scope of the review included the statutory regulators as well as the Accredited Registers.

The report of the Independent Review, ‘the Bailey Review’, is now published. It made nine recommendations, which the government is now considering. We will need to consider the government’s response to the recommendations in relation to our own work with the regulators and Accredited Registers.  

Next steps

In July 2023, our Board decided to extend our safeguarding work to consider the arrangements for the statutory regulators. This will allow us to make sure we take a consistent approach.

The scope of the project is to:

  • Further liaise with the Government (UK health departments, Home Office and Ministry of Justice) on potential changes to the legislative framework underpinning criminal records checks and broader safeguarding policy.
  • Assess the risk of harm to the public, and to public confidence, of any weaknesses in the current approach taken by the Accredited Registers and regulators to safeguarding and criminal records checks. This will be informed by data available from our own processes, the ARs and the regulators, external literature, and engagement.
  • Engage and consult as needed to better understand the risks and issues presented by the Accredited Registers and regulators current arrangements for criminal records checks.
  • Develop our policy position about the current arrangements in place for criminal records checks by the Accredited Registers and the regulators, and wider Governmental policy.
  • Decide whether to revise our requirements for the regulators and Accredited Registers criminal records checks and other safeguarding measures such as mandatory duties for reporting.
  • Review if there is more we can do ourselves to strengthen safeguarding, such as reviewing our own reporting policies and facilitating greater sharing of information between the Accredited Registers and the regulators. 

We will give further updates about progress on this page. If you have any questions please contact

Further information about criminal records checks within the UK

Information about checks in Scotland

Changes are underway to criminal record checks in Scotland. The scheme in place operates on a different basis to that in the rest of the UK. The information below has been provided by Disclosure Scotland, for Accredited Registers.

What type of criminal record check should be used for an individual on a regulated profession or on one of the accredited registers?

The type of check appropriate for the role on an accredited register will depend on what the duties of the role involve. You should check with the relevant agency if you are unsure which type of criminal record check to apply for. 

We recommend that the highest level of check available for the role is carried out as part of safe recruitment practice. 

The PVG Scheme

The Protecting Vulnerable Groups (PVG) membership scheme is managed and delivered by Disclosure Scotland. It helps ensure people whose behaviour makes them unsuitable to work with children and protected adults cannot do 'regulated work' with these vulnerable groups. A PVG Scheme member's certificate shows the information available on the day it was created. Membership of the scheme lasts forever though, and scheme members are continuously checked, unless they decide to leave the scheme.

Not all roles on accredited registers will be eligible for PVG membership and it’s important that you only access PVG checks when you’re entitled to do so. You can find out more about the types of work covered by the PVG Scheme on the Disclosure Scotland website

What type of PVG check can I use if I am employed by an organisation or if I have been employed under a contract of service/contract for services? 

If you’re working for an organisation in a role considered to be 'regulated work', your employer can ask you to join the PVG Scheme, either by applying for a Scheme Record or a Short Scheme Record. You can find out more about this on the Disclosure Scotland website.

These types of certificate provide confirmation of the individual’s scheme membership details, along with details of vetting information (or state that there is no vetting information).  

What type of PVG check can I use if I am self employed?

If you're self-employed and doing regulated work for an individual (rather than for an organisation), you can join the PVG scheme without an organisation countersigning your application.

This is known as a Scheme Membership Statement application. If you're working for an individual (a personal employer), you can choose to ask them to countersign your application. They'll be sent a copy of your PVG certificate.

A Scheme Membership Statement will provide confirmation of the individual’s scheme membership details and, if provided, the name and address of the personal employer. You can find out more about this on the Disclosure Scotland website.


Find out more about our safeguarding consultation

We ran a consultation at the end of 2022 to find out more about how to strengthen safeguarding for Accredited Registers. You can find out more about the consultation and the report we published on the outcome here.

The Bailey Review

The Government has also reviewed the Disclosure and Barring regime. The resulting report of the Independent Review known as, ‘the Bailey Review’ made nine recommendations, which the government is now considering.  

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