Agenda item

The Assistant Director presented a report to the Committee detailing the proposed Criminal Records Bureau Policies, Procedure and Practice.  These policies had been created in accordance with the Criminal Record Bureau’s (CRB) Code of Practice which required Slough Borough Council, as a registered body to have written policies and guidelines to assist with the assessment of the suitability of applicants for positions of trust.  In addition, the policies were also created / amended in recognition of the Council’s safeguarding responsibilities.  These policies would provide a clear framework for managers and staff in the management of the CRB disclosure process.  The policies had been circulated in draft form for formal consultation with the Corporate Management Team, the recognised Trade Unions and the special interest group – BAME and the Disability Forum.

Members raised several issues in the following discussion, including:-

• Referring to Section 4.8 of the report, a Member queried whether there would be any costs to the Council.  The Assistant Director advised that there would be no additional financial cost to the Council but that it costs £36 per enhanced CRB check.
• A Member enquired as to whether any staff were required to provide their own CRB check.  The Officer informed the meeting that staff were not required to do so as the CRB check formed part of the Council’s pre-employment clearances related to the recruitment process.  A small administration fee was charged to external bodies allied to the Council, although this did not apply to Slough schools.  The Council processed approximately 130 CRB checks per month. [This has now been checked and it is confirmed that it is on average 300 per month.]
• A Member enquired as to what action would be taken where a prospective employee failed to disclose a minor offence.  The Assistant Director advised the Committee that a risk assessment would be carried out based on the offence in relation to the nature of the job and that a list of the rehabilitation period after which sentences could be discounted, was included within the recruitment of rehabilitation of offenders policy.  The risk assessment would be carried out by the line manager and the final decision regarding the offer of employment would be made via consultation with HR and the line manager.
• A Member enquired as to how long it took for the CRB check to be processed and whether the employee could work in a position of trust during this time.  The HR Business Partner (E&CS) informed the Committee that it took an average of 6-8 weeks for the CRB to be completed.  A risk assessment would have to be carried out and signed off by the relevant Assistant Director and Strategic Director to enable a member of staff to work in an unsupervised capacity during this period.  For example, if a teacher were to transfer from one school within the Borough to another, they would have a valid CRB check already in place; however, in most cases new members of staff would be supervised during this period and the induction process would allow sufficient time for the CRB check to be completed.
• Referring to Section 5.8 of the report regarding the development of the council’s safeguarding commitments, a Member sought further information about the external bodies involved.  Several organisations and developments effecting the national direction of these commitments were listed to the Committee; these included the Commission of Social Care Inspection (CSCI), the Office for Standards in Education (OFSTED), the Adult Learning Inspectorates (ALI) and the new Laming Report.  The Council was also made aware of the West Berkshire Safer Recruitment Guidelines.
• Further information was sought in relation to the storage of the CRB forms.  The Human Resources, Business Partner (E&CS) informed the meeting that the CRB had strict storage guidelines. Currently, the forms were kept in a single locked filing cabinet, with one set of keys and restricted access for the team.
• A concern regarding the possibility of employees working in sensitive positions before having been cleared by CRB was raised and a suggestion made that it should be best practice to ensure that this does not occur. The Committee was advised that posts that required CRB checks were often also posts which were hard to recruit to and, as a result, tended to be in pressured front-line services / areas. Delaying recruitment to these posts would be to the detriment of these services, however, all checks are undertaken as quickly as possible and appropriate risk assessments taken if a new employee started before receipt of relevant checks.

Resolved – That the revised Criminal Records Bureau Policies, Procedure and Practice be approved.