3.7 FA DISCLOSURE AND BARRING SERVICE CHECKS - FAQs - GUIDANCE NOTES NO

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3.7 FA DISCLOSURE AND BARRING SERVICE CHECKS - FAQs - GUIDANCE NOTES NO
GUIDANCE NOTES NO:

3.7
FA DISCLOSURE AND BARRING
SERVICE CHECKS - FAQs

                      Version: 1.1
                      Published: MAY 2019
3.7 FA DISCLOSURE AND BARRING SERVICE CHECKS - FAQs - GUIDANCE NOTES NO
FA DISCLOSURE AND BARRING SERVICE
CHECKS (DBS CHECKS) - FAQs

Your CFA Designated Safeguarding Officer
(DSO) and or The FA DBS Unit can assist if
                                                The information included in the document
                                                will depend on the type of disclosure applied
                                                                                                    2. WHAT IS THE                                    3. WHY DO PEOPLE IN
you have any questions as a result of using     for. The majority of checks in football             QUICKEST WAY TO                                   FOOTBALL NEED TO
these FAQs.                                     are undertaken on those who work with
                                                vulnerable groups, such as children or
                                                                                                    GET A DBS CHECK?                                  HAVE A DBS CHECK?
1. WHAT IS A                                    adults at risk.                                     Through the online application process run        Not everyone in football needs one. See

DISCLOSURE AND                                  An ‘Enhanced DBS Check’ contains all
                                                                                                    by The FA DBS Unit. Feedback from users
                                                                                                    of the service is extremely positive. For
                                                                                                                                                      question 4 below.

BARRING (DBS)                                   conviction information, spent and unspent,          more information about the process, e-mail
                                                                                                                                                      The law requires that The FA does all that
                                                                                                                                                      it can to prevent people who are barred
CHECK?
                                                and any other non-conviction information            FAchecks@TheFA.com or see question 5
                                                considered to be relevant by the police or                                                            from working with children in Regulated
                                                                                                    below.
                                                other government bodies. For more detailed                                                            Activity, from becoming involved in football
The Disclosure and Barring Service
                                                information about Enhanced DBS Checks                                                                 with U18s. An ‘Enhanced DBS Check with
Certificate which results from a DBS Check is
                                                please visit www.gov.uk and search for                                                                Children’s Barred List’ tells The FA if a person
a document containing confidential criminal
                                                ‘Disclosure and Barring Checks’.                                                                      is barred. The FA also uses Enhanced DBS
history information held by the police and
                                                                                                                                                      Checks for roles that are eligible.
government departments. It can be used          ¹’Barred lists’ refer’ to a list of people barred
by employers to make safer recruitment          from working with children (replacing List                                                            These checks help The FA make informed
decisions.                                      99, the POCA list and disqualification orders)                                                        recruitment decisions about the suitability of
                                                and a list of people barred from working with                                                         people with criminal records who are seeking
Disclosure information could include:
                                                adults (replacing the POVA list).                                                                     a role in under-18s’ football.
•     Details of criminal records such as
      convictions and cautions;
•     Information about a person’s inclusion
      on children’s or adults’ barred lists¹;
•     Other relevant information held by a
      local police force or government body;
•     Or state that there is no information.

                                                                                                    ¹’Barred lists’ refer’ to a list of people barred from working with children (replacing List 99,
                                                                                                    the POCA list and disqualification orders) and a list of people barred from working with adults
                                                                                                    (replacing the POVA list).

3.7   |   FA DISCLOSUR E AND BARRING SERVICE CHECKS - FAQS                                                                                                                                             2
4. DO I NEED AN                                                                                   The FA has invested considerable time
                                                                                                  consulting with stakeholders to define which
                                                                                                                                                     Ordinarily, Club Chairmen, Treasurers and
                                                                                                                                                     Secretaries do not require a check, if they are
ENHANCED DBS                                      ‘Frequently’ or ‘intensively’ are usually
                                                                                                  roles in football are unsupervised. As a result,   only or mainly administrative roles. However,
CHECK?
                                                  described as once a week or more, four days
                                                                                                  the following roles in under-18s’ football         if the people in these roles also help with
                                                  or more in one 30-day period, or overnight.
                                                                                                  should have an Enhanced DBS Check with             coaching or at matches, then they will need
There are two clearly-defined workforces          Although occasionally people with lower
                                                                                                  Children’s Barred List:                            an Enhanced DBS Check with Children’s
that will require checks:                         levels of contact may still need a check.
                                                                                                                                                     Barred List in their role as a coach, team
                                                                                                  •   Those in designated safeguarding/
•     Those working in the child workforce        Those who carry out these roles with                                                               assistant, etc.
                                                                                                      welfare officer roles e.g. Club Welfare
      in roles with under-18s in youth and/or     children frequently and are unsupervised will
                                                                                                      Officers;                                      Lots of roles do not need to have checks. For
      open-age football;                          need a Enhanced DBS Check with Children’s
                                                                                                                                                     example: you do not need to have a check to:
                                                  Barred List.                                    •   Team Managers, Coaches and
•     Those working with ‘adults at potential                                                         Assistants. This includes managers and         •   Watch your child play;
      risk of harm’ within the adults’            Supervision is defined by the legislation as:
                                                                                                      coaches who are referred to as Assistant
      workforce².                                                                                                                                    •   If you occasionally run the line;
                                                  •   Regular;                                        Managers or Coaches);
Those who are working or volunteering                                                                                                                •   If you drive your own child and his/
                                                  •   Day to Day;                                 •   Tutors, Mentors, Assessors, Sport
directly with children and young people                                                                                                                  her friends to games, if this is a private
                                                                                                      Scientists;
                                                  •   Reasonable in all circumstances for                                                                and personal arrangement with other
in football need to have an Enhanced DBS
                                                      protecting children; and                    •   Referees, Referee Mentors, Referee                 parents;
Check.
                                                                                                      Coaches and Observers in under-18
                                                  •   Carried out by someone in ‘regulated                                                           •   If your role is mainly administrative;
The Protection of Freedoms Act, 2012,                                                                 football;
                                                      activity’.
identified ‘regulated activity’ as specific                                                                                                          •   If you play alongside 16/17-year-olds in
activities, carried out frequently or                                                             •   Professional club Heads of Recruitment,
                                                  In making its decisions on which roles are                                                             adult football.
intensively, which is unsupervised.                                                                   Recruitment Officers [also referred
                                                  supervised and which are not, The FA has
                                                                                                      to as Scouts], Agents, Chaperones,             If you have been asked to have a check and
                                                  utilised the Government guidance, alongside
This includes those whose roles involve                                                               Landladies/Landlords, House Masters,           you don’t think you need one, please ring
                                                  the sport sector guidance on supervision.
teaching, training, instructing, supervising,                                                         and Host Families;                             The FA DBS Unit on 0845 210 8080 or e-mail
                                                  This was developed by the Sport and
giving advice or guidance on well-being,                                                                                                             FAChecks@TheFA.com for advice.
                                                  Recreation Alliance and the Child Protection    •   First-Aiders, Doctors, Physios and other
caring for children or driving a vehicle solely
                                                  in Sport Unit.                                      health and care professionals, as defined      If you have been asked to check certain
for children on behalf of a club or football
                                                                                                      by the Health Care Professional Council        individuals and are not sure if they need a
organisation.
                                                                                                      (HCPC) registered roles;                       check, then please speak to your County FA
                                                                                                                                                     Designated Safeguarding Officer or e-mail
                                                                                                  •   Chaplains;
                                                                                                                                                     FAChecks@TheFA.com for advice.
                                                                                                  •   Regular club drivers.
                                                                                                                                                     It is very important that people who do not
                                                                                                                                                     need a check are not required to have one,
                                                                                                                                                     as this is breaking the law and has serious
                                                                                                                                                     consequences.

                                                                                                  ² Further guidance in relation to DBS Checks will be provided for those working within the
                                                                                                  adults’ workforce.

3.7   |   FA DISCLOSUR E AND BARRING SERVICE CHECKS - FAQS                                                                                                                                            3
5. HOW DO I GET AN FA ENHANCED                                                                  6. WHAT IS THE     7. HOW MUCH DOES
DBS CHECK?                                                                                      MINIMUM AGE FOR AN IT COST?
You may have more than one role in football, but you only need one Enhanced DBS Check to        FA ENHANCED DBS    This depends on whether or not you are a
cover all your roles in football. Choose the role in which you have the most frequent contact
with under-18s from the table below.
                                                                                                CHECK?             volunteer and what application method
                                                                                                                   you use.
                                                                                                The legal minimum age is 16 years of age and
          YOUR ROLE IN FOOTBALL                              ACTION TO TAKE                     FA Policy requires DBS Checks for everyone                The Home Office is very strict in its definition
                                                                                                in an eligible role, who is 16 years or older, to         of volunteers. It defines a volunteer as:
 Grassroots under-18s coach, manager,                                                           undertake a check.                                        “Any person engaged in an activity which
                                                 Speak to your Club Welfare Officer
 first-aider or other club-based eligible role                                                                                                            involves spending time, unpaid (except for
                                                                                                                                                          travel and other approved out of pocket
                                                                                                                                                          expenses), which aims to benefit some third
 Club Welfare Officer, Youth League              Speak to your County FA Designated                                                                       party other than or in addition to a close
 Welfare Officer                                 Safeguarding Officer                                                                                     relative”.
                                                                                                                                                          The applicant must not benefit directly from
 Referee, referee mentor, referee coach,
                                                 Contact your County FA Referee                                                                           the position the DBS Check application is
 referee observer and referee tutor in U18
                                                 Development Officer                                                                                      being submitted for. The applicant must not:
 football
                                                                                                                                                          •   Receive any payment (except for travel
                                                 Ring 0845 210 8080 or e-mail                                                                                 and other approved out-of-pocket
 FA Licensed Coach applicant                                                                                                                                  expenses);
                                                 FAChecks@TheFA.com for advice
                                                                                                                                                          •   Be on a work placement;
                                                 You may not be able to get an FA Enhanced
 Working in a private soccer school or                                                                                                                    •   Be on a course that requires them to do
                                                 DBS Check. Please speak to your line
                                                                                                                                                              this job role;
 unaffiliated football                           manager or contact 0845 210 8080 or
                                                 e-mail FAChecks@TheFA.com for advice                                                                     •   Be in a trainee position that will lead to a
                                                                                                                                                              full time role/qualification.
                                                 Contact the Children’s Services Officer
 Working at a Premier League club
                                                 at your club
                                                                                                    YOU ARE           ADMINISTRATION                 GOVERNMENT                        TOTAL
                                                                                                                        FEE ONLINE                     CHARGE
                                                 Contact the Designated Safeguarding
 Working an English Football League (EFL)                                                                              APPLICATION
                                                 Officer or contact 0845 210 8080 or
 club                                                                                                                    METHOD
                                                 e-mail FAChecks@TheFA.com for advice
                                                                                                 A Volunteer         £10                            Nil                       £20 or £10 depending on
                                                                                                                                                                              application method
                                                 Ring 0845 210 8080 or e-mail
 Unsure what you should be doing?                                                                Not a Volunteer     £10                            £44                       £64 or £54 depending on
                                                 FAChecks@TheFA.com for advice
                                                                                                                                                                              application method

3.7   |   FA DISCLOSUR E AND BARRING SERVICE CHECKS - FAQS                                                                                                                                               4
If you are unsure whether or not you
are a volunteer you must contact us
                                                To make a DBS Check ‘portable’ you need to
                                                subscribe to the Update Service atgov.uk/
                                                                                                11. WHY DO SOME                                  12. WHY ARE SOME
on 0845 210 8080 for advice. Making             dbs-update-service                              CHECKS TAKE                                      PEOPLE ASKED FOR
a dishonest application may have
                                                Checks undertaken through The FA should         LONGER THAN                                      FINGERPRINTS?
                                                                                                OTHERS?
serious consequences.
                                                cover you to work in affiliated football                                                         In some cases the DBS and Police cannot
Remember, cheaper, quicker applications can     including the EFL (English Football League).                                                     confidently match the person against a
be made online. There is an easy to follow      If you are in a Premier League Club your        Delays may be due to a number of reasons:
                                                                                                                                                 record. Some names are more common than
e-guide which describes step-by-step, how to    check may cover you for Football League         •   Complex address history;                     others and there may be two or more records
use this online application process.            or FA activities. Contact your Children’s’                                                       with the same name and date of birth. The
                                                Services Officer for advice.                    •   Common name;
Your club can either speak with their County                                                                                                     Police need to use another ‘identifier’ and
FA Designated Safeguarding Officer, email                                                       •   Delays in the local Police forces and in     fingerprints are an effective way of ensuring
FAChecks@TheFA.com or ring 0845 210             10. HOW LONG DOES                                   accessing local records;                     the correct record is identified and released.
8080 for information.
                                                IT TAKE TO GET AN                               •   Incomplete forms being submitted.            This is not at all unusual and is nothing to
                                                                                                                                                 worry about.

8. WHY DOESN’T THE                              FA ENHANCED DBS                                 Club Welfare Officers should use the Online
                                                                                                                                                 If you have been asked for fingerprints and

FA PAY FOR MY DBS                               CHECK?                                          Safeguarding Service accessed via The FA’s
                                                                                                online Whole Game portal to ensure the           you want to find out more, please e-mail:
                                                                                                                                                 FAChecks@TheFA.com or ring 0845 210
CHECK?                                          Online applications take seven days to be       application progresses to an ‘Accepted’
                                                                                                status. People should be under supervision       8080 for advice and assistance.
                                                processed.
The FA has already made, and continues to                                                       until their DBS Check shows as ‘Accepted’.
make, significant investments to help make
                                                You can check the progress of your
                                                application online via the DBS website. To do
                                                                                                No-one should be allowed to work                 13. WHAT IF THERE IS
children’s football fun and safe. Investment
                                                this you need to keep the Form Reference
                                                                                                unsupervised with children, without having
                                                                                                undertaken a check and been accepted, or         SOMETHING ON THE
                                                                                                                                                 DBS CERTIFICATE?
is made in its education programmes, case
                                                Number from your paper Disclosure               whilst their check is in progress.
management services and all the other
                                                Application Form. This begins with an ‘F’ and
support services available for clubs, leagues                                                   Best practice means people should wherever       The FA is very fair and it does have a duty to
                                                has 10 digits. Click here to track progress.
and individuals.                                                                                possible help or work in pairs or groups. This   make sure the information released does not
                                                If you are using the online application         provides safeguards for everyone.                affect the safety of children. Every Disclosure
9. I HAVE HAD A                                 process you can track progress using the
                                                E-Application number emailed to you as part
                                                                                                                                                 is assessed individually taking into account

DBS CHECK FOR MY                                of the process. Click here to track progress.
                                                                                                                                                 the person’s age at the time of the incident;
                                                                                                                                                 the time expired since the conviction, the
WORK, SPORT OR                                                                                                                                   way the court dealt with the crime and other
VOLUNTARY ROLE.                                                                                                                                  relevant information.

DO I NEED ANOTHER                                                                                                                                Old offences are not viewed as seriously

ONE?
                                                                                                                                                 as recent offences. Minor and financial
                                                                                                                                                 crimes are usually not as relevant. Juvenile
The Government introduced the potential for                                                                                                      offending is generally less concerning than
portable checks via the DBS Update Service,                                                                                                      adult offending. The DBS is also undertaking
which was launched in 2013.                                                                                                                      a process to filter old and minor convictions
                                                                                                                                                 and cautions.

3.7   |   FA DISCLOSUR E AND BARRING SERVICE CHECKS - FAQS                                                                                                                                       5
Recent assaults, violence with prison              To find out more about the requirements            To start the process you can ring 0870 9090      the Whole Game System portal to check the
sentences, sexual crimes and drug supply are       on The FA to use Disclosures fairly, see           811 or visit www.gov.uk and follow the links     Online Safeguarding Service and see your
some of the concerns that are considered as        The FA’s Policy Statement on Recruiting            to ‘Employing People’ and then ‘Recruiting       Disclosure has been ‘Accepted’ by The FA.
a higher risk.                                     Ex-Offenders: Guidance notes 3.8 at                and Hiring’.                                     This system can also show the club your
                                                   TheFA.com/governance/safeguarding                                                                   Safeguarding Children training record.
The FA will sometimes contact you about                                                               Sometimes The FA DBS Unit disputes a
                                                   or visit www.gov.uk and follow the links to
convictions or information on your DBS                                                                Disclosure because the postcode is wrong         If there is a criminal history, a set process
                                                   ‘Employing People’ and then ‘Recruiting and
Certificate and ask you to provide two                                                                or a name has been printed incorrectly by        will be followed. For more about this
                                                   Hiring’. This website can also put you in touch
character references. This is to reassure The                                                         the Home Office. This may result in a second     see question 13 above: ‘What if there is
                                                   with organisations that support ex-offenders.
FA you are now suitable to be involved in                                                             Disclosure being issued to you with the          something on The FA DBS Check?’
children’s football and that your convictions,                                                        correct information. If this happens you are
or other information are not relevant to the       14. WHAT POLICE                                    advised to destroy the first one.
                                                                                                                                                       If you are suspended, your club and County
                                                                                                                                                       FA will be told of the suspension.
welfare of under-18s in football. If you are
                                                   NATIONAL COMPUTER
                                                   (PNC) INFORMATION 17. WHO WILL SEE
asked for this information it is very important
you provide it quickly. The FA may suspend                                                                                                             18. WHAT HAPPENS
people who do not reply to these requests          WILL BE FILTERED   MY DISCLOSURE?                                                                   IF I CHANGE CLUBS
                                                   FROM INCLUSION ON As                                                                                OR REGISTER WITH A
for information.
                                                                          of June 2013 only The FA may request
The final decision will be made by an
independent Panel of people including              A DBS CERTIFICATE? to see your original Disclosure to update
                                                                       its records. Please comply swiftly when                                         NEW COUNTY FA?
individuals with relevant professional             For more information visit:                        this happens.                                    Speak to the Club Welfare Officer at your
expertise and understanding of football who        gov.uk/government/publications/dbs-                                                                 new club. They can access The FA’s Online
                                                                                                      You should not be asked by your Club
are fair and careful in their decision making.     filtering-guidance/dbs-filtering-guide                                                              Safeguarding Service via Member Services
                                                                                                      Welfare Officer or anyone else in your
Occasionally The FA may make a decision                                                               club to show your check. The Club can            to ensure that your Disclosure has been
that a person should be suspended while            16. WHAT IF THE                                    access the details they need by using the        accepted. You will need to provide evidence

                                                   INFORMATION
these enquiries are carried out. If this                                                              Whole Game System portal to check the            of your identity, but not your Disclosure
happens you will be given clear information                                                           Online Safeguarding Service. You do not          certificate. You do not need to show your
about what you may and may not do in               ON DBS CHECK IS                                    need to show your check to anyone outside        Disclosure to anyone outside of The FA’s
football and how to progress your situation.
                                                   WRONG?                                             of The FA’s recruitment process.                 recruitment process.
                                                                                                                                                       Clubs may ask you to have a new check
When the enquiry process is complete and                                                              The FA may however, ask you to share
                                                   You need to tell the DBS immediately. The                                                           especially if your previous one is over three
The FA is satisfied, the Disclosure will be                                                           your copy with the County FA Designated
                                                   DBS refer to this process as a ‘Dispute’. If you                                                    years old. This is nothing to worry about and
treated as if it were clear of convictions. This                                                      Safeguarding Officer, or in the EFL
                                                   wait more than 90 days information cannot                                                           is simply FA Policy.
means The FA Online Safeguarding Service                                                              (English Football League), the Designated
                                                   be changed.
will be updated to show you as ‘Accepted’ in                                                          Safeguarding Officer as they may be directly     If you move County FAs (e.g. as a referee),
football and your Disclosure will be shredded      It is very important to tell the DBS as you        involved with assessing your suitability to be   your new County FA can access your
in accordance with the law. You will receive a     might find the wrong information affects           involved in under-18s’ football.                 previous records. However, depending on
letter telling you when this happens.              your ability to have a role in under-18s                                                            when your check was done, they may require
                                                                                                      If there is no relevant criminal history a
                                                   football or to get a job elsewhere.                                                                 you to complete an updated one.
To speak to someone in confidence about                                                               record will be kept stating that you have
your history or to ask more about this             Information about how to contact the DBS           completed the DBS Check process and
process please call The FA DBS Unit enquiry        will be on the back of your Disclosure.            there is currently no known reason why you
line on 0845 210 8080 or e-mail FAChecks@                                                             should not be accepted into football. Club
TheFA.com with your query.                                                                            Welfare Officers and County FAs can use

3.7   |   FA DISCLOSUR E AND BARRING SERVICE CHECKS - FAQS                                                                                                                                             6
19. WILL I NEED                                    21. HOW DO I MAKE A
TO RENEW MY DBS                                    COMPLAINT?
CHECK?                                             To make a complaint about any aspect of The
                                                   FA DBS process please contact The FA DBS
Given that a DBS Check is a snapshot in time
                                                   Unit by emailing FAChecks@TheFA.com or
and therefore potentially only accurate
                                                   calling 0845 210 8080. Alternatively, write
at the time it was printed, it is FA Policy to
                                                   to:
require checks to be renewed every three
years.                                             Complaints
                                                   The FA DBS Unit
All checks must be ‘in-date’ by three years
                                                   1 Wilford Business Park
at the point of affiliation and/or registration,
                                                   Ruddington Lane
and/or licensing.
                                                   Nottingham NG11 7EP
The FA’s Policy requires that rechecks of
                                                   The FA DBS Unit will direct your complaint
the status of those who have subscribed to
                                                   to the appropriate person.
the DBS ‘Update Service’ will be undertaken
every 12 months.

20. WHERE CAN I GET
MORE INFORMATION?
For more about the DBS Check process
visit www.gov.uk and follow the links to
‘Employing People’ and then ‘Recruiting and
Hiring’. This website also carries information
about organisations that support ex-
offenders.

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