Recurring concern
Unreliable criminal-conviction vetting for safety-sensitive roles
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Request correctionFirst reported 12 May 2015•Latest report 13 Feb 2023
What this concern includes
Includes failures in obtaining, checking, accurately recording, interpreting or considering domestic or foreign criminal-conviction information through DBS or equivalent vetting arrangements before appointment or continued authorisation for roles involving firearms, vulnerable people or comparable safety-sensitive responsibilities.
Not included
- Excludes general recruitment, character assessment or professional-competence concerns where criminal-conviction vetting is not the deficient control.
- Excludes failures to apply employment restrictions after accurate and complete conviction information has been obtained and considered.
- Excludes ordinary police crime-recording and offender-management processes unless they directly impair conviction information used for safety-sensitive vetting.
- Excludes routine background checks for roles without a material firearms, vulnerable-person or comparable public-safety responsibility.
- Reports
- 4
- Individual concerns
- 4
- Date range
- 2015–2023
- Stated actions
- 1
Distinct published reports
A report can raise multiple concerns
First to latest report issue date
Described in published responses
Reports over time
Reports over time
Reports about this concern issued each year.
* 2026 is projected from reports observed to 7 Sep 2026.
Most frequent recipients
Most frequent recipients
Reports about this concern sent to each recipient.
Concerns and responses across reports
Only concerns grouped under this recurring concern are included. Select any concern, action or position to view the source wording.
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Concerns raised1
Failure of DBS certificates to accurately record relevant convictions
Responses linked to these concernsEach statement is shown once, even when linked to more than one concern.
No linked response statementsNo respondent-stated action or position is linked to these concerns in the published data.
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Concerns raised1
Lack of a statutory procedure for checking criminal convictions outside the UK
Responses linked to these concernsEach statement is shown once, even when linked to more than one concern.
Actions described in response An action is something a respondent says it has done, is doing, or plans to do in response to the concern raised.1
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Action
Publish advice on obtaining overseas criminal-record checks and link to relevant Home Office guidance on the DBS website.
Stated by Disclosure and Barring Service
Respondent positions A position is what a respondent says about the concern when they do not describe a specific action.3
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Position
Existing statutory arrangements allow overseas criminality information to be disclosed, while employers can obtain further overseas checks as part of recruitment risk assessment.
Stated by Disclosure and Barring Service
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Position
Further statutory obligations concerning overseas criminal-record checks are matters for the Home Office and Parliament.
Stated by Disclosure and Barring Service -
Position
Reliable international data flows cannot be established because necessary agreements and cooperation with overseas law-enforcement agencies are unavailable.
Stated by Disclosure and Barring Service
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Concerns raised1
Failure to obtain and consider DBS certificates for proposed Nominated Individuals
This report raised 1 other concern. They are not shown here because they do not form part of this recurring concern.
Responses linked to these concernsEach statement is shown once, even when linked to more than one concern.
Respondent positions A position is what a respondent says about the concern when they do not describe a specific action.4
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Position
CQC will not directly check nominated individuals’ DBS records because it lacks power to approve or refuse their appointment as nominated individuals.
Stated by Care Quality Commission
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Position
Providers are responsible for assessing nominated individuals’ suitability and conducting appropriate enquiries, including DBS checks where necessary.
Stated by Care Quality Commission -
Position
Providers remain responsible for managing and delivering care; CQC should not oversee providers’ management decisions.
Stated by Department of Health and Social Care -
Position
The existing nominated-individual arrangements and CQC’s general powers provide proportionate assurance, so the system should be maintained.
Stated by Department of Health and Social Care
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Concerns raised1
Unavailability of enhanced criminal-record disclosures for overseas armed private security employment
This report raised 15 other concerns. They are not shown here because they do not form part of this recurring concern.
Responses linked to these concernsEach statement is shown once, even when linked to more than one concern.
Respondent positions A position is what a respondent says about the concern when they do not describe a specific action.1
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Position
Employment of security and close protection personnel outside the United Kingdom falls outside the Home Office’s and SIA’s jurisdiction.
Stated by Home Office
Data last updated 7 September 2026