Recruitment & WorkforceRegulation & CQC

DBS checks are an important part of safer recruitment in care, but they are only one part of the picture. As identity fraud evolves and recruitment becomes increasingly digital, care providers need to know they are checking the right person, carrying out the right checks for the role and maintaining a clear record of the decisions behind each hire.

Recruiting into care comes with a particular responsibility. Employers need people with the right skills and experience, but they also need recruitment processes that help establish whether someone is suitable to work with people who may be vulnerable.

For care providers regulated by the Care Quality Commission (CQC), this is reflected in Regulation 19. Providers must establish and operate effective recruitment procedures and confirm specified information about candidates before they are employed. CQC guidance also makes clear that where recruitment checks are carried out by another party, the provider still needs to assure itself that those checks are complete and satisfactory.

That makes safer recruitment much broader than completing a DBS application.

A strong process brings together identity, criminal-record checking, Right to Work, employment history, references and, where relevant, professional registrations or qualifications. Just as importantly, employers need to understand what each check establishes, what it does not, and which checks are appropriate for the particular role.

Start with the role, not the check

It can be tempting to think of a DBS check as a standard requirement for anybody joining a care organisation. In practice, the level of DBS check an employer can request depends on the role and the activities the individual will undertake.

A Basic DBS check can be requested for any position or purpose and shows relevant unspent convictions and cautions.

A Standard DBS check is only available for eligible positions and shows spent and unspent convictions and adult cautions held on the Police National Computer, subject to filtering rules.

An Enhanced DBS check is also restricted to eligible roles. It contains the relevant information included at Standard level and may include information held by police that is considered relevant to the role.

Where a role is eligible, an Enhanced check may additionally include a check of the Children’s and/or Adults’ Barred List. For the adult workforce, regulated activity can include activities such as providing healthcare or personal care in the circumstances set out in legislation and DBS guidance.

This distinction matters. DBS warns that knowingly requesting a higher-level check than the legislation permits is unlawful. Care providers should therefore assess the duties of the role against current DBS eligibility guidance rather than assuming that every person working within the same organisation requires an identical check.

Identity comes before the DBS result

Before asking what a DBS certificate says about an applicant, there is an even more fundamental question: are you confident the person being checked is who they say they are?

That question is becoming increasingly relevant as identity fraud evolves. According to Cifas, nearly 130,000 identity-fraud cases were recorded to the UK National Fraud Database in the first half of 2026, a 9% increase on the same period in 2025. Cifas has also highlighted growing concerns around synthetic identities, AI-enabled impersonation and digitally manipulated documents.

These figures are not specific to recruitment or the care sector, but they illustrate a wider change in the identity-risk landscape. Visual document checking alone is increasingly being supplemented by digital verification designed to establish a higher level of confidence in someone’s identity.

For care providers, identity is particularly important because it sits underneath other parts of screening. If the identity information supplied is inaccurate, the integrity of checks that rely on that information can also be affected.

DBS itself recognises this. Identity verification forms part of the DBS application process, and its digital identity guidance sets minimum confidence levels for digital verification. Standard, Enhanced and Enhanced with Barred List applications require a High level of confidence through the digital route.

This is where technology such as DBS HI-ID from EBC Global. can support the process. Rather than treating identity verification, Right to Work and the DBS application as disconnected stages, HI-ID brings them into an automated digital journey, with candidate consent, live selfie and identity-document capture forming part of the process.

Safer recruitment in care. Process showing identity, Right to Work, DBS and employment screening checks

The objective isn’t automation for its own sake. It is to establish greater confidence in who is actually being screened while reducing unnecessary manual administration.

DBS and Right to Work answer different questions

This distinction is particularly important.

A DBS check helps an employer make a safer recruitment decision by providing criminal-record and, where eligible, barred-list information.

It does not establish that somebody has the right to work in the UK. DBS explicitly states that a separate Right to Work check is required.

Employers must therefore carry out the appropriate Right to Work check before employing someone. Current Home Office guidance provides different routes depending on the individual’s circumstances. These include a manual document check, a Home Office online Right to Work check and, for eligible British and Irish citizens, a digital identity check using an Identity Service Provider.

Bringing identity, Right to Work and DBS processes into a connected digital journey can reduce duplication and make administration easier, but they remain distinct checks with different purposes.

That distinction should be reflected in recruitment policies, workflows and staff training. Technology can connect the journey, but employers still need to understand what each check establishes and why it is being carried out.

Bringing the screening journey together

For care providers, a criminal-record check should not become a substitute for the rest of the recruitment process.

CQC’s Regulation 19 guidance specifically refers to areas including qualifications, competence, skills and experience, full employment history where required and relevant professional registration.

As with DBS eligibility, additional screening should reflect the role and circumstances. This might include employment history verification, references, or other role-specific checks.

The challenge is not simply completing those checks, but deciding what needs to be established for each role and managing those checks as part of a consistent process.

A role-based approach can help avoid two opposite problems: missing an important check, or collecting information that isn’t necessary for the role.

Technology can then help bring the relevant stages together. Rather than treating DBS, identity verification, Right to Work and wider employment checks as disconnected processes, screening workflows can be structured around the requirements of the role, reducing unnecessary manual hand-offs and giving recruitment and people teams greater visibility.

What about DBS Adult First?

There are also exceptional circumstances where an eligible employer may use DBS Adult First while the full Enhanced DBS process continues.

Adult First is available where strict criteria are met, including that the position requires a criminal-record check by law, is eligible for access to the Adults’ Barred List and the employer has requested an Adults’ Barred List check as part of the DBS application.

The result will state either that the Registered Body must wait for the DBS certificate or that no match exists for the person on the current Adults’ Barred List.

Crucially, Adult First is only the first part of the criminal-record checking process. A “no match” response is not an Enhanced DBS certificate and does not provide the wider criminal-record or relevant police information that may appear on the completed certificate. Depending on the result and circumstances, an employer may decide to allow the individual to begin work under supervision, but the full DBS process still needs to continue.

Care providers should therefore view Adult First as an option available in eligible circumstances, not as a general replacement for completing the appropriate Enhanced DBS process.

Consistency matters as much as speed

Faster checks can be useful, but speed isn’t the only measure of an effective screening process. Visibility matters too.

See what is happening

When several people are moving through recruitment, those responsible for screening need to understand who has completed their checks, what is still outstanding and where action may be required.

Screening technology can bring those stages together. EBC Global’s employment screening platform, for example, provides candidate progress tracking and status updates, helping teams see what has been requested, completed or still requires attention.

Reduce repetitive administration

Workflows can be configured around the checks required for particular roles, while automation can handle repetitive tasks such as application and form reminders. This can reduce reliance on manual chasing while recruitment and People teams retain oversight.

A guided digital journey can also make the process easier for candidates, with features such as secure document upload, digital forms, progress updates and auto-save functionality.

Keep a clearer record

Visibility shouldn’t stop once the checks are complete. A Final Vetting Report can bring completed background checks, screening results and compliance certificates into a single downloadable report, giving teams a clearer record of the screening completed for an individual.

For care providers, that can make completed screening easier to review and evidence without changing who makes the final recruitment decision.

Automation doesn’t remove accountability

Human judgement remains essential. Technology cannot decide whether a particular DBS level is legally appropriate for a role, assess the significance of information disclosed during recruitment or determine whether an individual is ultimately suitable to work within a care setting.

Those decisions remain with the employer.

A useful question for care providers

Rather than asking simply, “Have we completed the DBS check?”, there is a broader question care providers can ask:

“Can we clearly demonstrate that we checked the right person, carried out the right checks for the role and made an informed recruitment decision?”

That changes the focus from completing an individual check to building a safer recruitment process.

It means establishing identity accurately, choosing the appropriate DBS level, confirming Right to Work separately, completing relevant employment and role-specific checks, maintaining visibility while those checks are underway and keeping a clear record of what was completed.

Technology can make that journey more consistent and less administratively demanding. Digital identity verification can strengthen confidence at the beginning of the process. Automation and progress tracking can provide greater visibility while screening is underway. And structured reporting can bring the evidence together once screening is complete.

But the foundation remains the same: understand the role, understand what each check tells you, and make informed recruitment decisions based on the complete picture.

Author/company bio

EBC Global provides automated employment background screening software solutions for employers, recruiters and compliance teams. Its solutions support DBS checks, digital identity verification, Right to Work, references and wider pre-employment screening, helping organisations manage candidate screening with greater automation, visibility and consistency.

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