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Bookshop potentially undertaking ineligible DBS checks

We were recently contacted by an individual who was considering applying for a job as a manager in a charity bookshop but had been concerned about the level of criminal record check that the company had requested. They stated that:


xxxx takes its obligation to protect the rights of children and vulnerable people very seriously; therefore the successful candidate for this post will be subject to extensive background checking, including a Disclosure and Barring Service check (DBS), as this role involves unsupervised access to the above-mentioned groups.


The potential applicant had contacted the shop to request further information about the ‘unsupervised access’ element of the job and was told that:


I can confirm that the shop manager’s role does not involve looking after children. It does, however, involve managing young volunteers some of whom can be as young as 14, and a diverse range of adult volunteers, some of whom are vulnerable adults with specific needs. Hence the reason that this wording is put in the advert, to advise applicants that we require all shop staff to undergo a DBS check.


We sought guidance from the Disclosure and Barring Service who confirmed that in order to carry out an enhanced criminal record check an applicant would need to be in “regulated activity” with children. The role would need to involve supervising/caring for children frequently (one a week or more), intensively (four or more times in a 30 day period) or overnight (between 2am and 6am). The DBS stated that an organisation would not be able to state that this ‘might happen’.

We contacted the bookshop to raise our concerns with them.

The bookshop replied to us and confirmed that their shops had a significant number of volunteers under the age of 18 many of whom would be working towards the Duke of Edinburgh awards. In addition to this, several local schools have placement schemes running in the bookshop. Shop managers would therefore be responsible for supervising these under 18’s.


This case demonstrates how, on the face of it, employers often assume that an enhanced check is the right one to do, yet it’s often more complex than that and it depends on the specific details of the role.


Notes about this case study

This case study relates to Unlock’s work with organisations.

Names and details have been changed to protect the identity of those involved.

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