Because the public sector tends to be self-sufficient when it comes to Criminal Records Bureau (CRB) checks, checking services are not receiving many applications from the sector.
This is worrying as I doubt whether managers have really got their minds around the full impact of the impending scheme, which comes into place on 26 July.
The burden of the scheme (which regulates all those working with children and vulnerable adults) comes in several parts. Initially, there's carrying out the registration with the Independent Safeguarding Authority (ISA). The timetable runs to 2015, with each employee's registration keyed to job change or the date of their last CRB. This demands careful scheduling or mass registration, not to mention deciding whether to pay for it, at upwards of £64 per head.
Managers must also try to foresee the impact of problems with registration. What do they do if an existing employee is barred? How will they manage delay or an error by the ISA? Given the issues in the past with major IT-based innovations (I'm thinking of the changes to the issue of CRBs and passports), organisations need to have some contingencies laid down.
Increased demand
If an organisation is registered to carry out CRB checks directly then it will need to re-engineer its provision to allow for a major hike in demand from colleagues. If not, managers must review current suppliers to ensure they are able to cope both with an inundation of applications and increased demand for added-value support.
And if the service is sold to external customers, it is imperative to review its continuing viability. Staffing levels and skills will need to be cranked up, any service promise revisited and the duty to protect the organisation demands new terms of business to address the issue where non, or underperformance leads to potential liability.
Toxic threat
Perhaps the most toxic threat to managers is the new duty to refer. Where one thinks that there may be a risk of harm, an invasive new process is triggered. Employees must be suspended or moved to work not involving children or vulnerable adults. An investigation will determine the reality of that risk. If it leads to a manager thinking the risk is genuine, the person must be permanently removed from regulated activity and referred to the ISA.
The impact of this will be readily appreciated, ramifying on job descriptions of senior managers, disciplinary and grievance procedures, and contracts of employment.
Above all, managers must remember this. Failure to meet the demands of the new scheme creates criminal liability, with prison and hefty fines flowing (not to mention unemployment) from a guilty verdict.
Barry Clark is co-author of Vetting and Barring – a practical guide to the new CRB/ISA scheme. A former superintendent of the Metropolitan Police Force, Clark is of the UK's leading experts in vetting and Criminal Records Bureau checks
From Bubb's Blog
From Whitehall Watch
