Introduction

Safer Recruitment is a vital factor in keeping apprentices and young people safe within the education environment. It is essential that when Accountancy Learning employs staff, uses contractors or engages volunteers to work with apprentices or young people, that it adopts a consistent and rigorous approach in the recruitment and selection process. The aim is to ensure that those recruited are suitable for such an important and responsible role.

The purpose of safer recruitment is ultimately to:

Deter:

From the beginning of the recruitment process, it is important to send the right message – that the organisation has a rigorous recruitment process and does not tolerate any form of abuse. Wording in adverts and recruitment information must aim to deter potential abusers.

Identify and Reject:

It will not always be possible to deter potential abusers. Therefore, careful planning for the interview and selection stage, in terms of asking the right questions, setting appropriate tasks and obtaining the right information can assist in finding out who is suitable for the role and who is not.

Prevent and Reject:

There are no guarantees that even the most robust safer recruitment process will prevent an inappropriate appointment. However, this does not mean it is too late to act. Ensuring that comprehensive induction and probation processes are in place, together with appropriate policies and procedures, raising awareness through staff training and generally developing and maintaining a safe culture within the organisation will all help to prevent abuse or identify potential abusers.

The intention of this policy is to ensure that all stages of the recruitment process contain measures to deter, identify, prevent and reject unsuitable people from gaining access to apprentices and young people during their training with Accountancy Learning. This policy and the practical implementation of recruitment and selection processes also aim to meet all legislative requirements, any statutory or other guidance that may from time to time be issued in order to keep apprentices and young people safe, as well as principles of general good practice.

Scope

The document contains the protocols for Accountancy Learning to follow in order to comply with legal duties, to ensure the recruitment process is transparent and fair and to ensure that the welfare of apprentices and young people in our care are protected. Everyone within the Accountancy Learning team has a responsibility to adhere to it.

Roles and Responsibilities

It is the responsibility of Accountancy Learning to:

• Ensure Accountancy Learning has effective policies and procedures in place for recruitment of all staff and volunteers in accordance with current guidance and legal requirements.
• Monitor Accountancy Learning’s compliance with them.

It is the responsibility of Prue Deane (Director) and Jackie Salter (HR Manager) and other staff involved in recruitment to:

• Ensure that Accountancy Learning operates safe recruitment procedures and makes sure all appropriate checks are carried out on all staff who work for Accountancy Learning.
• To monitor contractors’ and agencies’ compliance with this document.
• Promote welfare of apprentices and young people at every stage of the procedure. The School Staffing (England) Regulations 2009 require governing bodies of maintained educational organisations to ensure that at least one person on any appointment panel has undertaken safer recruitment training. In keeping with this guidance, Accountancy Learning has delegated responsibility to Jenna Mayne to lead in all appointments. Other staff may be involved in staff appointments, but the final decision will rest with Prue Deane, Simon Deane and Jenna Mayne.

The Recruitment Process

Recruitment panel members will be appropriately trained or briefed. In accordance with statutory requirements, at least one member of the panel will have successfully completed safer recruitment training. Several key employees have now undertaken this necessary training.

Job Descriptions and Person Specifications

A job description is a key document in the recruitment process and must be finalised prior to taking any other steps in the recruitment process. It will clearly and accurately set out the duties and responsibilities of the job role. The person specification is of equal importance and informs the selection decision. It details the skills, experience, abilities and expertise that are required to do the job. The person specification will include a specific reference to suitability to work with apprentices and young people.

Application Forms

A suitably-structured, pre-defined application form will be used for recruitment to all posts including volunteers. CVs in isolation will not be accepted because CVs are left to the discretion of individual applicants and contain only information that they choose to provide whereas application forms are employer-led, requiring specific information from all applicants. The use of application forms will help to ensure that detailed information, critical to the recruitment process, can be gathered from all applicants in a consistent format. This will also help to identify any gaps in employment which should then be clarified with the applicant at interview. Applicants will be asked to complete and return the company application form when an interview has been scheduled to be received in advance of the interview.

Advertising

To ensure equality of opportunity, Accountancy Learning will normally advertise all vacant posts to encourage as wide a field of applicants as possible. This normally entails an external advertisement unless a decision has been made to recruit internally to a vacant post. All documentation relating to applicants will be treated confidentially in accordance with the Data Protection Act (DPA).

Safeguarding

The job advertisement provides potential applicants with their first impression of Accountancy Learning. An important part of the message of the advert is to inform anyone viewing it that our organisation is fully committed to safeguarding and protecting the welfare of apprentices and young people. In these circumstances, all advertisements will include a statement to the effect that: “Accountancy Learning is committed to safeguarding and promoting the welfare of apprentices and young people. Therefore, we expect all workers and employees to share this commitment”.

Other general statements applicable to all posts may also be included in the wording of advertisements, e.g. “All appointments are subject to satisfactory pre-employment checks, including a satisfactory Enhanced criminal records with Barred List check through the Disclosure and Barring Service (DBS).” AND “CVs alone will not be accepted.”

Prospective applicants for posts will receive the following materials in recruitment packs (to be sent when interview is scheduled) by Bev Chambers (PA):

• Application Pack (including Application form, Job Description, Company Safeguarding Policy and guidance/details for the next stage of application process)
• Any other relevant details or documentation.

Equal Opportunities

Each advert will contain a statement similar to the following: “Accountancy Learning is committed to being an equal opportunity employer”.

Our full Equal Opportunities statement is on our company website.

Shortlisting

To support safer recruitment and to ensure fairness in the process, the recruitment panel should take adequate time to properly scrutinise the applications.

• For consistency it is recommended to assess each application against the criteria, including criteria specific to working with children through the use of a checklist.
• Consider whether each application is fully completed – if not, it may be returned to the applicant or discarded from the process.
• Highlight any gaps (in employment etc.) to be explored further at interview should the candidate be long/shortlisted.
• Look for evidence provided against the criteria set out in the person specification and the job description.
• Normally only shortlist those applications that meet all the essential criteria set out in the person specification. However, if this is not clear in relation to any applications, it may be decided to shortlist and explore the issues further at interview.

Invitation to Interview

Interview invitations to shortlisted candidates will normally include the following:

• Details of date, time, venue (if not taking place online).
• Direction and/or map, together with details of parking arrangements (if applicable)
• Where to report on arrival (if applicable).
• Likely length of the interview and information about any tests or exercises to be included in the process.
• The company application form and confirmation of date for the application form to be completed and returned by and to whom.
• Details of the scope of the interview (to be based on the person specification and to include exploration of each candidate’s suitability to work with apprentices and young people, together with any issues arising from the application form or references).
• Details of documents that candidates will need to bring with them, e.g. proof of identity, documents for the Immigration, Asylum and Nationality check (Right to work check).
• Company Self Disclosure form – to be completed and returned with the application form.
• A request that candidates let Accountancy Learning know should they have any special requirements, or need any adaptations, to enable them to access the interview and selection process.
• A request that candidates inform Accountancy Learning of their intention to attend, or otherwise, together with the necessary contact details.

Interviews

The recruitment and selection process, in particular interviews, will normally be carried out by two or more people and may involve a 2nd interview. A set of the same basic questions to ask all shortlisted candidates should be prepared in advance. However, additional follow-up questions are likely to be needed at the interview itself as a means of probing for additional information. These questions will depend upon initial responses given by individual candidates. Interviews will be used to:

• Focus on the requirements to carry out the duties of the job, as described
• Explore issues relating to the safeguarding and promoting the welfare of apprentices and young people (especially for Tutor roles), including:

• Motivation to work with apprentices and young people
• To test attitudes, awareness and understanding of safeguarding
• Ability to form and maintain appropriate relationships and personal boundaries with apprentices and young people
• Emotional resilience in working with challenging behaviours
• Attitudes to use of authority and maintaining discipline.

A specific Safeguarding question will be asked to check the candidate’s understanding of Safeguarding. This question will be asked by a panel member who is ‘Safer Recruitment’ trained. Safeguarding questions will examine the candidates understanding of the Accountancy Learning Safeguarding Policy which the candidate will have read as part of the application pack.

• To explore any relevant issues arising from references received prior to the interview.
• To investigate any gaps in employment, which will require the applicant’s date of birth to be able to do this effectively.

Employment Checks

DBS Security Checks:

All employees and paid workers at Accountancy Learning who are in regulated activity will have an Enhanced DBS with Barred List check (formerly List 99) carried out. This will include anyone who is involved in teaching or supervising apprentices and young people (including exam invigilators).  For any support/other staff who are not directly involved in this activity but may come into contact with young persons, they will have a standard DBS check (as advised by DCC DBS).

NEW DBS Security Checks:

New DBS checks will be completed when:

• A person moves to a new role which gives greater access to apprentices and young people or has more responsibility.
• The person has a break from employment for more than three months.
• There are concerns about the person, which may affect their suitability.

DBS Certificates

The DBS now issues a DBS disclosure certificate to the subject of the check only, rather than to the Employer. Except in exceptional circumstances, it is a condition of employment with Accountancy Learning that the original disclosure certificate is presented to Accountancy Learning after it has been received by the applicant. Applicants who are unable to attend Accountancy Learning premises in person to provide the certificate are required to send in a copy by post or email before, or as soon as practicable after, the person’s appointment and a teams appointment will be made with Bev Chambers or Jackie Salter to enable them to view the original.  Copies will not be retained as per Government guidance, but a record of the Certificate number and date of issue will be recorded.

Enhanced DBS certificates will be required for any employee who will be working within a role involving apprentices and young people (see page 6 and above).

Copies must be sent to: Bev Chambers, Jackie Salter or Prue Deane . Employment will remain conditional upon the certificate being presented and it being considered satisfactory by Accountancy Learning.

Frequency of DBS certificate updates: Accountancy Learning has encouraged all employees to subscribe to the DBS Update Service and new enhanced DBS certificates will be re-applied for at 2 yearly intervals during an employee’s service with Accountancy Learning.

Children’s Barred List Checks

Accountancy Learning is under a specific duty not to allow a barred person to work in regulated activity. Children’s Barred List checks are completed through the process of an enhanced DBS with a Children’s Barred List check. Isolated Barred List checks only check whether a person has been barred from teaching children and does not check all of the Children’s Barred Lists. Therefore, it should not be relied upon in isolation for substantiating the suitability of a person to work with children.

Offers of Employment

Any offer of appointment made to a successful candidate, including one who has lived or worked abroad, must be conditional on satisfactory completion of the necessary pre-employment checks.

• Verify a candidate’s identity: Identification checking guidelines can be found on the GOV.UK website. As part of the new DBS process- the Applicant uploads their own ID documents.
• Obtain a certificate for an enhanced DBS check which will include barred list information, for those who will be engaging in regulated activity using correct identification.
• Obtain a barred list check if an individual will start work in regulated activity before the DBS certificate is available.
• Verify the candidate’s mental and physical fitness to carry out their work responsibilities, if appropriate for the role. A job applicant can be asked relevant questions about disability and health in order to establish whether they have the physical and mental capacity for the specific role. A satisfactory medical assessment, which may include a questionnaire and / or with the applicant’s permission and at the cost of Accountancy Learning, a medical assessment with an Occupational Health Provider or information from a G.P.
• Verify the person’s right to work in the UK. Receipt of evidence to meet the requirements of the Immigration, Asylum and Nationality Act 2006 if applicable; valid Home Office (UK Visas and Immigration) permission to work in the post, if there is uncertainty about whether an individual needs permission to work in the UK – guidance can be followed on the GOV.UK website. This must be a form of photographic ID. Bev Chambers/Jackie Salter will view and verify all new starters original right to work documents and record details as applicable. This could be via a teams meeting if a remote member of staff, or face to face if possible.
• If the person has lived or worked outside the UK, make any further checks considered appropriate so that any relevant events that occurred outside the UK can be considered.
• Verify professional qualifications, as appropriate. Copies of all relevant certificates will be required, including confirmation of the Level 3 award in Education and Training or any other teaching qualifications. A copy is taken and retained on the personnel file. Verification of professional qualifications, where appropriate which will include further verification if there is concern about their validity. Where qualifications are a requirement or relevant for the post, successful applicants are asked to present the originals of the qualification document in person whenever possible. If this is not possible then copies should be sent to Bev Chambers and then originals can be viewed online during a teams meeting by Bev/Jackie Salter.

Other Conditions to Offers of Employment

Any job offers made must be conditional as it will be subject to a variety of pre-employment checks and other conditions.

• Two satisfactory references, one of which should be the current or most recent employer.
• If there is a delay in receiving a DBS disclosure, Accountancy Learning has discretion in exceptional circumstances, to allow an individual to begin work pending receipt of the disclosure but with limited access to certain IT systems until the DBS is received. This will only be allowed if all other checks have been completed and once appropriate supervision has been put in place along with a full risk assessment with risk management measures in place. Accountancy Learning is under a specific duty not to allow a barred person to work in regulated activity.

Conditional Offer Letters

Conditional offer letters will include the following:

• Job title/role and mutually agreed start date
• Relevant details relating to the position, e.g. type of contract and hours, if fixed term details of expiry date and/or circumstances/conditions
• Pay and conditions of service applicable
• Payment arrangements and a request for account details, P45 (of HMRC Checklist) and National Insurance number (not on offer letter but requested as part of the pre recruitment process).
• Pre-employment checks that need to be satisfactorily carried out before the offer can be finally confirmed (see above)
• Any other relevant action to be taken or information to be provided. In circumstances where any of the pre-employment checks prove to be unsatisfactory, a conditional offer will be withdrawn where Accountancy Learning considers it appropriate to do so.

Offer Letters

Accountancy Learning will issue every new employee with an employment offer letter. The purpose of the offer letter is to set out basic terms of employment and will inform prospective employees that they’re being offered the position for which they applied; they also inform a prospective employee of general expectations and conditions, should the prospective employee accept the offer.

Contracts of Employment

Accountancy Learning must give employees a contract of employment if their employment contract lasts at least a month or more. The legal parts of the contract are known as ‘terms’.

Accountancy Learning contracts of employment will include:

• the business’s name
• the employee’s name and home address
• job title or a description of work and start date
• how much and how often an employee will get paid
• hours of work (and if employees will have to work Sundays, nights or overtime)
• holiday entitlement (and if that includes public holidays)
• where an employee will be working and whether they might have to relocate
• if an employee works in different places, where these will be and what the employer’s address is
• notice periods
• collective agreements
• who to go to with a grievance

Sometimes terms do not have to be specifically written down but will still be covered by an implied term for example:

• the implied mutual duty of trust and confidence where employees and employers are bound by an implied term that they will not, without reasonable and proper cause, act in a manner calculated or likely to destroy or seriously damage the relationship of mutual trust and confidence between them
• employees should not steal from their employer
• the employer should provide a safe and secure working environment
• something necessary to do the job like a driver having a valid license

The written statement doesn’t need to cover the following (but it must say where the information can be found):

• sick pay and procedures
• disciplinary and dismissal procedures
• grievance procedures.

References and Employment History

All offers of employment will be subject to the receipt of a minimum of two references which are considered satisfactory by Accountancy Learning.

One of the references must be from the applicant’s current or most recent employer. Neither referee should be a relative or someone known to the applicant solely as a friend.

Accountancy Learning will always ask for written information about previous employment history (including start and end dates of employment) and check that information is not contradictory or incomplete. References will be sought when the offer of employment has been accepted by the applicant, any issues of concern can be raised and explored further with the referee and taken up with the applicant if necessary.

On receipt, references will be checked to ensure that all specific questions have been answered satisfactorily. The references will also be compared for consistency with the information provided by the candidate on their application form. Any discrepancies will be taken up with the candidate. Accountancy Learning will take reasonable steps to ensure that the provided referee’s contact details are legitimate. All referees will be asked whether they believe the applicant is suitable for the job for which they have applied and whether they have any reason to believe that the applicant is unsuitable to work with apprentices and young people.

Sometimes, a referee may not be willing to complete a standard reference questionnaire. This may be because a particular organisation has a policy of providing references only in a certain format, or because a standard reference has been agreed as part of a settlement (previously known as compromise) agreement. In these circumstances, it is at the discretion of Accountancy Learning to decide whether to accept this situation or to not proceed any further with the application. This may depend upon other information received or other checks that can be carried out.

Personnel Records

The digital personnel file for staff will normally contain the following information:

• CV
• Other paperwork related to the recruitment process, i.e. Interview and other notes, letters forming part of the process etc.
• Offer letter and signed copy
• Contract of Employment and signed copy
• Copies of original vocational or academic qualification certificates, as applicable
• Two satisfactory and verified references
• Health questionnaire
• DBS check (record of certificate number and date of issue).
• Other relevant employment documentation throughout the individual’s period of service including probation process documentation.

Induction

Induction is an extension of the recruitment process. Good recruitment and selection procedures help to ensure that the best person is appointed to the role, but it is equally important to induct him or her properly on commencement. A general Induction Programme is required for all new recruits, including those already within the organisation but appointed to new roles. This should be seen as additional to the more formal induction or probationary periods also required in relation to certain new appointments, as summarised below:

Support staff and tutors/trainers who are ‘new employees’ will be subject to a ‘Probationary Period’. A more general induction applicable to all will include a variety of arrangements and areas. The specific arrangements put in place will reflect the differing needs of individuals and job roles, e.g. whether already employed in a different role, whether full time, part time, fixed term, type and seniority of the post and level of contact or involvement with apprentices and young people.

The general induction programme will also include (for all) information on professional standards and boundaries in respect of child protection and safeguarding and promoting the health, safety and welfare of apprentices and young people. Reference will be made to relevant statutory requirements and/or local guidance in these areas. Statutory guidance includes, in particular, the DfE documents: ‘Keeping Children Safe in Education’ – all staff will be required to read and to understand at least ‘Part One – Safeguarding Information for All Staff’.

Safe Culture and Ongoing Vigilance

It is never sufficient to assume that a safer recruitment and selection process and robust induction arrangements are enough to ensure that apprentices and young people are safe and that there is no risk to them within the educational environment. Creation of a safe culture, with on-going vigilance is essential.

If Accountancy Learning has concerns about an existing staff member’s suitability to work with apprentices and young people, Accountancy Learning should carry out all relevant checks as if the person were a new member of staff. Similarly, if a person working for Accountancy Learning moves from a post that was not regulated activity, into work which is regulated activity, the relevant checks for the regulated activity must be carried out. Apart from these circumstances, Accountancy Learning is not required to request a DBS check or barred list check.

Accountancy Learning will continue to strive to create and maintain a safer culture by:

• Having in place, and putting into practice, clear policies and procedures and ensuring that all employees and workers are aware of and understand them
• Setting acceptable standards of behaviour
• Having in place clear procedures for reporting concerns, ensuring that all employees and workers know what the procedures are and their responsibility for following them
• Taking concerns seriously and providing support to individuals raising them
• Taking appropriate action in relation to concerns raised
• Having in place robust and appropriate induction arrangements
• Ensuring that all employees undertake child protection and other relevant training on a regular basis
• Keeping the commitment to safeguarding and child protection on the agenda through regular discussion and/or reminders at staff meetings, training sessions etc.
• Learning from experience
• Never thinking that enough has been done to ensure a safe culture.