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Portability and Risk Assessment |
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A question that is often asked by organisations carrying out CRB checks on their staff and volunteers is “Can I use a Disclosure check which a person has got from another organisation?”
The CRB have recently issued new guidance on this situation and this states that in certain circumstances it might be appropriate to use a Disclosure which has been obtained through another organisation, this is known as ‘Portability’.
The following is a summary of the CRB’s guidance which states that if you do want to use Portability, you should use the following procedure:
- Ask the individual to show you their copy of the CRB check
- Contact the Countersignatory, named on the front of the CRB check, and confirm that the reference number and identity details match
- Ask if the Countersignatory received any additional information - the Countersignatory can only confirm or otherwise the existence of such information – but not the content of the information
- If there is no additional information, carry out a formal risk assessment to decide whether to accept the CRB check – see below
- If there was additional information, you are strongly advised to ask the individual to apply for a fresh check.
If deciding to follow this procedure you should be aware that there are the following limitations:
- The CRB check may not be at the level you require - if you require an Enhanced Check you should not accept a Standard Check carried out by another organisation
- The CRB check may not have included a check of List 99, Protection of Children Act List (POCA) and/or the Protection of Vulnerable Adults List Act (POVA)
- If there was additional information provided by the police under cover of a separate letter, a Countersignatory can only confirm whether this was the case or not, they are not allowed to disclose what that information was
- As a CRB check carries no formal period of validity, the older a check, the less reliable the information is, as the information it contains may no longer be up to date – the person's criminal record or other relevant information may have changed since its issue
- You may be required by law to carry out a fresh check with List 99, POCA and/or the POVA. In certain circumstances, portability cannot be used e.g. care workers need a new POVA check each time they change employment
- You should be aware of the differences in the meaning of the wording that appears in the information boxes on Disclosure, in particular, ‘None recorded’ means no information was found, ‘Not requested’ means that a check was not done.
As stated above, if you are considering accepting a previously issued CRB check you should carry out a full risk assessment which should take into account the following:
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Are you required by law to get a new check?
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Is the level of CRB check the same as the level you need?
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How old is the CRB check?
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Is the position for which the previously issued CRB check was obtained similar to the position for which you need a CRB check now?
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Have all checks that you need been carried out?
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Have you validated and authenticated the person’s identity to ensure that the person presenting the CRB check is the person on whom the check was done? For instance, have you seen a range of identity documents that confirm their name, address, date and place of birth?
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Is the applicant still living at the same address as the one printed on the CRB check?
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If it is an Enhanced check, have you confirmed from the previous Countersignatory if any additional information was released by way of a separate letter?
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Have you obtained the consent of the applicant to approach the other organisation?
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CRB Disclosure Checking Service 
