Safer Working - Disclosures Handling Policy


‘Safeguarding First’ at The Prince’s Trust (The Trust) is at the heart of everything we do to protect the children, young people, and young adults we support via our programmes to live, learn, and earn. 

An important aspect of ‘Safeguarding First’ is the ability of The Trust to demonstrate and evidence, it has taken every possible step, through the application of Safer Working Practices to ensure the suitability of individuals to work in role, throughout their association with The Trust. 

One of these Practices is the requirement for disclosure to The Trust of personal and sensitive data relating to an individual’s criminal record, which is applied to prospective new and existing staff and volunteers, including trustees.    

Disclosure information relating to an individual’s criminal record is obtained by The Trust in a couple of ways – one route is via self-disclosure and forms part of the recruitment process for staff and volunteers.   There is also an ongoing requirement for self-disclosure by existing staff and volunteers relating to any changes in circumstance due to criminal charges, convictions and cautions obtained whilst working at The Trust, irrespective of whether it is in a personal capacity or not. 

The second route is via the use of external verification using Sterling, an organization appointed by The Trust to act on its behalf to obtain a formal disclosure check (criminal records check) as part of The Trust’s vetting requirements at the offer stage, from the UK Disclosure Checking Services – Disclosure & Barring Service (DBS) for England and Wales; Access NI for Northern Ireland, and Disclosure Scotland for Scotland.  The Trust also requires formal disclosure checks to be repeated for existing staff and volunteers with frequency at the discretion of The Trust.  This is currently every three years.    

The provision of disclosure information in terms of what can and cannot be provided is governed by UK legislation, which also informs how The Trust processes sensitive, personal disclosure information.  This policy provides information on how The Trust securely handles and disposes of disclosure information and certificates. 

Policy Statement

Disclosure information relating to criminal records is used by The Trust to contribute towards management decision making in establishing the suitability of individuals to undertake staff and volunteer roles within the UK.  This Safer Working - Disclosures Handling Policy describes how The Trust complies with its obligations when it comes to the safe handling, use, access, storage, retention and disposal of disclosure information and disclosure certificates in accordance with the requirements of the codes of practice for the UK Disclosure Checking Services and UK legislation pertaining to the Police Act 1997; Rehabilitation of Offenders Act 1974 and subsequent amendments; DPA (Data Protection Act) 2018 and GDPR requirements.

Part of The Trust’s obligations in relation to the UK Disclosure Checking Services codes of practice is the provision of this written Safer Working - Disclosures Handling Policy and access to the policy for those who wish to see it upon request, which is facilitated through publication on The Trust’s internal and external websites.

This Safer Working - Disclosures Handling Policy should be read in conjunction with the Joiners and Leavers Policy.

Training on this policy will be provided as necessary to those who are carrying out activities to implement the requirements of this policy.

Ownership and responsibility for this policy rest with The Prince’s Trust Council, delegated to the Executive Leadership Team.

Handling of Information

In accordance with section 124 of the Police Act 1997, disclosure information and disclosure certificates should only be passed to those who are authorised to receive them in the course of their duties, for example, Members of the HR Services team for transactional activity purposes; the Recruiting Manager, Service Delivery Manager and/or Youth Development Lead, Delivery Partnerships and Volunteer Manager and/or Youth Development Lead; managers from Talent Management, HR People Partner including Volunteer and Secondee Partner, Employee Relations team and for adverse information and safeguarding concerns, Project Manager - HR & Safeguarding; Safeguarding Manager and Advisory Team, and Adverse Record Review (ARR) group members.  It is a criminal offence to pass this information to anyone who is not entitled to receive it.

Every effort will be taken to preserve the identities of individuals through the application including the use of case reference numbers in place of names.  Shared documentation will also be password protected and access limited to those needing to know (referred to in paragraph 1 of this Handling Of Information section) as part of their duties.

Any breaches in the handling of this sensitive personal data by staff and volunteers will be referred to The Trust’s Data Protection and Legal Counsel and Project Manager – HR & Safeguarding.  This will be investigated taking account of the nature and severity of the breach, whether it was a deliberate act, impact on the subject of the breach, and potential reputational and other risks to The Trust.  Where appropriate the Information Commissioner’s Office will be notified of the breach. Outcomes may range from a simple verbal caution, recorded on an individual’s record to formal disciplinary action and in some instances may ultimately lead to termination of role. 

Use of Information Needed

The Trust applies the use of disclosure checks fairly and in accordance with the law and best practice, supported through the application of The Trust’s policy on the Recruitment of Ex-Offenders, which is available to individuals via The Trust’s internal & external websites.

Roles requiring an enhanced with child barred list check are exempt from the Rehabilitation of Offenders Act 1974 and subsequent amendments, enabling The Trust to ask and obtain information relating to unspent and spent convictions and cautions, which are not eligible to be filtered, with an option for police to share any information they hold and deem relevant, together with checks of the applicant against the barred list.  Whereas basic check roles are not exempt from the Rehabilitation of Offenders Act 1974 and subsequent amendments, with criminal record information limited to unspent convictions and adult cautions.

Disclosure information is obtained with the individual’s consent and used by The Trust to inform the suitability of applicants and existing staff and volunteers to undertake roles within The Trust.  Disclosure information forwarded to The Trust via Sterling from the UK Disclosure Checking Services is limited to the individual’s name, type of disclosure, the position for which the disclosure was requested, the disclosure reference number, date of issue, disclosure status (satisfactory or unsatisfactory).  The Trust does not receive a copy of the Disclosure Certificate with an original only sent to the individual concerned.

Where an individual has disclosed a criminal offence/s or a disclosure check has revealed an unsatisfactory check (adverse disclosure), these circumstances will always be followed through by The Trust on an individual basis.  Before a suitability decision can be taken, the sight of the original certificate supplied to the individual concerned is required to obtain/confirm full offence details; an investigation conducted including a meeting with the individual concerned to enable them to provide their perspective, plus any mitigating circumstances, and completion of an appropriate risk assessment if required.  Risk assessments are forwarded to the Project Manager – HR and Safeguarding for triage, assessment, and consideration by the Adverse Record Review Group where appropriate.

Deliberate attempts to conceal information requested could result in withdrawal of an offer, disciplinary proceedings, or dismissal.

Suitability decisions should take account of the information supplied on a disclosure certificate; offence details and mitigating circumstances from the individual’s perspective; when the offence/s occurred, age at the time of the offence/s, nature, and severity of offence/s; relevance to role; the potential impact of offending behaviour on children & young people, beneficiaries, staff, and volunteers, and reputational risk to The Trust.  Recommendations for withdrawal of an offer or termination of a member of staff or volunteer will be shared with the Safeguarding Director.

Storage and Access

The Trust does not keep disclosure information or disclosure certificates on an individual’s personal file.  Disclosure information received from Sterling is stored centrally and managed by the HR Services Team, unless a copy disclosure certificate and disclosure information is required for safeguarding case management purposes, and for suitability decision-making by the Adverse Records Review group.  Disclosure data and information is kept securely in an electronic file, or in lockable, non-portable storage containers and with both, access is strictly controlled and limited to those who are entitled to see it as part of their duties as outlined in paragraph 1 in the section on Handling Disclosures. 


Self-disclosures relating to unsuccessful applicants during recruitment will be deleted/destroyed in accordance with DPA and GDPR requirements. 

The Trust does not keep Disclosure information for any longer than is necessary and will not retain any paper or electronic images once the suitability to work decision has been taken. 

Retention of disclosure information is generally for a period of up to six months (“the retention period”) to allow for the consideration and resolution of any disputes or complaints, for the purpose of completing relevant audits, or the date an individual ceases to undertake work for The Prince’s Trust, whichever is sooner. 

However, notwithstanding the above, The Trust will keep a record of the date of issue of a certificate, the name of the individual, the type of certificate requested, the position for which the disclosure certificate was requested, the unique certificate reference number, whether clearance was satisfactory and unsatisfactory, and where unsatisfactory details of the suitability to work decision.

In very exceptional circumstances, it may be considered necessary to keep disclosure certificates and disclosure information for longer than six months to support safeguarding case management and audit purposes.

At all times we will ensure the safe and secure storage and strictly controlled access to disclosure information.


Once the retention period has elapsed, The Trust will ensure that any disclosure certificate information is destroyed by secure means.  While awaiting destruction, disclosure information will not be kept in any insecure receptacle (waste bin or confidential waste sack).


Director of Safeguarding

Head of Safeguarding

Data Protection Officer & Legal Counsel

Head of Employee Relations and Policies

Project Manager – Safeguarding & HR

Related Policies and Documents

Recruitment Statement

Policy – Recruitment of Ex-Offenders

Codes of Practice – please select appropriate link:

Author - Safeguarding

Date approved by Council - 09/11/2021

Next Council review date - 09/11/2023

Details of previous reviews and approvals - 2019 Approved for initial publication