Safer Recruitment Policy

Introduction

This Policy applies to the entire setting including for appointments to boarding, the co-curriculum and operational positions. Copies of this Policy are available on request. This policy should be read in conjunction with the School’s Safeguarding Policy.

Purpose

The purpose of this document is to set out the policies in force at the School in order to safeguard children through safe recruitment of staff and volunteers.

 

Aims

 

The aims of the School’s Safer Recruitment Policy are:

• to ensure that the best possible staff are recruited on the basis of their merits, abilities and suitability for the position;
• to ensure that all job applicants are considered equitably and consistently;
• to ensure that no job applicant is treated unfairly on any grounds including race, colour, nationality, ethnic or national origin, religion or religious belief, sex or sexual orientation, marital status, disability or age;
• to ensure compliance with all relevant regulation and guidance including that set out by the Department for Education statutory guidance Keeping Children Safe in Education 2022and the code of practice published by the Disclosure and Barring Service (DBS);
• to ensure that the School meets its commitment to safeguarding and promoting the welfare of children and young people by carrying out all necessary pre-employment checks.

Employees involved in the recruitment and selection of staff are responsible for familiarising themselves with and complying with the provisions of this policy.

The School aims to recruit staff that share and understand our commitment and to ensure that no job applicant is treated unfairly by reason of a protected characteristic as defined within the Equality Act 2010.

 

Scope Of This Policy

This policy refers and applies to staff directly recruited and employed by the School. In the Education (Independent Schools Standards) (England) Regulations 2010, staff are defined as:

Any person working at the School whether under a contract of employment, under a contract for services or otherwise than under a contract, but does not include supply staff or a volunteer.  

In the case of agency or contract workers, the School shall obtain a Letter of Assurance from the agency or company that it has carried out the appropriate checks. The School conducts identity checks on agency and contract workers on arrival in school and, in the case of agency workers, the School must be provided with a copy of the DBS check for such staff.

Any staff who TUPE transfer into the School’s staff will be required to undertake the statutory requirements with regard to safer recruitment checks.

Recruitment Process In Brief

1. Principal and SLT identify a need for recruitment and agree the scope of the role (Job Description), salary range and details of advertisement (where, when, body text to be included)
2. Applicants download Recruitment Information pack including Job Description, Application Form, Safer Recruitment Policy, Welcome Document.
3. Applications are received into admissions@sgiemail address and are sent an acknowledgement of receipt.
4. The Principal will select a panel of staff to be involved in interviewing and other formal assessment tasks.
5. Principal and panel produce a shortlist of candidates to invite to interview. The schedule for interviews is drawn up based on the number of shortlisted candidates. The Principal agrees on the salary on offer to each candidate, taking into account their skills and experience in line with the Internation School Pune pay structure.
6. Where candidates have given consent, references are sought prior to interview.
7. Candidates are invited to interview, the nature of which will vary depending on the role. For teaching positions, the formal interview(s) will usually be supplemented by a teaching and a written exercise.
8. Panel members convene to select the preferred candidate. Where possible an offer is made on the day of the interview, subject to references and other recruitment checks as outlined in this policy.
9. Unsuccessful candidates will be offered verbal feedback on their performance.
10. The School will carry out all relevant pre-employment checks and update the SCR.
11. Successful candidates will receive an offer letter and contract of employment along with a welcome pack and invitation to new staff induction day in June.

Application Form

The School will only accept applications from candidates completing the relevant Application Form in full. CVs will not be accepted in substitution for completed Application Forms.

The School will make candidates aware that all posts in the School involve some degree of responsibility for safeguarding children, although the extent of that responsibility will vary according to the nature of the post. Candidates for employed posts will receive a Job Description.

As the position for which candidates are applying involves substantial opportunity for access to children, it is important that applicants provide the School with legally accurate answers. Upfront disclosure of a criminal record may not debar a candidate from appointment as the School shall consider the nature of the offence, how long ago and at what age it was committed and any other relevant factors. Information should be submitted in confidence enclosing details in a separate sealed envelope which will be seen and then destroyed by the Bursar.   If candidates would like to discuss this beforehand, they are asked to please telephone in confidence to the Principal or Bursar for advice.

Any unspent convictions, cautions, reprimands or warnings must be disclosed to the School. However, amendments to the Exceptions Order 1975 (2013) provide that certain spent convictions and cautions are ‘protected’ and are not subject to disclosure to employers, and cannot be taken into account. Guidance and criteria on the filtering of these cautions and convictions can be found at the Disclosure and Barring Service website.

The successful applicant will be required to complete a Disclosure Form from the Disclosure and Barring Service (“DBS”) for the position. Additionally, successful applicants should be aware that they are required to notify the School immediately if they are any reasons why they should not be working with children.

The School takes its responsibility to safeguard children very seriously and any staff member and/or successful candidate who is aware of anything that may affect his/her suitability to work with children must notify the School immediately. This will include notification of any convictions, cautions, court orders, reprimands or warnings s/he may receive.

Staff and/or successful candidates who are disqualified from childcare or registration may apply to Ofsted for a waiver of disqualification. Such individuals may not be employed in the areas from which they are disqualified, or involved in the management of those settings, unless and until such waiver is confirmed. Please speak to the Bursar for more details.

Failure to declare any convictions or police warnings not identified by the DBS check may disqualify a candidate from appointment or result in summary dismissal if the discrepancy comes to light subsequently.

If the candidate is currently working with children, on either a paid or voluntary basis, the School will ask their current employer about disciplinary offences, including disciplinary offences relating to children or young persons (whether the disciplinary sanction is current or time expired), and whether the candidate has been the subject of any child protection allegations or concerns and if so the outcome of any enquiry or disciplinary procedure.

If the candidate is not currently working with children but has done so in the past, the School will ask the previous employer about those issues. Where neither the current nor previous employment has involved working with children, the School will still ask the current employer about the candidate’s suitability to work with children. Where the candidate has no previous employment history, the School may request character references which may include references from the candidate’s school or university.

All candidates should be aware that provision of false information is an offence and could result in the application being rejected or summary dismissal by the School if they have been appointed, and a possible referral to the police and/or DBS.

Invitation To Interview

 

The School will short list applicants according to the relevance and applicability of their professional attributes and personal qualities to the role. Short-listed applicants will then be invited to attend a formal interview at which his/her relevant skills and experience will be discussed in more detail.

All formal interviews will have a panel of at least two people chaired by the Principal or Bursar as appropriate. At least one person on the appointment panel will have undertaken safer recruitment training or an additional safer recruitment interview is also held. The interviewers involved will be required to state any prior personal relationship or knowledge of any of the candidates and a judgement will be made by the Chair as to whether or not an interviewer should withdraw from the panel.

The interview will be conducted in person as standard, although video interviews may be used under certain circumstances, and the areas which it will explore will include suitability to work with children.

All candidates invited to interview must bring documents confirming any educational and professional qualifications that are necessary or relevant for the post (e.g. the original or certified copy of certificates, diplomas, etc.). Where originals or certified copies are not available for the successful candidate, written confirmation of the relevant qualifications must be obtained by the candidate from the awarding body.

The School requests that all candidates invited to interview also bring with them:

1. A current driving licence including a photograph ora passport or a full birth certificate;
2. A utility bill or financial statement issued within the last three months showing the candidate’s current name and address;
3. Where appropriate any documentation evidencing a change of name;
4. Where the candidate is not a citizen of a country within the European Economic Area or Switzerland, proof of entitlement to work and reside in the UK.

Please note that originals of the above are necessary: photocopies are not sufficient.

Candidates with a disability who are invited to interview should inform the School of any necessary reasonable adjustments or arrangements to assist them in attending the interview.

Conditional Offer Of Appointment: Pre-Appointment Checks

 

Any offer to a successful candidate will be conditional upon:

1. Receipt of at least two satisfactory references (if these have not already been received); checks on the authenticity of said references;
2. Verification of identity and qualifications including, where appropriate, evidence of the right to work in the UK;
3. A satisfactory enhanced DBS check and if appropriate, a check of the Barred List maintained by the DBS;
4. For a candidate to be employed as a teacher, a check that that the candidate is not subject to a prohibition order issued by the Secretary of State. Teaching work is defined in The Teachers’ Disciplinary (England) Regulations 2012 to encompass:
   1. Planning and preparing lessons and courses for students
   2. Delivering and preparing lessons to students
   3. Assessing the development, progress and attainment of students
   4. Reporting on the development, progress and attainment of students;
5. Verification of professional qualifications, where appropriate;
6. Verification of successful completion of statutory induction period (for teaching posts – applies to those who obtained QTS after 7 May 1999);
7. Where the successful candidate has worked or been resident overseas such checks and confirmations as the School may consider appropriate so that any relevant events that occurred outside the UK can be considered;
8. Where the successful candidate will be taking part in the management of the School, a check will be carried out under section 128 of the Independent Educational Provision in England (Prohibition on Participation in Management) Regulations 2014. This applies to Directors, Senior Management Team and teaching heads of department.

It is the School’s practice that a successful candidate must complete a pre-employment health questionnaire. The information contained in the questionnaire will then be held by the School in strictest confidence. This information will be reviewed against the Job Description for the particular role, together with details of any other physical or mental requirements of the role i.e. proposed workload, extra-curricular activities, layout of the School.

The School is aware of its duties under the Equality Act 2010. No job offer will be withdrawn without first consulting with the applicant, considering medical evidence and considering reasonable adjustments.

References

 

The School will seek the references referred to in section 5 above for shortlisted candidates and may approach previous employers for information to verify particular experience or qualifications before interview. If the candidate does not wish the School to take up references in advance of the interview, they should notify us in their application form.

The School will ask all referees if the candidate is suitable to work with children.

The School will compare any information provided by the referee with that provided by the candidate on the Application Form. Any inconsistencies will be discussed with the candidate.

Criminal Records Policy

 

The School will refer to the Department for Education (“DfE”) document, ‘Keeping Children Safe in Education’ and any amended version in carrying out the necessary required DBS checks.

The School complies with the provisions of the DBS Code of Practice, a copy of which may be accessed here: https://www.gov.uk/government/publications/dbs-code-of-practice.

DBS Update Service

Where an applicant subscribes to the DBS Update Service the applicant must give consent to the School to check there have not been changes since the issue of a disclosure certificate.

If disclosure is delayed

A short period of work is allowed under controlled conditions, at the Principal’s discretion. However, if an ‘enhanced disclosure’ is delayed, the Principal may allow the member of staff to commence work:

Without confirming the appointment;

After a satisfactory check of the barred list if the person will be working in regulated activity and all other relevant checks (including any appropriate prohibition checks) having been completed satisfactorily;

Provided that the DBS application has been made in advance;

With appropriate safeguards taken (for example, loose supervision) recorded in a risk assessment;

Safeguards reviewed at least every two weeks;

The person in question is informed what these safeguards are;

A note should be added to the single central register and evidence kept of the measures put in place.

Safe To Start Form

Prior to the new employee starting work, the Principal or Bursar will complete the ‘Safe to Start’ form (Appendix) to verify that all appropriate checks have been satisfactorily completed.

Retention and Security of Records

 

The School will comply with its obligations regarding the retention and security of applicants’, employees’ and former employees’ records in accordance with the DBS Code of Practice and its obligations under the Data Protection Act. Copies of DBS certificates are not retained by the School.

Policy On The Recruitment Of Ex-Offenders

 

The School will not unfairly discriminate against any candidate for employment on the basis of conviction or other details revealed. The School makes appointment decisions on the basis of merit and ability. If an individual has a criminal record this will not automatically bar him/her from employment within the School. Instead, each case will be decided on its merits in accordance with the objective assessment criteria set out below.

All candidates should be aware that provision of false information is an offence and could result in the application being rejected or summary dismissal if they have been appointed, and a possible referral to the police and/or DBS.

Under the relevant legislation, it is unlawful for the School to employ anyone who is included on the lists maintained by the DBS of individuals who are considered unsuitable to work with children. In addition, it will also be unlawful for the School to employ anyone who is the subject of a disqualifying order made on being convicted or charged with the following offences against children: murder, manslaughter, rape, other serious sexual offences, grievous bodily harm or other serious acts of violence. It is also unlawful for the School to knowingly employ someone who works in the relevant settings and is disqualified from providing childcare under the Childcare (Disqualification) Regulations 2009.

It is a criminal offence for any person who is disqualified from working with children to attempt to apply for a position within the School. The School will report the matter to the Police and/or the DBS if:

• the School receives an application from a disqualified person;
• is provided with false information in, or in support of an applicant’s application; or
• the School has serious concerns about an applicant’s suitability to work with children.

In the event that relevant information (whether in relation to previous convictions or otherwise) is volunteered by an applicant during the recruitment process or obtained through a disclosure check, the School will consider the following factors before reaching a recruitment decision:

• whether the conviction or other matter revealed is relevant to the position in question;
• the seriousness of any offence or other matter revealed;
• the length of time since the offence or other matter occurred;
• whether the applicant has a pattern of offending behaviour or other relevant matters;
• whether the applicant’s circumstances have changed since the offending behaviour or other relevant matters;
• in the case of disqualification from providing childcare, whether the applicant has or is able to obtain an Ofsted waiver from disqualification; and
• the circumstances surrounding the offence and the explanation(s) offered by the convicted person.

If the post involves regular contact with children, it is the School’s normal policy to consider it a high risk to employ anyone who has been convicted at any time of any the following offences: murder, manslaughter, rape, other serious sexual offences, grievous bodily harm or other serious acts of violence, serious class A drug related offences, robbery, burglary, theft, deception or fraud.

If the post involves access to money or budget responsibility, it is the School’s normal policy to consider it a high risk to employ anyone who has been convicted at any time of robbery, burglary, theft, deception or fraud. If the post involves some driving responsibilities, it is the School’s normal policy to consider it a high risk to employ anyone who has been convicted of drink-driving or other serious driving offences.

Approval & Review

 

This policy will be reviewed every two years or as necessary following a change in regulation.

APPENDIX 1: SAFE TO START FORM

 

NAME OF RECRUIT:  

	Checked binitials)	Checked on (date)
Job description seen by candidate
Application form received and checked
Two written references received, including from current/most recent employer
Candidate interviewed by Safer Recruiting trained interviewer
Offer conditional upon items set out in Recruitment Policy and incorporates standard terms and conditions of employment
Satisfactory enhanced disclosure received
Barred list checked
Prohibition order list checked
Prohibition from Management list checked (Directors, SLT, Head of Dept)
Overseas checks completed, where applicable
Phone calls made to check references
Identity checked to original documents (passport or driving license)
Qualifications checked to original documents
Medical questionnaire completed and checked
Any necessary risk assessments completed and on file
Evidence of National Insurance Number received
Contract of employment signed
Induction completed
Statutory and Internal Safeguarding training completed
Central Record updated

This policy is available to applicants and to parents of students and prospective students on request.

APPENDIX 2: Checklist guide to recruitment process

Pre-interview	Initials	Date
Planning – timetable decided: job specification and description and other documents to be provided to applicants, reviewed and updated as necessary. Application form seeks all relevant information and includes relevant statements about references etc.
Vacancy advertised – (where appropriate) advertisement includes reference to safeguarding policy, that is, statement of commitment to safeguard and promoting welfare of children and need for successful applicant to be DBS checked.
Applications on receipt – Scrutinised – any discrepancies/ anomalies / gaps in employment noted to explore if candidate considered for shortlisting.
Interview Panel – should be briefed and at least one member suitability trained in safer recruitment.
Shortlist prepared and interview	Initials	Date
References – Seeking – sought directly from referee on shortlisted candidates; ask recommended specific questions; including any previous safeguarding allegations.
Reference – on receipt checked against information on application; scrutinise; any discrepancy/issue of concern noted to take up with referee and/or applicant.
Invitation to interview – includes all relevant information and instructions.
Interview arrangements – at least 2 interviewers; panel members have authority to appoint; have met and agreed issues and questions/assessment criteria/standards.
Interview – explores applicant’s suitability for work with children as well as suitability for the requirements of the post.
Any self-disclosed criminal history or issues of suitability – check information would not be filtered / protected, discuss context with candidate at interview, record what was discussed, seek additional advice if necessary.
Identity & right to work – original documents verified on day of interview OR (for remote recruitment) scanned originals seen by school & date scan was received should be recorded here
Qualifications of successful applicant verified on the day of interview by scrutiny of appropriate original documents; copies of documents taken and placed on file OR (remote recruitment) scanned originals seen by school & date scan received should be recorded here
Conditional offer of appointment – offer of appointment is made on conditional satisfactory completion of the following pre-appointment checks and consideration of a probationary period.
References – receive and check (If not obtained and scrutinised previously) any issues are clarified with referee and/or candidate. Electronic references are verified as from a legitimate source.
Identity & Qualifications (If that could not be verified at interview) If recruitment process was remote, the originals must be seen in school on or before the in-school start date & the date seen should be recorded here
Evidence of right to work in the UK – refer to https://www.gov.uk/legal-right-work-uk for guidance. If recruitment process was remote, originals must be seen on or before start date & the date seen recorded here

	Initials	Date
DBS Certificate – Apply for relevant level of DBS, which will be sent back to the applicant. Applicant should then present the original certificate to the recruiting manager. The recruiting manager should make a note on the Single Central Record of the date it was seen by them. Any disclosed information relevant to suitability should be compared with the self-disclosure. For applicants who are signed up to the DBS update service, permission must be sought from the candidate to view the certificate by the recruiting manager.  If it isn’t at the appropriate level or the disclosure details have changed, a new DBS must be obtained. If recruitment process was remote, a scanned copy of the ID and DBS certificate can be used to check status on the update service but originals must be seen on or before the in-school start date & cross-referenced with details on scanned docs.
Barred list check – check the candidate is not barred from taking up the post (this check should only be undertaken for those working in regulated activity, more guidance at https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/550197/Regulated_activity_in_relation_to_children.pdf).
Qualified Teacher Status (QTS) – (for teaching posts in maintained schools) the teacher has obtained QTS or is exempt from the requirement to hold QTS (for teaching posts in FE Schools), the teacher has obtained a PGCE or Certificate of Education (Cert. Ed) or FE Teaching Certificate
Prohibition (S128) – (for teaching posts) the teacher has not been included in the prohibition list, interim prohibition list or subject to other relevant sanctions
Prohibition from management (independent/free schools/academies and maintained school governors) – anyone appointed to a management position is not barred from management by the Secretary of State
Health – Ensure the candidate is medically fit to take up the post. This requirement can be satisfied by using a self-declaration medical form.
Disqualification from childcare – (for relevant posts only) go to https://www.gov.uk/government/publications/disqualification-under-the-childcare-act-2006/disqualification-under-the-childcare-act-2006 for more guidance on who is bound by the disqualification rules.
Employing individuals who have lived or worked outside the UK – These individuals must undergo the same checks as any other candidate, as well as further checks so that relevant events that occurred outside the UK can be considered. Further guidance on overseas criminal checks, taking into account changes to KCSIE January 2021, can be found here: https://www.gov.uk/government/publications/criminal-records-checks-for-overseas-applicants
Appointment and probationary period	Initials	Date
Induction – include the following: – Appropriate level of safeguarding and child protection training – Name and how to contact the DSL – Whistleblowing – Student behaviour policy – Safe working practice / staff code of conduct – Health & Safety in the workplace – Setting emergency evacuation procedures – Any other relevant CPD