Guidance for Guild Members

The Disclosure and Barring Service is a Government Agency set up to protect children and vulnerable adults from exposure to people who have relevant convictions or are ‘known to the police’. There is a statutory requirement for employers and organisations to ensure that employees and volunteers who are in roles that involve working closely, regularly, or unsupervised with children or vulnerable adults.

The term “DBS Check” can often cause confusion as it is used as an umbrella term for several distinct tiers which each add an extra layer of information and are relevant as roles carry an increasing level of safeguarding risk.  Two of these are of particular relevance to Tower Captains and ringing teachers.

A bellringing teacher in a church is typically required to have an Enhanced DBS check with a Children’s Barred List check if their role involves teaching, training, or supervising children. Under the Safeguarding Vulnerable Groups Act 2006, if this teaching or supervision happens frequently (once a week or more) or intensively (4 or more days in a 30-day period), it legally constitutes “Regulated Activity”. Because bellringing often takes place in confined spaces like towers and involves close physical proximity to guide technique, churches have a strict statutory and canonical duty to ensure that anyone trusted to teach minors has been thoroughly vetted.

Conversely, a DBS check would not be required for an ordinary adult bellringer who simply attends practices and services but holds no responsibility for teaching, supervising, or organising activities for children. Similarly, a teacher who only instructs independent adults would not qualify for a standard or enhanced check, as the legal eligibility is strictly triggered by responsibility over vulnerable groups. Furthermore, a ringer who occasionally steps in to help a child on a one-off basis would not meet the legal “frequency test” required to mandate an Enhanced check.

An Enhanced Child DBS Check should be obtained through the Parish Safeguarding Officer (PSO) as ringers are part of their parish team. If this is not possible speak to your Incumbent, as there may be another PSO in the Benefice who could assist; or consult the Guild Safeguarding Officer who will advise you. Make sure the PSO ticks the box for automatic updates which will automatically complete a DBS check every 3 years without having to re-apply. As we are volunteers, all DBS checks are free.

In addition to the statutory requirements for Enhanced DBS checks outlined above, the church, through canon law, requires all Tower Captains and “Ringing Teachers” who do not meet the requirements for an Enhanced check to have a Basic DBS check.

How it works

1. Application and ID Verification: The applicant fills out an online or paper form. The PSO physically verifies the applicant’s identity using official documents like a passport, driving licence, and proof of address.
2. Barred List Check: The Disclosure and Barring Service (DBS) cross-references the applicant’s details against the Children’s Barred List to ensure they are not legally prohibited from working with minors.
3. Database Searching (PNC): The DBS searches the Police National Computer for any criminal record history, including spent and unspent convictions.
4. Local Police Records Check: The application is forwarded to relevant local police forces. They check for non-conviction data (such as arrests without charge or harassment orders) that might pose a safeguarding risk.
5. Filtering: Not all spent convictions are included on an Enhanced DBS check. While Enhanced checks are designed to reveal a deep history, the DBS uses a legal process called “filtering” (essentially a rule-based removal system) to wipe older, less serious spent convictions and cautions from appearing on certificates. Offences which resulted in a custodial (prison) sentence or a suspended prison sentence and those which are a “specified offence” relevant to safeguarding (including violent crimes, sexual offences, and offences involving firearms, terrorism, or the supply of drugs) are always included whereas those not in these two categories and enough time has passed (at least 11 years since the conviction date if the individual was an adult (18+) at the time, or 5.5 years if they were under 18) are not included in the certificate.
6. Certificate Issuance: The DBS prints the final certificate on secure paper and posts it directly to the applicant’s home address. The applicant must then show this certificate to the employer or, in our case, the PCC (or Guild Secretary if relevant for Guild events).

What about Vulnerable adults?

An adult (aged 18+) is classed as vulnerable when they are receiving one of the following services: health care, relevant personal care, social care work, assistance in relation to general household matters by reason of age, illness or disability, relevant assistance in the conduct of their own affairs, or conveying (due to age, illness or disability).

There are no activities within bellringing where an Enhanced DBS check for adults is required or permitted.

The rules regarding how and when an organisation can request a check are tightly regulated: an organisation can demand a DBS check as a strict condition of volunteering, but they absolutely cannot seek one without your explicit permission and active participation.

Seeking a Check Without Permission is Impossible and Illegal

It is a serious breach of UK law for an organisation to attempt to run a DBS check behind your back. The system is intentionally designed to prevent this:

• The Process Requires You: To submit a DBS check, an organisation needs your private personal data (like a 5-year address history), your physical identity documents (like a passport or driving licence), and your formal signature or digital declaration.
• GDPR Restrictions: Under UK data protection laws, criminal record data is classified as “special category data”. Processing it without an individual’s explicit, informed consent is a major violation.
• The Certificate is Yours: When a DBS check is completed, the physical certificate is posted only to the applicant’s home address. The employer cannot see the final result unless you choose to show it to them.

Can an Organisation “Demand” a Check?

Yes, if it is a legal requirement for the role. If the activity legally falls under the definition of “regulated activity” (like teaching children or treating patients), the organisation has a statutory duty to ensure a check is completed before you start.

• Your Right: You always have the right to refuse to undergo the check.
• The Organisation’s Right: If you refuse, the organisation has the absolute right to deny you the volunteer role. “The Organisation” means the PCC in relation to your tower or the Guild in relation to a Guild role.

An organisation cannot just demand a high-level check because they feel like it. Under the Police Act 1997, it is actually a criminal offence for an organisation to knowingly request a Standard or Enhanced DBS check for a role that does not legally qualify for one.

Frank Marshall & Andy Waring

Guild Safeguarding and Communications Officers