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Last reviewed on 12 October 2021
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Use our list of required checks for new staff, trustees, members and local governors to stay compliant with the latest statutory safeguarding guidance.

12 October 2021: we updated our checklist to reflect the latest version of Keeping Children Safe in Education.

Download our list of required checks 

Use our list of pre-employment checks for new staff, trustees and local governors to check whether:

  • Appropriate checks have been carried out
  • Checks have been recorded on the single central record (where applicable)
  • Copies of evidence of checks have been kept in the employee's personnel file

This list has been approved by Forbes Solicitors, and is based on the requirements outlined in Keeping Children Safe in Education, The Education (Independent School Standards) Regulations 2014.

No requirement to check periods of unemployment

The only way to verify that a potential employee was unemployed is to speak with them directly about any gaps in their employment history.

The application form for a role should ask applicants for their employment history. You should address any concerns during the interview.

This was explained to us by representatives from Acas and the Association of School and College Leaders (ASCL)

Record completed checks on the SCR

You're not required to have a separate single central record (SCR) for each of your schools. However, you should make sure you record the information in a way that makes the details for each academy easily accessible for those entitled to inspect it, such as inspectors.

This is explained in paragraph 257 of Keeping Children Safe in Education.

Associate members

There's no definition of 'associate member' for academies, but some academies use the term to describe individuals who sit on committees but who are not trustees.

Where the committee has any delegated responsibilities, these individuals must have:

  • An enhanced DBS check
  • A section 128 check

This is specified in KCSIE 2021 (paragraph 308).

If the individual is involved in regulated activity then they'll need an enhanced DBS with barred list check.


There's no requirement for clerks to have a DBS check. However, if the clerk works from a school premises and has an opportunity for ‘regular contact’ with children then they will need to have an enhanced DBS (as per paragraph 220 of KCSIE 2021).

If the clerk engages in any regulated activity then they'll need an enhanced DBS with barred list check.

Who's responsible for the checks?

The trust and the chair are responsible for making sure checks happen (as per paragraphs 304 to 308 of KCSIE 2021).

However, in practice, it's usually a trust or school administrator that applies for the checks, depending on your board's structure. The general application process is described on this GOV.UK website.

DBS webpage sets out which identification documents it accepts. At least one of the documents must show the applicant's current address

For local governing bodies, the actual process of applying for checks is usually done by the school. 

Chair of trustees must complete a suitability check with the ESFA

When a new chair of trustees is appointed you must update your governance information on the DfE's Get information about schools (GIAS) register within 14 days of the appointment (as per paragraphs 2.52 to 2.57 of the Academy Trust Handbook 2021). 

The chair requires the same checks as other trustees. Most of these are carried out when the chair completes a suitability check with the ESFA. They must complete the application form for this check within 14 days of the update on GIAS.

The suitability check will include:

  • Enhanced DBS check
  • Identity check
  • Check to confirm right to work in the UK
  • Any checks deemed necessary if the chair has lived outside the UK

This suitability check doesn't include a section 128 check, so your trust will need to carry this out separately.

Can we accept an existing DBS check?

As the employer, you decide whether to accept DBS checks from other employers and establishments.  

For a newly appointed chair, as described above, they must complete the suitability checks themselves with the ESFA, even if they may not need a new DBS - see exceptions here.

Failure to obtain a DBS may result in disqualification of trustees and local governors

Trustees, local governors and associate members are disqualified from holding office if:

  • They fail to obtain a DBS check; or
  • Their DBS certificate discloses information that the chair believes makes them unsuitable for the role

If there's any dispute over whether someone should be disqualified, the secretary of state has the final say.

This is outlined in paragraphs 78 and 80 (pages 38 to 39) of the model articles of association. Please check your trust’s articles of association in case they differ.

If an individual is disqualified, they can reapply in the future. The DfE told us this.

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