Criminal Record Bureau Checks – A Review of A Primary School’s Procedures and Record-Keeping.


This report is written following a request from KCC (Children, Families & Education) that all lead Governors on Children’s Safeguarding (Child Protection) undertake a review of CRB checking procedures in order to ensure that such checks are being properly carried out, and that good records are being kept.

CRB Checks - Requirements

At present, the school is required to carry out checks for the following categories of adults entering the school;

  • Teachers
  • Teaching assistants
  • Supply teaching staff
  • Administrative and clerical staff
  • Catering, cleaning and caretaking staff
  • Midday supervisors
  • School governors
  • Parent and non-parent volunteers

It also seeks CRB clearance for those for whom there is no requirement, but who have regular contact with children at the school, such as the school’s taxi driver.

CRB Check Procedure for Adults Other Than Supply Teachers

When an individual first has contact with the school, sufficient personal details are taken to enable a CRB check to be made. However, there is normally a time lag of 4-8 weeks between a request for information being made and the final clearance being given. Because of this, standard procedure is to undertake a List 99 “spot check”.

List 99 is a DfES-maintained register of persons whose employment is barred or restricted on grounds of misconduct or medical grounds (Education Act 2002). Those whose employment or contact with children is barred on grounds of misconduct may have been added to the list for a wide variety of reasons, from abuse of trust and drug-related offences, to violent crime and child abuse.

Provided an individual clears the List 99 check, they will be permitted to go about their intended business at the school while awaiting the results of the full CRB check.

Once cleared, an individual will be identified as having either standard or enhanced clearance. Standard clearance allows an individual adult to work with children in groups while under the “supervision” of an individual with enhanced status, while enhanced status allows an adult to have sole charge of children. The school is increasingly moving to assigning enhanced contact status to all staff and volunteers, since even volunteer drivers will have sole charge of children for a short period.

CRB Checks On Supply Teachers

A supply teacher will normally bring a copy of their CRB Disclosure form with them (supplied via their recruiting Agency). The school retains a copy of this.  A List 99 check is also carried out. 

Frequency of Checks

A new CRB check is required in cases where the contact/contract between a CRB-cleared adult changes. This might happen for example, when a supply teacher becomes a contracted teacher.

Whilst new List 99 checks are carried out on serving teachers, no new CRB checks are required on entering the school, since the existing Disclosure is considered sufficient.

There is no legal requirement to carry out periodic checks.

Recording of Information

A record of all checks (List 99 and full disclosure), plus level of clearance is kept on a simple spreadsheet. Original documentation is also kept.

The record of CRB and List 99 checks was generally in good order when I viewed it on 1/12/06, apart from the fact that disclosure dates had not been added for two individuals. Since the disclosures are available, the spreadsheet should now be updated.


While the school itself is meeting its legal obligations in this area, there are number of issues which because they fall outside current requirements present potential dangers. These are as follows;

  • The school is not required to seek CRB clearance for individuals who come into contact with children outside school hours. These currently include taxi drivers and parents who volunteer to transport children to and from extra-curricular events such as sports matches or theatre trips.

    While I’m aware that the school has sought to ensure that the school’s taxi driver is CRB cleared, and that many of the parents who volunteer their time after school are in fact cleared, the school needs to implement a policy to ensure that it knows exactly who is transporting children, and ensuring that these adults are cleared.
  • There is no legal requirement for individuals who have formed either a contractual or voluntary relationship with the school before the implementation of the Education Act, 2002, to have CRB or List 99 clearance. The school has a number of such individuals. While there is clearly no suggestion that any of the adults currently connected with the school present a risk, this exemption by the Act does not present a good example of best practice.
  • Since there is no requirement on schools to carry out periodic checks either of List 99 or with CRB, a previously cleared individual could theoretically be convicted of a relevant offence whilst remaining connected with a school.

    While it is likely that if a person employed by a school committed a relevant offence whilst employed, the education authority would be informed about his/her conviction, this is far less likely in the case of volunteers or even school Governors, particularly in the case of a minor offence, simply because there would be no automatic requirement for the convicted individual to reveal his/her connections with a school.


My review suggests that the school is currently maintaining good CRB checking procedures in accordance with current requirements. However, we need to ensure that all returned disclosures are properly recorded so that the information is readily available.

The school may also wish to consider the implications, if any, of the gaps as highlighted in the paragraph on concerns as detailed above.

Erika Lawal

December 2006

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