Managing a positive DBS disclosure with confidence and fairness

A retail client contacted me after a new hire’s DBS (Disclosure and Barring Service) check came back showing historical convictions. They weren’t sure what to do next—and were worried about getting the legal and ethical balance wrong. They wanted to handle it fairly, respectfully, and in line with safeguarding expectations, but didn’t have a clear process in place.

Together, we created a step-by-step approach using templates from my Safeguarding and Recruitment Toolkits, backed up by bespoke advice.

Step 1: Understanding the Legal and Policy Framework

We started by reviewing the relevant legislation—particularly the Rehabilitation of Offenders Act 1974—to clarify what had to be disclosed and when.

Next, we looked at the client’s recruitment and safeguarding policies. While they had some general guidance, it wasn’t specific enough on how to handle disclosures—so I helped them tighten it up.

Step 2: Strengthening Internal Policies

Using templates from my Recruitment Policy Toolkit, we added a clear section on how DBS disclosures would be managed—covering confidentiality, fair risk assessment, and safeguarding responsibilities.

We also updated their Safeguarding Policy to reflect best practice and include guidance on risk management when recruiting people with criminal records into roles involving vulnerable groups.

Step 3: Equipping Managers with the Right Skills

To avoid rushed or biased decisions, I delivered a short training session for HR and key hiring managers, covering:

• How to read a DBS check
• When and how to have a disclosure conversation
• Fair assessment techniques and unconscious bias
• Documentation and audit trail essentials

Managers left feeling confident they could handle these situations sensitively but decisively.

Step 4: Handling the Disclosure – Case in Practice

The manager arranged a confidential meeting with the new employee, using my conversation script to create a calm and respectful tone.

The employee explained the convictions were over a decade old, with no issues since. They’d disclosed them before in similar roles and were open about wanting to move forward positively.

The manager documented the discussion with my DBS Disclosure Meeting Notes Template and sought advice before making a final decision.

Step 5: Conducting a Risk Assessment

I supported the manager to complete a formal DBS Risk Assessment, considering:

• The nature and severity of the offences
• How long ago they occurred
• The relevance to the employee’s role
• Any safeguarding or reputational risks

We concluded that, with clear boundaries and minor adjustments during onboarding, the risk could be managed appropriately.

Step 6: Communicating the Outcome

The employee was invited back for a second conversation, where the decision was shared: they could continue in their role, with additional support during probation.

We drafted a DBS Outcome Letter confirming the decision, any conditions, and offering access to the Employee Assistance Programme.

Step 7: Ongoing Monitoring and Policy Review

To support the employee’s transition, we agreed on monthly check-ins and manager oversight for the first three months.

The client also reviewed recruitment documentation to ensure DBS and safeguarding procedures remained up to date and consistent.

The Result

The business made a fair, informed decision aligned with their values, protecting everyone involved. They now have:

• A clear, respectful approach to DBS disclosures
• Updated policies supporting compliance and fairness
• Managers trained to act confidently and legally
• An inclusive recruitment process that doesn’t unnecessarily penalise people with past convictions

With the right tools and advice, they’ve built a process that balances safeguarding with second chances—showing that doing the right thing doesn’t have to be risky or complicated.