The rise of remote work has transformed the way many organisations operate, but it also raises important questions about compliance and safeguarding, particularly in relation to DBS (Disclosure and Barring Service) checks.  

It’s crucial for employers to understand that there is a significant difference between working remotely in general (“home working”) and operating a role from your home address where clients or vulnerable individuals are physically present.  

This blog post will explore the implications of these different types of home working on DBS checks, outline eligible and ineligible roles, and address the key considerations for employers. 
 
Understanding the Core Principles of DBS Checks 

It’s essential to remember that the fundamental purpose of a DBS check remains the same, regardless of whether an employee is working remotely or in a traditional office setting.  

The core principle is about assessing the suitability of individuals for roles that involve working with children or vulnerable adults.  

The key question to ask is whether the role itself requires a DBS check, and not just the location where the work is performed. 
 

Key Considerations for Home Working and DBS Checks (General Remote Work) 

These points relate to remote work not involving people attending the home address: 

• Access to Sensitive Information: Does the home-working role involve access to sensitive personal data, confidential records, or other information that could potentially be misused? 
• Direct Contact with Vulnerable Groups (Remote): Even in a remote setting, does the role involve any form of direct online interaction with children or vulnerable adults, such as online mentoring, remote tutoring, or virtual support services? 
• Responsibility and Trust: Does the role involve a high degree of trust and responsibility, even if it doesn’t involve direct contact with vulnerable groups? 
• Supervision and Oversight: How will the organisation ensure adequate supervision and oversight of the employee’s work, especially in terms of handling sensitive information or engaging with vulnerable individuals remotely? 
• Data Security at Home: What measures are in place to ensure data security at the employee’s home, such as secure internet connections, password protection, and appropriate disposal of confidential documents? 
   
   

Important Distinction: Operating from a Home Address with In-Person Contact 
 

The DBS guidelines make a key distinction between general remote work (where the worker is simply at home) and situations where children or vulnerable adults are physically present at the worker’s home address as part of their role. If a role involves children or vulnerable adults visiting the worker’s home address, significantly stricter safeguarding rules apply.  

This includes, but is not limited to: 

• Enhanced DBS Checks for Household Members: All adults (usually defined as 16 or over) who reside at the property may be legally required to undergo Enhanced DBS checks, regardless of their direct involvement in the employee’s work. 
• Assessment of the Home Environment: The employer may be required to assess the suitability of the home environment, to ensure that it is a safe and appropriate place for children or vulnerable adults. This can include a risk assessment for a visit to the home. 
• Stringent Safeguarding Policies: The organisation must implement rigorous safeguarding policies to protect the children or vulnerable adults who are visiting the home address. 

Examples of Situations Requiring Household Checks: 
 

• Registered Childminder Operating from Home: A registered childminder caring for children in their home must ensure that all adults living at the property have Enhanced DBS checks with Barred List checks. 
• Foster Carer Providing Respite Care: A foster carer providing short term respite care in their home is often required to have all other adults residing at the property checked by an enhanced DBS check with barred list checks. 
• Therapist Seeing Vulnerable Clients in a Home Office: A therapist seeing vulnerable adults in a dedicated home office, or another part of their home. 

Impact on Household Members (General Remote Work, No In-Person Contact) 
 

These points only relate to remote work with no in-person contact: 

• Awareness and Training: Household members should be made aware of the importance of confidentiality and data protection. 
• Access to Equipment: Family members should not have access to work equipment or systems. 
• Supervision and Contact: Steps should be taken to ensure that any online contact with vulnerable people is kept private, and family members are not able to observe any sessions. 

 
 
Examples of Roles Likely to Require a DBS Check, Even When Working From Home 
 

• Remote Tutor for Children: An individual providing online tutoring services to children. Even though the interaction is virtual, they are still engaging in direct contact with children. 
• Remote Social Worker: A social worker providing support and guidance to vulnerable families through online platforms. They have access to sensitive information and are making decisions that impact vulnerable individuals. 
• Remote Counsellor or Therapist (No In-Person Contact): A counsellor or therapist providing online therapy services to vulnerable adults or children, with no clients visiting the home address. 
• Database Administrator with Access to Sensitive Patient Data: An individual responsible for maintaining a database containing sensitive medical records of vulnerable patients. Although they may not have direct contact with patients, they have access to highly sensitive data. 

Examples of Roles Less Likely to Require a DBS Check When Working From Home 

• Remote Marketing Specialist: An individual responsible for creating marketing materials for a company. Their role does not involve direct contact with vulnerable groups or access to sensitive information. 
• Remote Accountant: An individual responsible for managing the financial records of a business. Their role does not typically involve direct contact with vulnerable groups or access to sensitive personal data. 
• Remote Customer Service Representative (General Inquiries): An individual handling general customer service inquiries for a company. Their role does not typically involve direct contact with vulnerable groups or access to sensitive information. 
• Remote IT Support (General): An IT support professional providing technical assistance to company employees. Their role may involve some sensitive data, but is not likely to qualify for a DBS check if the data is anonymised and there is no way to link back to a real person. 
   

Considerations for Employers 

 
Risk Assessment: Conduct a thorough risk assessment of all home-working roles to determine whether a DBS check is necessary based on the specific duties and responsibilities, and consider whether the job role necessitates people visiting their home. 

Policy Updates: Update your DBS policy to specifically address the implications of home working and outline the criteria for determining when a DBS check is required for remote roles, including checks for those in the household. 

• Data Security Measures: Implement robust data security measures to protect sensitive information, such as encryption, password protection, and secure remote access protocols. 
• Supervision and Monitoring: Establish clear guidelines for supervision and monitoring of home-working employees, particularly those working in roles that require a DBS check. This might include regular check-in meetings, remote monitoring software, or other oversight mechanisms. 
• Employee Training: Provide thorough training to all home-working employees on data security, safeguarding, and their responsibilities in relation to DBS checks, and consider providing limited guidance to family members also. 
• Household Awareness: Ensure that the impact on other household members is a key element of your safeguarding policy, and assess whether the home is suitable for those working with vulnerable groups. 
• Regular Review: Regularly review and update your policies and practices to ensure they remain effective and compliant with relevant legislation. 
   

Conclusion 

 
The increase in home working requires employers to carefully consider the implications for DBS checks, as well as the wider implications for others in the employee’s household.  

It’s essential to distinguish between remote work in general and situations where vulnerable individuals are physically present at the worker’s home address.  

While not all remote roles will require a DBS check, a thorough risk assessment and robust safeguards are essential to protect vulnerable groups and ensure compliance with the law.  

By understanding these nuances and taking proactive measures, organisations can confidently navigate the challenges of home working while maintaining a safe and secure environment.