1. Scope

This Safer Recruitment Policy applies to all recruitment and engagement activity undertaken by No user found for the delivery of domiciliary care services in England. It covers every stage of workforce entry and movement, including attraction, advertising, selection, pre-employment checks, conditional offers, contracting, induction, probation, internal transfers, promotions, secondments, role changes, and the engagement of agency staff, contractors, volunteers, apprentices, students on placement, and independent assessors.

The policy applies to all people involved in recruiting or influencing recruitment decisions on behalf of No user found, including Directors, the Registered Manager (No user found), the Duty Manager, line managers, panel members, HR administrators, clinical leads, and any third party recruitment providers engaged by No user found. It also applies to any person whose role requires a Disclosure and Barring Service check, barred list check, professional registration check, right to work verification, or other vetting activity associated with regulated activity in adult social care.

Service scope includes domiciliary care provided in people’s own homes and in community settings, including personal care and associated support that falls within regulated activity under the Health and Social Care Act 2008. Where roles interface with children, even if infrequently, the enhanced safeguards in this policy apply.

Geographical scope is England only. The policy applies to remote, hybrid, field-based and office-based roles. It covers drivers and escorts involved in transport to and from community activities where this forms part of the service. It applies to any role that may have access to service user information or homes, whether or not the role is client facing.

The Duty Manager is responsible for day to day implementation, ensuring recruitment steps are followed consistently on each live vacancy, that conditional offers are not confirmed until all checks are satisfactorily completed, that exceptions are risk assessed and authorised by the Registered Manager, and that records are complete, accurate and auditable.

This policy is based on regulation 13, 18, 12, 17 and 19 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 and all other relevant English legislation, including the Equality Act 2010, the Rehabilitation of Offenders Act 1974 and the Exceptions Order 1975, the Safeguarding Vulnerable Groups Act 2006, the Protection of Freedoms Act 2012, the Police Act 1997, the Care Act 2014, the Data Protection Act 2018, the UK General Data Protection Regulation, the Immigration, Asylum and Nationality Act 2006, the Employment Rights Act 1996, the Working Time Regulations 1998, the Health and Safety at Work etc. Act 1974, the Human Rights Act 1998, and the Modern Slavery Act 2015.

2. Legal and Regulatory Framework

3. Definitions of Key Terms

4. Policy Statement

The purpose of this policy is to ensure that No user found recruits only people who are safe, suitable and competent to deliver high quality, person centred domiciliary care. Safer recruitment is a core control within our safeguarding and quality governance system and supports compliance with Care Quality Commission requirements, including Regulation 19 Fit and proper persons employed, Regulation 18 Staffing, Regulation 12 Safe care and treatment, Regulation 13 Safeguarding service users from abuse and improper treatment, Regulation 17 Good governance, and Regulation 5 Fit and proper persons directors where applicable.

No user found commits to a fair, transparent and evidence based recruitment process that prevents unsuitable people from working with adults who use our services. Decisions will be based on verified identity, right to work, DBS disclosure at the appropriate level with barred list checks where required, employment history and gaps, references from the most recent employer in care where applicable, verification of qualifications and professional registrations, role specific skills assessment, values and behaviour based interviewing, and health declarations that are proportionate and lawful.

We will uphold equality, diversity and inclusion through lawful positive action and the removal of unnecessary barriers, in accordance with the Equality Act 2010. We will process personal data collected during recruitment in line with the Data Protection Act 2018 and the UK GDPR, using clear retention schedules, access controls and data minimisation. Advertising, role profiles and selection tools will focus on the skills, competencies and values needed to deliver safe, person centred care, including communication, dignity, respect, choice, consent, privacy, and safeguarding responsibilities.

No user found will resource safer staffing levels through planned workforce forecasting, prompt backfilling, and the safe engagement of agency workers only where essential and subject to the same vetting standards. Overseas recruitment will only be undertaken in line with immigration law and ethical recruitment principles, with additional police clearance from countries of residence as required.

The Duty Manager will oversee day to day operational compliance with this policy on live campaigns, ensuring all checks are requested promptly, that applicants are not deployed to regulated activity until clearance is confirmed, and that any conditional risk-based deployment in exceptional circumstances is documented with control measures and authorised by the Registered Manager (No user found). The Registered Manager retains overall accountability for compliance, supported by internal audits, spot checks and record reviews. The Safeguarding Lead (No user found) will be consulted on any information of concern arising during recruitment that may indicate risk, and will advise on appropriate actions including referral to the Disclosure and Barring Service where the legal duty applies.

No user found expects all staff engaged in recruitment to complete training on safer recruitment, equality and diversity, information governance and safeguarding, and to apply this policy consistently. Any concerns about conduct during recruitment or indications of modern slavery, fraud or identity deception will be escalated without delay through safeguarding and whistleblowing routes.

This policy is based on regulation 19, 18 and 13, 12 and 17 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 and all other relevant English legislation, including the Equality Act 2010, the Rehabilitation of Offenders Act 1974 and the Exceptions Order 1975, the Safeguarding Vulnerable Groups Act 2006, the Protection of Freedoms Act 2012, the Police Act 1997, the Care Act 2014, the Data Protection Act 2018, the UK General Data Protection Regulation, the Immigration, Asylum and Nationality Act 2006, the Employment Rights Act 1996, the Working Time Regulations 1998, the Health and Safety at Work etc. Act 1974, the Human Rights Act 1998, and the Modern Slavery Act 2015.

5. Roles and Responsibilities

6. Procedures

6.1 Workforce planning and role design

• No user found maintains a workforce plan that forecasts staffing needs by skill, geography and shift patterns to meet safe staffing requirements in line with Regulation 18.
• Each role has a current job description and person specification that include duties, required competencies, values, safeguarding responsibilities and lone working arrangements.
• The Registered Manager (No user found) reviews role risk profiles to determine the level of checks required, including the need for enhanced DBS with adults barred list for regulated activity.

6.2 Vacancy approval and advertising

• The Duty Manager confirms budgeted vacancies, authorises recruitment timelines and ensures adverts are accurate, inclusive and values based.
• Adverts include the requirement for right to work in the UK, disclosure of criminal history in accordance with the Rehabilitation of Offenders Act 1974 and the Exceptions Order, and agreement to obtain an enhanced DBS where applicable.
• No user found commits to fair selection practices under the Equality Act 2010 and welcomes applications from diverse communities.

6.3 Application, screening and shortlisting

• Applicants complete a safer recruitment application form that captures full work history with explanations for gaps, qualifications, professional registrations and referees from the most recent employer in care where applicable.
• The Duty Manager screens applications against essential criteria, verifies declared gaps and seeks clarification before shortlisting.
• Reasonable adjustments are offered to applicants under the Equality Act 2010.

6.4 Values based interviews and selection activities

• Interview questions test values, behaviours and safeguarding judgement, including scenarios on dignity, consent, choice, privacy and professional boundaries.
• Where practicable, people who use services or their representatives are invited to contribute to selection in a way that is accessible and safe.
• Skills tests may include literacy, numeracy relevant to care tasks, safe handling of information, and role specific competencies.

6.5 Conditional offer

• A conditional offer is issued subject to satisfactory identity verification, right to work, DBS checks, barred list checks where required, two references including the most recent relevant employer, verification of qualifications and professional registration, health declaration, driving checks if applicable and any overseas police clearances.
• The Duty Manager ensures candidates understand that employment will not commence in regulated activity until all required checks are satisfactorily completed.

6.6 Verification checks

• Identity: verified in person or through a certified Identity Service Provider, retaining only the evidence permitted by law.
• Right to work: verified in accordance with Home Office guidance. Copies of acceptable documents or a share code outcome are retained. Where status is time limited, follow up checks are diarised.
• DBS: an enhanced check with adults barred list is obtained for roles in regulated activity. The DBS certificate number and outcome are recorded. Copies of certificates are not stored unless lawfully justified and tightly controlled.
• Employment history and references: a complete chronology is obtained. At least two references are sought, one from the most recent relevant employer. References are verified directly and concerns are escalated to the Duty Manager.
• Qualifications and professional registration: original certificates are checked. Professional registers such as NMC or HCPC are verified on the day of decision and recorded.
• Health declaration and fitness: a proportionate pre-placement health questionnaire assesses ability to perform the role with reasonable adjustments where needed.
• Driving roles: driving licence, business insurance and vehicle roadworthiness are verified when driving is an intrinsic duty.
• Overseas checks: where the applicant has lived or worked outside the UK, a certificate of good conduct or police clearance is sought from the relevant country, with additional references where needed.

6.7 Positive disclosure risk assessment

• Where disclosures or adverse information arise from DBS, references, employment history or interviews, the Duty Manager completes a written risk assessment considering nature, seriousness, age at time, pattern, relevance to the role, safeguarding risk and protective factors.
• The Registered Manager approves the final decision and control measures. Decisions are documented with reasons and retained securely.

6.8 Employment decision, contract and start controls

• No individual undertakes unsupervised regulated activity before all checks are complete and recorded.
• In exceptional circumstances, if limited duties are required to maintain safety, a time bound plan is authorised by the Registered Manager, with direct supervision and mitigations recorded.
• Contracts of employment include conditions requiring ongoing disclosure of matters relevant to fitness and cooperation with repeat checks.

6.9 Probation and early supervision

• A structured probation period is set, ordinarily six months, with reviews at weeks 2, 4, 8, 12, 16 and 24.
• During probation the line manager observes practice, completes competency sign offs and provides additional training where gaps are identified.
• Failure to attain required standards triggers formal support plans or termination in line with employment law.

6.10 Agency workers and contractors

• Agencies must confirm in writing that identity, right to work, DBS at the correct level, references, qualifications and training have been completed. Evidence is sampled by the Duty Manager before deployment.
• Agency workers receive a local induction before starting any shift and are supervised until competent.
• Contractors with access to people’s homes or personal data are vetted proportionately to role risk.

6.11 Volunteers, students and apprentices

• A role specific risk assessment determines the level of DBS and supervision required.
• Volunteers and learners do not provide personal care unsupervised until competencies are evidenced.

6.12 Person centred care within recruitment

• Selection tools assess empathy, communication, respect, promoting independence and cultural sensitivity.
• People receiving support are asked for feedback on staff attitude and fit during shadowing, which informs confirmation in post.

6.13 Safeguarding

• All appointees must complete safeguarding adults training and understand reporting routes on or before day one.
• Any allegation or information suggesting risk of harm is escalated to the Safeguarding Lead (No user found) for decision making, and to the Local Authority where thresholds are met in line with Regulation 13.
• Where the legal duty applies, referrals to the Disclosure and Barring Service are made without delay.

6.14 Risk assessment in deployment

• Individual task risk assessments inform safe allocation of duties during probation, including lone working and visits that present additional risks.
• The Duty Manager ensures staff are paired appropriately until competencies are demonstrably met.

6.15 Medication management competence

• Staff who support with medicines complete theory training and a practical assessment against No user found medicines competency framework before working unsupervised.
• Ongoing assessment occurs at least annually or sooner after errors, incidents or changes in role.
• Only staff authorised in the medicines register administer medicines and their signatures are kept up to date.

6.16 Health and safety onboarding

• Before unsupervised work, staff complete moving and handling, infection prevention and control, lone working, incident reporting, fire safety and use of equipment training.
• The Health and Safety Officer (No user found) confirms that necessary equipment, personal protective equipment and instruction have been provided.

6.17 Information governance and data protection

• Personal data gathered during recruitment is processed lawfully, fairly and transparently in line with the UK GDPR and the Data Protection Act 2018.
• Only necessary data is collected. Access is restricted to those with a need to know.
• Retention: unsuccessful applicant records are ordinarily retained for six months unless a longer period is required to defend legal claims. Successful applicant recruitment records transfer to the personnel file and are retained in line with No user found retention schedule.
• The Data Protection Officer (No user found) oversees compliance and responds to data subject rights.

6.18 Equality, diversity and inclusion

• Reasonable adjustments are offered throughout the process.
• Hiring decisions are based on merit against objective criteria. Any positive action measures are lawful and proportionate.

6.19 Record keeping and audit

• A safer recruitment checklist is maintained for each recruit, covering every check and the decision trail.
• The Duty Manager conducts monthly file audits. The Registered Manager completes quarterly governance audits in line with Regulation 17. Actions are tracked to closure.

6.20 Duty of candour and notifications

• Material recruitment related safety incidents are managed in line with Regulation 20 duty of candour and applicable notification requirements.

6.21 Managing concerns post appointment

• Concerns about conduct, capability or safeguarding are managed through disciplinary and safeguarding procedures.
• If employment ends or duties change because a person has harmed, or may harm, a vulnerable adult, No user found considers and makes a DBS referral where the legal conditions are met.

6.22 Preventing modern slavery and fraud

• Procurement and recruitment processes incorporate checks to identify identity fraud, document forgery and signs of labour exploitation.
• Concerns are escalated to the Duty Manager and the Safeguarding Lead for action and, where necessary, reported to the police or the Modern Slavery Helpline.

The procedures in this section support compliance with Regulation 19 fit and proper persons employed, Regulation 18 staffing, Regulation 12 safe care and treatment, Regulation 13 safeguarding service users from abuse and improper treatment, and Regulation 17 good governance, and align with regulation and other relevant English legislation named in section 1.

7. Training and Development

7.1 Induction

• Every new starter completes a structured induction before unsupervised work. Induction includes values and behaviours, safeguarding adults, Mental Capacity Act 2005 and consent, communication, privacy and dignity, equality and inclusion, record keeping, medicines awareness, infection prevention and control, moving and handling, health and safety, lone working, incident reporting, information governance and confidentiality, professional boundaries and whistleblowing.
• Shadowing is arranged with experienced staff. The Duty Manager ensures a minimum number of shadow shifts appropriate to the role and risk profile.

7.2 Care Certificate

• New care workers are enrolled on the Care Certificate on day one. No user found expects completion as soon as reasonably practicable, ordinarily within the first twelve weeks, with assessor observation, knowledge checks and portfolio evidence.
• Any prior learning is mapped and evidenced. Gaps are addressed with targeted training.

7.3 Role specific competencies

• Medicines support: theory and practical assessment before authorisation, with annual reassessment or sooner after errors.
• Moving and handling: practical training with equipment used in people’s homes and competency observation in practice.
• Specialist areas as required by the service user group, for example dementia, learning disability, autism, mental health, diabetes care, enteral feeding or epilepsy awareness.
• Drivers: safe driving, route planning, lone working, and incident procedures.

7.4 Mandatory training refresher standards

• Safeguarding adults: at least every two years, with enhanced content for supervisors and managers.
• Mental Capacity Act and consent: at least annually.
• Medicines: at least annually for those involved in medicines support.
• Infection prevention and control: at least annually.
• Moving and handling: at least annually with practical reassessment.
• Basic life support and first aid appropriate to role: at least annually.
• Health and safety including fire safety and lone working: at least annually.
• Information governance, confidentiality and data protection: at least annually.
• Equality, diversity and inclusion: at least every two years.
  Commissioner or insurer requirements that exceed these intervals are adopted as the standard.

7.5 Training for people involved in recruitment and supervision

• Safer recruitment and selection, equality law, right to work checks, DBS eligibility and decision making, interviewing skills and avoiding bias. Refreshed at least every three years.
• Conducting investigations, risk assessments on positive disclosures and documenting defensible decisions.
• Supervision and appraisal skills, coaching and giving feedback.

7.6 Supervision, appraisal and continuous professional development

• Formal supervision occurs at least every eight weeks during probation and at least quarterly thereafter.
• An annual appraisal sets objectives linked to quality, safety and person centred outcomes and identifies development needs.
• Staff are supported to pursue recognised qualifications relevant to their role. Study time is considered where feasible to maintain safe staffing.

7.7 Competency assessment and assurance

• Line managers complete direct observations of practice for key tasks such as personal care, communication, record keeping and medicines support.
• Competency sign offs are recorded and repeated if practice concerns arise or if the role changes.

7.8 Training records and monitoring

• The Duty Manager maintains a live training matrix that records completion dates and next renewal due dates for every staff member.
• Automatic prompts are issued before expiry. Staff who fall out of date are removed from relevant duties until refreshed.

7.9 Effectiveness evaluation

• Learner feedback, incident trends, medicines errors, complaints and audit findings are analysed to evaluate training effectiveness.
• The Registered Manager reviews this analysis in governance meetings and commissions updates to content and methods where improvement is needed.

7.10 Non compliance and escalation

• Failure to complete required training or to demonstrate competence triggers a management plan that may include additional supervision, retraining, removal from specific duties or formal action.
• Persistent non compliance is managed through capability or conduct procedures and may lead to dismissal where risks cannot be mitigated.

The training and development standards in this section support compliance with Regulation 18 staffing, Regulation 12 safe care and treatment, Regulation 13 safeguarding service users from abuse and improper treatment, Regulation 17 good governance and align with regulation and other relevant English legislation named in section 1. The Duty Manager oversees day to day adherence to these standards and reports compliance to the Registered Manager for governance assurance.

8. Monitoring and Review

Purpose
Monitoring and review arrangements provide assurance that safer recruitment is consistently applied and remain compliant with regulations and the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including Regulations 19, 18, 12, 13 and 17. Oversight also ensures alignment with the Equality Act 2010, the Rehabilitation of Offenders Act 1974 and the Exceptions Order 1975, the Safeguarding Vulnerable Groups Act 2006, the Police Act 1997, the Care Act 2014, the Data Protection Act 2018, the UK GDPR, the Immigration, Asylum and Nationality Act 2006 and the Modern Slavery Act 2015.

8.1 Governance structure

• Day to day oversight is led by the Duty Manager, who verifies that each live recruitment follows the safer recruitment checklist, and that no person undertakes unsupervised regulated activity until all clearances are complete.
• The Registered Manager (No user found) holds overall accountability and receives a monthly compliance report from the Duty Manager covering all recruitment activity and exceptions.
• Quarterly governance meetings review trends, risks, actions and learning. Themes inform updates to procedures, training and role design.

8.2 Key performance indicators and thresholds

• Percentage of new starters with enhanced DBS including adults barred list clearance before start. Target 100 percent.
• Percentage of files with verified identity, right to work and reference triangulation completed before start. Target 100 percent.
• Time to conditional offer and time from offer to full clearance, with reasons for delay and mitigations.
• Percentage of staff completing induction and mandatory training before unsupervised work.
• Probation completion rate and competence sign off within expected timeframes.
• Agency and contractor vetting assurance rate, including sample checks.
• Equality monitoring of applicants, shortlists and hires, including reasonable adjustments provided and any adverse impact analysis.
• Data protection compliance indicators, including timely deletion of unsuccessful candidate data and access control checks.

8.3 File audits and sampling

• The Duty Manager completes monthly recruitment file audits using a standard tool. A minimum sample of 10 percent of closed campaigns or five files, whichever is greater, is reviewed. High risk roles are always included.
• Each file is rated using a red, amber or green score with actions, owners and dates for completion.
• The Registered Manager completes a quarterly meta audit that checks accuracy of the monthly audits and ensures actions are closed.

8.4 Data quality, security and retention assurance

• Recruitment records are maintained in secure systems with restricted access and audit trails.
• The Data Protection Officer (No user found) completes a quarterly spot check to confirm lawful processing, minimisation, retention and deletion in accordance with the UK GDPR and the Data Protection Act 2018.
• Unsuccessful applicant data is retained ordinarily for six months unless a longer period is justified to defend legal claims. Retention schedules are documented and reviewed annually.

8.5 Learning from events and continuous improvement

• Concerns, incidents, complaints, medicines errors, safeguarding notifications and CQC feedback are reviewed for any link to recruitment or competence.
• Root cause analysis is performed where recruitment factors contribute to harm or near misses. Resulting actions may include adjustments to role design, interview questions, reference guidance, supervision and training content.
• Feedback from people who receive services during shadowing or early visits is collected and used to refine values based selection.

8.6 External assurance and notifications

• Where an incident meets statutory notification criteria, No user found notifies the Care Quality Commission in line with provider guidance.
• If information indicates that a person has harmed or may harm a vulnerable adult and the legal conditions are met, a referral to the Disclosure and Barring Service is made.
• Local Authority safeguarding partners are engaged as required by the Care Act 2014.

8.7 Policy review and version control

• This policy is reviewed at least annually by the Registered Manager and updated sooner if regulations, statutory guidance or local safeguarding arrangements change, or if audits, investigations or inspection findings identify gaps.
• Document control includes version number, approval date, approver, and next review date. Updated versions are communicated to all staff and incorporated into induction and refresher training.

8.8 Reporting and assurance outputs

• A monthly safer recruitment dashboard is produced by the Duty Manager and shared with the Registered Manager. It includes KPI performance, audit findings, overdue actions and risks.
• An annual statement of assurance summarises performance, themes, improvements and any external referrals or notifications made.

9. Reporting Concerns

Purpose
This section explains how staff, candidates, volunteers, agency workers and contractors can raise concerns about safer recruitment, safeguarding or integrity matters, and how No user found will respond. It supports compliance with regulations, Regulation 13 safeguarding service users from abuse and improper treatment, Regulation 17 good governance and Regulation 19 fit and proper persons employed, and aligns with the Public Interest Disclosure Act 1998 and other relevant legislation listed in section 1.

9.1 What to report

• Suspected falsification of identity, qualifications, training or references.
• Undeclared or misleading criminal history or safeguarding concerns.
• Pressure to allow a person to start work before required checks are complete.
• Conflicts of interest, favouritism or bias undermining fair selection.
• Signs of modern slavery, labour exploitation or document fraud.
• Breaches of data protection during recruitment.
• Any behaviour or information indicating risk to people who use services, colleagues or the public.

9.2 Immediate safety

• If there is immediate risk of harm, staff must act to protect the person and contact emergency services. The Duty Manager and the Safeguarding Lead (No user found) must be informed as soon as it is safe to do so.

9.3 How to report inside No user found

• Speak with the line manager or the Duty Manager at the earliest opportunity.
• If the concern involves those individuals or remains unresolved, report directly to the Registered Manager (No user found).
• Safeguarding concerns are reported to the Safeguarding Lead without delay.
• Data breaches or suspected unlawful processing are reported to the Data Protection Officer (No user found).
• Candidates and agency workers can report through the same routes or via the whistleblowing contact listed in the whistleblowing policy.

9.4 Whistleblowing

• Whistleblowing concerns made in the public interest are protected by the Public Interest Disclosure Act 1998. No user found provides confidential reporting arrangements and will accept anonymous reports.
• Victimisation of a person who raises a concern in good faith is prohibited. Allegations of victimisation will be managed through disciplinary procedures.
• Whistleblowing routes are publicised during induction and on staff communications. Reports are acknowledged promptly and handled impartially.

9.5 External reporting options

• Local Authority Safeguarding Adults Team in the area where the person lives, in line with the Care Act 2014. Contact details are maintained in the safeguarding directory and kept current by the Duty Manager.
• Disclosure and Barring Service for referrals where legal criteria are met.
• Care Quality Commission if there are concerns that regulated activities are not being carried out safely or lawfully.
• Police for suspected criminal offences including fraud, identity crime or modern slavery. The Modern Slavery and Exploitation Helpline may also be contacted for advice.
• Home Office Employer Checking Service for complex right to work enquiries.

9.6 Managing and investigating concerns

• The Duty Manager logs concerns in the safer recruitment concerns register and acknowledges receipt within one working day where contact details are available.
• Concerns are triaged to determine immediacy, safeguarding implications, and whether external notifications are required.
• An investigator is appointed who is suitably senior and impartial. Terms of reference, timescales and confidentiality expectations are agreed and documented.
• Evidence is preserved, including application materials, interview notes, reference communications, DBS information handling records and system audit trails.
• Investigations may include interviews, documentary review, liaison with previous employers, professional regulators and statutory bodies.
• Findings, conclusions and recommendations are recorded in a report. Outcomes may include withdrawing an offer, redeployment with controls, enhanced supervision, training, disciplinary action, external referral and learning actions.

9.7 Feedback, confidentiality and support

• Confidentiality is maintained so far as compatible with a fair investigation and legal duties. Information is shared on a need to know basis.
• Where possible, the reporter receives confirmation that the concern has been considered and, subject to legal constraints, is informed of the outcome.
• Support is offered to those involved, including access to guidance, supervision and wellbeing resources.

9.8 Learning and follow up

• The Duty Manager and the Registered Manager review lessons from each concern and update procedures, training and risk assessments as required.
• Themes are reported in quarterly governance meetings and included in the annual assurance statement.
• Where recruitment failures have caused harm, duty of candour requirements are followed, people affected are supported, and statutory notifications are made if criteria are met.

9.9 Records and retention

• Concern logs, investigation reports, decisions and action plans are stored securely with restricted access.
• Retention periods are set in line with legal requirements and No user found retention schedules. The Data Protection Officer provides oversight to ensure compliance.

These monitoring, review and reporting arrangements form part of No user found quality governance system and support continuous compliance with CQC regulations and relevant English law.

10. Equality, Diversity and Inclusion in Recruitment

10.1 Purpose and regulatory basis
This section sets out how No user found ensures recruitment is fair, inclusive and lawful. It supports compliance with the Equality Act 2010, the Employment Rights Act 1996, the Human Rights Act 1998, the Rehabilitation of Offenders Act 1974 and the Exceptions Order 1975, the Data Protection Act 2018 and UK GDPR, and the Modern Slavery Act 2015. It contributes to meeting Care Quality Commission requirements under Regulation 19 fit and proper persons employed, Regulation 18 staffing, Regulation 17 good governance, Regulation 13 safeguarding service users from abuse and improper treatment, and Regulation 12 safe care and treatment.

10.2 Principles

• Treat applicants with dignity, respect and fairness throughout the process.
• Base all decisions on objective criteria linked to the role’s person specification and values required to deliver safe, person centred care.
• Offer reasonable adjustments to remove barriers for disabled applicants and those with health conditions.
• Apply consistent scoring, moderation and quality assurance to reduce bias.
• Use lawful positive action where appropriate to address underrepresentation, without conferring automatic advantage.

10.3 Inclusive role design and advertising

• Role profiles emphasise essential competence and values rather than unnecessary credentials that could disadvantage certain groups.
• Adverts use plain language, avoid discriminatory terms and include a clear invitation to request reasonable adjustments.
• Channels are selected to reach diverse communities. The Duty Manager tracks effectiveness and adapts sourcing strategies.

10.4 Accessible assessment and interviews

• Interview locations, virtual platforms and materials are accessible. Reasonable adjustments may include additional time, accessible formats, interpreters, assistive technology or alternative assessment methods.
• Interview panels reflect diversity where practicable. Panel members are trained in fair selection and inclusive communication.
• Values based scenarios assess dignity, consent, privacy, safeguarding awareness and cultural sensitivity.

10.5 Managing criminal record information fairly

• For roles eligible under the Exceptions Order, disclosures are requested at the appropriate DBS level and considered case by case using a documented, proportionate risk assessment.
• No user found does not automatically exclude applicants with convictions. Decisions consider relevance, seriousness, recency, pattern and safeguarding risk, and are approved by the Registered Manager.

10.6 Data protection and confidentiality

• Equality monitoring data is collected on a voluntary basis, kept separate from selection materials and used for statistical analysis to identify barriers.
• Personal data is processed lawfully and securely in line with UK GDPR and the Data Protection Act 2018. The Data Protection Officer oversees compliance.

10.7 Preventing discrimination and harassment

• Discrimination, harassment and victimisation in recruitment are prohibited. Concerns are reported through the Duty Manager or whistleblowing routes and investigated without delay.
• Interview notes and scores are retained to evidence objective decision making.

10.8 Positive action and outreach

• Where underrepresentation is identified, lawful positive action may include outreach to specific communities, inclusive imagery and role models in recruitment materials, mentoring for applicants and targeted advertising.
• Actions are reviewed for effectiveness and proportionality.

10.9 Training and assurance

• All staff involved in recruitment complete training on equality law, unconscious bias, inclusive interviewing and reasonable adjustments.
• The Duty Manager samples shortlisting and interview outcomes to check for adverse impact and reports findings to the Registered Manager as part of governance monitoring.

10.10 Responsibilities

• The Duty Manager leads day to day implementation, ensures adjustments are arranged and records are maintained.
• The Registered Manager holds overall accountability and approves decisions where complex equality considerations arise.
• The Data Protection Officer monitors lawful handling of sensitive data.

11. Use of Technology and Digital Recruitment Platforms

11.1 Scope and regulatory basis
This section covers the use of applicant tracking systems, online application forms, digital identity and right to work services, virtual interview tools, online testing and e-signature services used by No user found. It supports compliance with UK GDPR and the Data Protection Act 2018, the Equality Act 2010, the Immigration, Asylum and Nationality Act 2006, Home Office right to work guidance, and Care Quality Commission Regulations 19, 18 and 17.

11.2 Governance and procurement

• Digital recruitment tools are procured through a documented vendor due diligence process that evaluates security, data protection, availability, accessibility and fitness for purpose.
• Contracts with processors include UK GDPR Article 28 requirements, confidentiality, sub processing controls, audit rights, incident notification and exit provisions.
• A data protection impact assessment is completed for technologies that present higher risk.

11.3 Security controls

• Access to recruitment systems uses unique accounts with least privilege and multifactor authentication where available.
• Data in transit and at rest is encrypted where supported by the supplier.
• Activity logs are enabled and reviewed periodically by the Duty Manager to detect unusual access.
• Backups and business continuity provisions are documented by the supplier and tested according to contract.

11.4 Privacy by design

• Application forms collect only data necessary for assessment. Optional fields are minimised.
• Privacy notices explain purposes, lawful bases, retention periods, data sharing and candidate rights.
• Data subject rights requests are coordinated by the Data Protection Officer and responded to within statutory timescales.

11.5 Automated decision making and profiling

• No user found does not make recruitment decisions based solely on automated processing. Any automated screening or ranking is used as an aid and is subject to human review.
• Where automated features are enabled, candidates are informed about their use and offered a route to request human intervention.
• The Duty Manager performs periodic checks for unintended bias in algorithmic filters by reviewing outcomes across protected characteristics using anonymised monitoring data.

11.6 Digital accessibility and inclusion

• Online forms and candidate portals are selected or configured to meet recognised accessibility standards such as WCAG 2.1 level AA or equivalent.
• Alternative application routes are offered where needed, including telephone support or paper forms.
• Virtual interviews include instructions for testing equipment, and adjustments are arranged on request.

11.7 Virtual interviews and recordings

• Approved platforms with appropriate security are used. Recording is only undertaken when necessary and with candidate consent, and recordings are retained for a defined period consistent with retention schedules.
• Identity verification steps are taken for virtual interviews, such as pre interview document checks or secure waiting rooms.

11.8 Digital identity and right to work checks

• Where permitted by Home Office guidance, certified Identity Service Providers may be used for digital identity verification. Share codes are used for online right to work checks where applicable.
• Where digital routes are not permitted, compliant manual checks are carried out.
• Copies or outcomes are retained in line with statutory requirements and follow up checks are diarised for time limited permissions.

11.9 Online testing and assessments

• Any psychometric or skills tests are validated for job relevance and checked for adverse impact.
• Reasonable adjustments are available for timed or online assessments.
• Test results are only one element of a balanced, evidence based decision.

11.10 Social media and open source screening

• Social media checks are not used routinely. If used for particular roles, scope is documented, only publicly available information is viewed, and protected characteristics are excluded from consideration.
• Findings are verified for accuracy before use and candidates are given an opportunity to respond to material concerns.

11.11 E-signatures and digital offers

• E-signature tools used for conditional offers and contracts provide tamper evident audit trails.
• Signed documents are stored securely within approved systems and linked to the personnel record.

11.12 Retention and deletion

• Applicant data in digital platforms is retained for defined periods. Unsuccessful candidate accounts and documents are deleted or anonymised in line with the retention schedule.
• The Duty Manager runs quarterly reports to confirm deletion routines are operating correctly and escalates issues to the supplier if required.

11.13 Incident management

• Suspected data breaches involving recruitment systems are reported immediately to the Duty Manager and the Data Protection Officer.
• Incidents are investigated, contained and, where required, notified to the Information Commissioner’s Office and affected individuals in accordance with legal requirements.

11.14 Responsibilities

• The Duty Manager oversees day to day configuration, user access, supplier performance, audits of logs and deletion reports.
• The Data Protection Officer provides advice, approves data protection impact assessments and monitors compliance with UK GDPR.
• The Registered Manager receives assurance through regular reports and approves significant technology changes affecting recruitment.

12. Overseas Recruitment and Ethical Standards

12.1 Purpose and regulatory basis
This section governs recruitment from outside the United Kingdom for roles in domiciliary care. It ensures lawful, ethical and safe recruitment that protects people using services and those we recruit. It supports compliance with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including Regulations 19, 18, 12, 13 and 17, the Immigration Rules including the Health and Care Worker route, Home Office Sponsor Guidance, the Immigration, Asylum and Nationality Act 2006, the Code of Practice for the international recruitment of health and social care personnel in England, the World Health Organization health workforce support and safeguards list, the Equality Act 2010, the Modern Slavery Act 2015, the Data Protection Act 2018 and UK GDPR, and the Police Act 1997.

12.2 Ethical recruitment commitments

• No user found does not charge recruitment fees to candidates and does not work with intermediaries who charge such fees.
• Recruitment does not target countries on the WHO safeguards list except where permitted for direct applications without active promotion, and in line with the Code of Practice.
• Candidates receive clear written information about role, salary, contractual terms, supervision, training, accommodation options, and costs. Contracts are provided before travel.
• Passports, visas or personal documents are never retained by No user found or any agent.
• Indicators of labour exploitation or coercion are treated as safeguarding concerns and escalated to the Safeguarding Lead (No user found) and, where appropriate, to the police or the Modern Slavery and Exploitation Helpline.

12.3 Sponsorship governance

• Where sponsorship is required, No user found maintains a valid sponsor licence and complies with all sponsor duties, including record keeping, reporting via the Sponsor Management System, and monitoring attendance and contact details.
• A named sponsorship compliance lead coordinates with the Duty Manager to ensure Certificates of Sponsorship are issued only after pre employment vetting has begun and role requirements are confirmed.
• Right to work permission end dates are diarised. Follow up checks are completed within Home Office timescales.

12.4 Selection and pre employment checks

• Identity is verified using passports and compliant digital or manual methods. Where available, share codes are used to confirm immigration status.
• Enhanced DBS with adults barred list is obtained for regulated activity. Where the applicant has lived or worked overseas, a certificate of good conduct or police clearance is requested from each relevant country, with certified translations where required.
• Qualifications and professional registrations are verified directly with issuing bodies. Where international qualifications are presented, equivalence is considered and mapped to role requirements.
• Full employment history with explanations of gaps is obtained. References include the most recent relevant employer and are verified directly.
• Health declarations are completed proportionately to the role, with reasonable adjustments considered under the Equality Act 2010.

12.5 Relocation preparation and arrival

• Candidates receive a pre arrival pack including role description, local area information, equipment and PPE requirements, induction timetable, and contact points for the Duty Manager and pastoral support.
• Practical support is signposted for accommodation, opening a bank account and obtaining a National Insurance number. Support is voluntary and non coercive.
• A local induction covers safeguarding adults, the Care Act 2014 context, person centred care, communication and cultural orientation, lone working, medicines awareness, information governance and local operating procedures.

12.6 Induction, supervision and competence

• New starters complete the Care Certificate unless prior learning is evidenced and mapped. Shadow shifts are completed before any unsupervised work.
• Medicines support is not undertaken until competence is demonstrated and signed off.
• Supervision occurs at least every four weeks during the first six months, with additional support for language or cultural integration where helpful.

12.7 Data protection and information handling

• Candidate data is processed lawfully with clear privacy notices, minimal collection, restricted access and defined retention periods.
• Cross border transfers of personal data are assessed for adequacy and safeguarded with appropriate legal mechanisms where relevant.

12.8 Monitoring, reporting and escalation

• The Duty Manager maintains a register of sponsored workers with visa expiry dates, address and contact details, supervision milestones, and training completion.
• The Registered Manager (No user found) reviews compliance monthly. Any reportable changes are notified to the Home Office within required timescales.
• Concerns about exploitation, document fraud or trafficking are escalated to the Safeguarding Lead and external authorities as necessary.

12.9 Working with third party recruiters

• Third party recruiters are contracted under written terms that require compliance with the Code of Practice, Home Office guidance, equality law and the Modern Slavery Act 2015.
• Due diligence includes checks on fee practices, references from UK providers, and sample interviews with placed candidates to confirm ethical conduct.
• Contracts include audit rights and termination for breach.

12.10 Withdrawal or refusal of appointment

• Where pre employment checks are unsatisfactory or concerns remain about safeguarding risk, the appointment is withdrawn. The decision, rationale and any duty to refer to the Disclosure and Barring Service are recorded.

13. Agency Staff, Contractors and Third Party Providers

13.1 Purpose and regulatory basis
This section sets standards for engaging agency workers, contractors and third party providers who may deliver care or have access to people using services, their homes or personal data. It supports compliance with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including Regulations 19, 18, 12, 13 and 17, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, the Agency Workers Regulations 2010, the Health and Safety at Work etc. Act 1974, the Data Protection Act 2018 and UK GDPR, and the Modern Slavery Act 2015.

13.2 General principles

• People supplied by agencies or contractors must meet the same safer recruitment and competence standards as permanent staff before being deployed.
• No user found maintains written agreements with agencies and contractors that set out vetting, training, supervision and data protection requirements.
• The Duty Manager oversees day to day checks and deployment.

13.3 Pre engagement assurance

• Agencies confirm in writing that identity, right to work, enhanced DBS with adults barred list where required, employment history, references, qualifications and mandatory training are verified and current.
• Evidence packs are obtained and sampled by the Duty Manager before the first shift and then periodically. Non compliant workers are not deployed.
• For roles involving driving, licence, business insurance and vehicle roadworthiness are confirmed.

13.4 Local induction and authorisation

• Agency workers and contractors receive a local induction that covers safeguarding, lone working, incident reporting, confidentiality and information governance, health and safety, risk assessments relevant to scheduled visits, and role boundaries.
• Medicines support is only undertaken after local competence assessment and written authorisation. Names and signatures are added to the medicines authorisation register.
• Identity badges are issued or verified at each shift start.

13.5 Supervision and performance

• Initial shifts are supervised until competence is observed. Feedback from people receiving support and permanent staff informs ongoing deployment.
• Concerns about practice or conduct are reported to the agency or contractor immediately and recorded. Where safeguarding thresholds are met, referrals are made to the Local Authority and, if required, to the Disclosure and Barring Service.

13.6 Information governance and confidentiality

• Data processing by agencies and contractors is governed by written agreements that define purposes, lawful bases, retention and security standards.
• Access to care records is the minimum necessary and is removed when engagement ends. Devices used to access data must meet security requirements and be protected against loss or theft.

13.7 Health and safety

• The Health and Safety Officer (No user found) confirms that agency workers and contractors are briefed on relevant risk assessments, safe systems of work and use of equipment and PPE.
• Contractors working in people’s homes follow agreed visit plans to minimise disruption and risk.

13.8 Payment controls and engagement status

• Timesheets are approved only where shifts are evidenced and competence is satisfactory.
• Where individuals are presented as self employed contractors, No user found reviews engagement terms to ensure legal compliance, including tax status, insurance and liability.
• Insurance requirements are verified for agencies and contractors, including professional indemnity where applicable.

13.9 Managing agencies and supplier performance

• Approved supplier lists set minimum standards and KPIs such as fill rate, compliance error rate, incident rate and timeliness of evidence packs.
• The Duty Manager conducts periodic supplier reviews. Persistent non compliance leads to corrective action or removal from the approved list.

13.10 Incident, complaint and whistleblowing routes

• Agency workers and contractors are informed of reporting routes for incidents, safeguarding concerns and whistleblowing.
• Concerns are logged by No user found, investigated, and outcomes are shared with the supplier and regulators where required.

13.11 Record keeping and audit

• A register of all agency and contractor deployments is maintained with evidence of checks, induction, authorisations and supervision records.
• Quarterly audits by the Registered Manager test compliance with this section and the accuracy of agency confirmation statements, with actions tracked to closure.

13.12 Termination or suspension

• No user found may suspend or terminate deployment where safety or compliance concerns arise. Decisions and reasons are documented, and required notifications to agencies, regulators or statutory bodies are made.

These sections form part of No user found safer recruitment governance and provide assurance to people who use services, commissioners and regulators that temporary and international recruitment is safe, lawful and ethically managed.

14. Conflict of Interest Management

14.1 Purpose and regulatory basis
This section sets out how conflicts of interest in recruitment are identified, declared and managed so that decisions are fair, transparent and defensible. It supports compliance with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including Regulation 19 fit and proper persons employed, Regulation 17 good governance and Regulation 18 staffing, and with the Bribery Act 2010, the Fraud Act 2006, the Equality Act 2010, the Public Interest Disclosure Act 1998, and the Data Protection Act 2018 and UK GDPR.

14.2 What a conflict is
A conflict exists when a reasonable person might question the impartiality of a recruitment decision. Examples include family or close personal relationships with an applicant, financial interests in an agency or training provider linked to a candidate, prior disputes, gifts or hospitality, or any situation that could unfairly influence scoring or panel discussion.

14.3 Principles

• Declare, document and manage actual, potential and perceived conflicts at the earliest opportunity
• Remove or reduce bias through panel composition, moderation and oversight
• Keep accurate records to evidence fair process
• Escalate concerns that may indicate bribery, fraud or safeguarding risk

14.4 Declarations

• All staff involved in recruitment complete an annual conflict of interest declaration and update it whenever circumstances change
• For each campaign, panel members sign a campaign specific declaration before shortlisting or interviews
• Any relationship with a candidate, including past supervisory relationships or work in the same service, is declared even if positive

14.5 Risk assessment and controls

• The Duty Manager reviews declarations and decides controls. Options include recusal from the panel, appointing an additional independent panel member, separating shortlisting from interviewing, using anonymised applications where feasible, or external moderation of scores
• High risk conflicts are escalated to the Registered Manager for a decision. Where the Registered Manager is conflicted, a Director reviews and approves controls

14.6 Gifts and hospitality

• Gifts and hospitality from candidates, agencies or related parties are not accepted. Any offer is declined and recorded in the gifts register. Repeated or undue offers are escalated to the Registered Manager and may be reported to the agency or relevant authority under the Bribery Act 2010

14.7 Use of agencies and third parties

• Selection of agencies is made through approved supplier processes that consider quality, compliance and price. Staff involved must not hold personal interests in the agency. Any interest is declared and managed
• The Duty Manager samples agency evidence packs to verify independence and accuracy

14.8 Records and privacy

• Conflict assessments, controls and decisions are recorded on the recruitment file and in the conflicts register. Access is restricted in line with UK GDPR. The Data Protection Officer (No user found) advises on lawful processing and retention

14.9 Breaches and concerns

• Suspected breaches are reported to the Duty Manager or through whistleblowing routes. Allegations are investigated and, where substantiated, may lead to disciplinary action, withdrawal of offers or referral to statutory bodies
• Indicators of fraud or bribery are reported to the police when appropriate. Concerns that indicate risk of harm are reported to the Safeguarding Lead (No user found) and to the Local Authority where thresholds are met

14.10 Assurance

• The Duty Manager includes conflict management compliance in monthly recruitment audits. The Registered Manager (No user found) reviews themes quarterly and updates training and procedure where improvements are required

15. Policy Links and Associated Documents

15.1 Purpose
This section shows how safer recruitment connects with the wider governance framework at No user found, supporting coherent compliance with CQC regulations and English law.

15.2 Related policies and procedures

• Safeguarding Adults Policy
  Confirms duties under the Care Act 2014, Regulation 13 safeguarding service users from abuse and improper treatment, internal reporting routes, multi agency working and DBS referral criteria. Recruitment outcomes that indicate a risk of harm are managed through this policy and escalated to the Safeguarding Lead (No user found)
• Whistleblowing Policy
  Sets confidential routes protected by the Public Interest Disclosure Act 1998. Used by staff, candidates, agency workers and contractors to raise concerns about recruitment integrity, exploitation or unsafe practice
• Data Protection and Information Governance Policy
  Sets requirements under the UK GDPR and Data Protection Act 2018 for lawful processing, minimisation, retention and security of applicant data. Includes subject access request handling and breach response led by the Data Protection Officer (No user found)
• Equality, Diversity and Inclusion Policy
  Implements equality duties in recruitment and employment under the Equality Act 2010, supports reasonable adjustments, positive action and monitoring
• Medicines Management Policy
  Defines competence standards and authorisation for medicines support, which are referenced during selection, induction and probation
• Health and Safety Policy
  Covers safe systems of work, moving and handling, infection prevention and lone working. Links to pre employment health declarations and role specific competence checks overseen by the Health and Safety Officer (No user found)
• Induction, Training and Competence Policy
  Describes the Care Certificate pathway, refresher cycles and observation in practice. Used to plan probation and ongoing supervision in line with Regulation 18 staffing
• Disciplinary and Capability Policy
  Sets processes to manage conduct or performance concerns identified during recruitment or probation, ensuring fair procedure and documentation
• Right to Work and Immigration Compliance Procedure
  Explains lawful routes, document checks and follow up checks under Home Office guidance and the Immigration, Asylum and Nationality Act 2006
• Positive Disclosure Risk Assessment Procedure
  Provides the structured approach and template for assessing DBS or reference information, with approval by the Registered Manager
• Agency and Contractor Engagement Procedure
  Sets the evidence pack requirements, sampling, local induction and performance monitoring for temporary workers and third parties
• International Recruitment and Sponsorship Procedure
  Covers sponsor licence duties, ethical recruitment standards, police clearance expectations and post arrival support
• Records Management and Retention Schedule
  Defines retention periods for recruitment records, unsuccessful applicant data and personnel files, and secure disposal standards
• Incident Reporting and Duty of Candour Procedure
  Describes how recruitment related safety incidents and near misses are reported, investigated and, where criteria are met, communicated to people affected under Regulation 20

15.3 Tools and templates

• Safer Recruitment Checklist and file cover sheet used by the Duty Manager to evidence each check and decision
• Shortlisting and interview scoring matrices with guidance on values based questions
• Reference request templates and verification script
• Professional registration verification log
• Medicines competence assessment forms and authorisation register
• Conflicts register, gifts and hospitality register and campaign declaration form
• Recruitment file audit tool with red, amber and green scoring and action tracker

15.4 Version control and document ownership

• The Registered Manager is the document owner and approves updates. The Duty Manager manages day to day distribution, ensures current versions are in use and withdraws superseded documents
• Version history records the version number, approval date, approver and next review date. Updates are communicated to staff and included in induction and refresher training

15.5 Access and availability

• Policies and templates are accessible to recruiting managers, panel members and administrators through approved systems. Paper copies are available on request to ensure accessibility
• Agency partners are provided with relevant extracts and templates where needed to meet evidential requirements before deployment

These sections ensure that safer recruitment is integrated into the governance system at No user found, with clear connections to safeguarding, information governance, equality, health and safety, and workforce development, and with day to day coordination by the Duty Manager and oversight by the Registered Manager.