Screening volunteers, and what a DBS check does not tell you
A DBS check for a mentoring or befriending volunteer is a criminal record check carried out by the Disclosure and Barring Service, whose checks cover England and Wales only, and it is free of charge where the person meets the DBS definition of a volunteer.
A coordinator running safer recruitment without an HR department, and a volunteer asked to consent to a check who wants to know what it is and who sees it.
The person who will be alone with the volunteer. Every other purpose of screening, including the scheme’s own protection, is downstream of that one.
The certificate becomes the decision. A scheme treating a clear check as approval has stopped screening and started processing, and it will accept, with the right paperwork, the applicant whose references were vague and whose interview raised something nobody wrote down.
Scotland and Northern Ireland use different systems and different bodies, so a scheme working across borders does not get a DBS check for its Scottish volunteers. The check is also the least informative part of screening: it reports what is recorded about a person’s past, on the day it is issued, and nothing else.
Which level of check a one-to-one role qualifies for
The level a role qualifies for is set by law rather than by the scheme’s preference, and it depends on what the volunteer does rather than on how important the role feels. Check the written role description against DBS eligibility guidance before any application is submitted.
| Level | What it shows | Typical one-to-one role |
|---|---|---|
| Basic | Unspent convictions and conditional cautions | Anyone may request one; the fallback where a role is not eligible for more |
| Standard | Spent and unspent convictions, cautions, reprimands and warnings, subject to filtering | Eligible listed roles falling short of regulated activity |
| Enhanced | Standard content plus anything a chief officer of police reasonably considers relevant | Eligible work short of regulated activity, such as occasional rather than frequent contact |
| Enhanced with barred list | Enhanced content plus a check of the children’s or adults’ barred list | Regulated activity, where weekly one-to-one mentoring of a child normally sits |
Two distinctions do most of the work. For children, regulated activity turns on what the volunteer does and how often: unpaid teaching, training, instructing, caring for or supervising a child counts where it is carried out frequently, or where it meets the period condition in the legislation. Weekly one-to-one mentoring ordinarily meets that test, meaning an enhanced check with a children’s barred list check. For adults, regulated activity is defined by the assistance given, such as personal care, healthcare, help with cash, bills or shopping, or conveying someone to an appointment. Companionship befriending, where the volunteer visits for company and does none of those, frequently does not meet the adult definition, so one scheme can be entitled to different levels for its youth mentors and its befrienders.
That test changed recently, and a scheme working from older guidance will get it wrong. The Crime and Policing Act 2026 removes the supervision exemption from the definition of regulated activity with children, and it comes into force on 1 September 2026. Before that date, unpaid teaching, training, instructing, caring for or supervising children was not regulated activity if it was supervised by somebody who was themselves in regulated activity, so a supervised volunteer could sit outside it. From that date all such activity is regulated activity if it is carried out frequently or if it meets the period condition, supervised or not. The government guidance announcing the change states that it applies to England, so a scheme in Wales, Scotland or Northern Ireland should check its own national position rather than assume the change reaches it.
Volunteering in a school follows the same logic with a written framework over it. Keeping Children Safe in Education requires the school to decide, risk assess and record which check each volunteer role needs, on the basis of what the volunteer does and how often, not on who is watching. The school, not the mentoring scheme, holds that decision.
Scotland and Northern Ireland do it differently
Scotland does not use the DBS. A volunteer doing regulated work with children or protected adults in Scotland joins the PVG scheme, administered by Disclosure Scotland, and PVG membership is continuously updated rather than being a one-off certificate, so Disclosure Scotland can notify a registered organisation when new vetting information arises. Northern Ireland uses AccessNI, which issues basic, standard and enhanced checks, and an enhanced AccessNI check can include the barred lists. Those lists are maintained by the Disclosure and Barring Service for England, Wales and Northern Ireland alike, so Scotland is the only nation keeping its own. Writing “DBS” as though it covered the United Kingdom is the commonest error in guidance on this subject: a cross-border scheme needs a policy naming all three systems and saying which applies, based on where the volunteering happens.
What a check costs a charity
Checks are free of charge for volunteers meeting the DBS definition of a volunteer, which turns on the person receiving no payment beyond expenses and not benefiting from the role as an employee or trainee would. Three things sit around that mechanism.
- Apply through a registered or umbrella body, because a voluntary organisation ordinarily cannot submit standard or enhanced applications directly, and an umbrella body may charge its own administration fee even where the check itself is free.
- Expect to pay for paid staff, at fees set by the DBS and revised from time to time. Check the current fee with the DBS rather than any website, including this one, which publishes no fee amounts.
- Join the DBS Update Service, which allows a certificate to be reused where the level and workforce match. It is free to join for volunteers, whether joining is done with the volunteer application itself or against a certificate already issued, and each route has its own time limit, so decide at the point of applying rather than months later.
References, and what they are actually for
References find out what the check cannot see, which is how a person has behaved around other people. Two written references are the ordinary minimum for one-to-one work, from people who have known the applicant in a relevant capacity, not from a friend or a relative.
- Take up references before the interview, so anything odd can be asked about in the room rather than chased afterwards.
- Ask specific questions rather than for a character reference: has this person worked with children or vulnerable adults, why did it end, is there any reason they should not do so.
- Telephone the referee where a written reply is thin, and record what was said and when.
- Treat an unreturned reference as information rather than an administrative nuisance.
A certificate comes back with something disclosed on it
The volunteer is neither rejected automatically nor left in limbo. Only the applicant receives the certificate, so the coordinator asks to see it, arranges a private conversation, and weighs what the disclosure is, how long ago, how it relates to this role and what the person says about it. The decision is recorded with its reasons and taken by two people, one of whom did not recruit them. Barring is different from disclosure: it is a criminal offence to knowingly engage a barred person in regulated activity, and a barred list match ends the application rather than starting a discussion.
A clear certificate is the floor, never the decision
A clear certificate proves one thing: on the date it was issued, no relevant record was found. A check finds only what has been recorded, so it cannot identify somebody who has never been convicted or cautioned, and it says nothing about whether this applicant suits a particular referred child. That is why safer recruitment is a system rather than a search. There is also no expiry date on a certificate and no legal requirement to recheck at a fixed interval, so the scheme writes its own renewal period, justifies it and applies it to everyone.
The screening decision is built from six things together: an application form with a full history and any gaps explained, two references taken up properly, a structured interview asking directly about motivation and boundaries, the check at the correct level, a signed role description, and a probationary period with close supervision. Any one of the six failing is a reason to stop.
The volunteer being screened
- Discloses a full history, including anything that would appear on a check, before it is run
- Consents to the check and shows the certificate to the coordinator when it arrives
- Names referees who have known them in a relevant capacity
- Tells the scheme immediately if anything changes after clearance, including an arrest or a charge
The child or adult who will be visited
- Is entitled to a volunteer screened at the correct level for what that volunteer actually does
- Is entitled to be told, in plain terms, that checks were done, without seeing anybody’s personal data
- Is never matched with an applicant whose screening is incomplete, however long the waiting list
The scheme decides the level, records the reasoning, and holds the certificate details rather than a copy, which the DBS code of practice discourages keeping longer than necessary. It stores that data under UK GDPR and the Data Protection Act 2018, keeps recruitment records for unsuccessful applicants 6 to 12 months, volunteer files around 6 years after the volunteer leaves, and anything relating to a safeguarding concern about a child for decades: the Independent Inquiry into Child Sexual Abuse recommended 75 years. UK GDPR sets no fixed period; it requires the scheme to set one, justify it and apply it.