1. Our commitment
Luma Education Recruitment Ltd ("Luma") uses the Disclosure and Barring Service (DBS) to assess candidates' suitability for roles working with children. We comply fully with the DBS Code of Practice and are committed to treating every candidate fairly. A criminal record will not, on its own, stop someone working with us unless it makes them unsuitable for the role or the law prevents them from doing it.
We make this policy available to every candidate at the start of the recruitment process, and we will give a copy of the DBS Code of Practice to anyone who asks.
2. Which checks we ask for
- Roles in schools, colleges and early years settings that involve teaching, training, instructing, caring for or supervising children are regulated activity. Following the Crime and Policing Act 2026 there is no longer a "supervision exemption", so every Luma worker in these roles needs an enhanced DBS check with a children's barred list check for the child workforce.
- We only ask for checks at the level the role is legally eligible for, using the DBS eligibility guidance and tool where there is any doubt.
- If a candidate holds a certificate covering both the child and adult workforce for a role that is only eligible for the child workforce, we ask them to apply for a new child workforce certificate.
3. Asking about convictions
- Because roles working with children are covered by the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975, we can ask about unspent convictions and cautions and about spent convictions and cautions that are not protected under the DBS filtering rules. We never ask about protected (filtered) convictions or cautions, and we will not take them into account.
- Candidates complete a confidential self-declaration before an offer of work. The declaration is seen only by those who need to see it as part of the recruitment process.
- We select candidates for interview based on their skills, qualifications and experience. A declared conviction does not stop a candidate being interviewed.
4. Assessing a disclosure
Where a candidate declares a conviction or caution, or a DBS certificate contains information, a director who is trained in assessing criminal record information will:
- discuss the matter openly with the candidate before any decision is made;
- consider the nature and seriousness of the offence, how long ago it happened, the candidate's age at the time, any pattern of offending, what the candidate has done since, and how relevant it is to the role;
- take advice where needed, for example from the Teaching Regulation Agency or the Local Authority Designated Officer;
- record the decision and the reasons for it, and keep the risk assessment with the worker's file.
We will not place anyone who is barred from regulated activity with children, prohibited from teaching, or disqualified from childcare. Failing to disclose information that is relevant to the role may lead to an offer of work being withdrawn.
Where the certificate disclosed information and we decide to place the worker, we give the school a copy of the certificate before the worker starts, with the worker's knowledge, so the school can make its own decision.
5. DBS Update Service
We encourage every candidate to join the DBS Update Service within 30 days of their certificate being issued. With the worker's consent we check its status before the first placement and at least every 12 weeks while they work with us. If a status check shows new information, the worker must apply for a new enhanced certificate before they can be placed again.
6. Handling DBS certificate information
- Storage and access: certificate information is held securely in Matrix eBulk and Hello Edun, with access limited to the directors and staff who need it as part of their duties. It is never stored on personal devices or personal email.
- Use: it is used only for the purpose for which it was requested and with the candidate's consent.
- Sharing: it is shared with a school only where the certificate contains information and the worker knows we are doing so. It is never passed to anyone else unless the law requires it.
- Retention: we do not keep certificate information for longer than six months after the suitability decision, unless there is a dispute or the DBS agrees a longer period. After that we keep only the date of issue, the certificate number, the type of check, the Update Service status and the decision made.
- Disposal: copies are securely and permanently deleted. Luma works paperless; any paper copy is shredded.
7. Duty to refer
If we remove a worker from regulated activity, or would have done had they not left, because we believe they have harmed or posed a risk of harm to a child, we must refer them to the DBS. See section 13 of our Safeguarding and Child Protection Policy.
8. Training and review
Every director and member of staff involved in recruitment is trained to identify and assess the relevance of offences and in the legislation covering the employment of ex-offenders. This policy is reviewed every year alongside our Recruitment, Selection and Vetting Policy.