Recruitment, Selection and Vetting Policy

Our rule is 100% clearance. No worker starts any assignment until every check in this policy has been completed, recorded and confirmed to the school in writing. If a check is not complete in time, the start date moves.

1. Introduction

Luma Education Recruitment Ltd ("Luma") is an employment business supplying teachers, support staff and other temporary workers to schools, colleges and early years settings. Every work-seeker must pass the checks in this policy before we consider them for any assignment.

Keeping Children Safe in Education 2026 (KCSIE, paragraph 364) requires schools to obtain written confirmation from an agency that it has carried out the same checks the school would carry out for a direct appointment. This policy sets out how we meet that standard, together with the Conduct of Employment Agencies and Employment Businesses Regulations 2003 (the Conduct Regulations), the requirements of the GCA RM6376 and HEART Academies / Value Match frameworks, and APSCo Compliance+ Education Standards.

It should be read with our Safeguarding and Child Protection Policy, our Recruitment of Ex-Offenders and DBS Policy, our Code of Conduct and our Data Retention Schedule. Where KCSIE or a framework sets a higher standard than this policy, the higher standard applies.

2. Safer recruitment

• Every director and consultant who recruits completes safer recruitment training, refreshed at least every three years.
• Job adverts and role descriptions state our commitment to safeguarding and that the role is subject to an enhanced DBS check with children's barred list.
• Candidates complete a full application, including full employment history since leaving school. A CV alone is not accepted.
• We make reasonable adjustments at every stage for disabled candidates, in line with our Equal Opportunities Policy.

3. Interview

Before placing anyone, a Luma consultant interviews them face to face, in person or by video (not by telephone). The interview uses a standard set of questions so every candidate is assessed in the same way, and covers:

• motivation to work with children, professional boundaries and safeguarding knowledge;
• employment history, with any gaps and inconsistencies explored and explained;
• qualifications, experience and the requirements of the roles they are seeking.

A written record of the interview is kept on the candidate's file. Provided the outcome is satisfactory, we start the pre-placement checks.

4. Pre-placement checks

Framework requirements

For placements under the GCA RM6376 and HEART Academies / Value Match frameworks we also make sure the enhanced DBS has been checked within the last 12 months, the candidate has signed a Rehabilitation of Offenders Act declaration, and the candidate has been told they must report any investigation or prosecution. Documents are held to each framework's document standard.

5. Confirming checks to schools

• Before each worker starts, we send the school written confirmation of every check carried out, with dates and DBS details, so the school can complete its single central record.
• Where an enhanced DBS certificate disclosed information, we give the school a copy before the worker starts, with the worker's knowledge.
• We ask schools to check, when the worker arrives, that the person in front of them is the person on whom the checks were made.

6. Keeping workers compliant

• We check the DBS Update Service status of every active worker at least every 12 weeks, with consent.
• A worker who has not been placed for 12 weeks or more is re-checked before their next assignment, including an Update Service status check, a prohibition check and, where the gap is not otherwise accounted for, an additional reference.
• Registration details, right to work, DBS status and training are fully reconfirmed at least once a year.
• Workers must tell us immediately of any arrest, caution, charge, conviction, investigation or other change that could affect their suitability. We tell the school straight away if we learn anything that suggests a worker may be unsuitable.
• We collect feedback from schools on every placement and act on any concern under our Safeguarding and Child Protection Policy.

7. Referrals

As an employment business, Luma is a "personnel supplier" under the Safeguarding Vulnerable Groups Act 2006. We must refer a worker to the DBS where we remove them from regulated activity (or would have done had they not left) because we believe they have engaged in relevant conduct, the harm test is satisfied, or they have received a caution or conviction for a relevant offence. Where we stop supplying a teacher because of serious misconduct, we consider a referral to the Teaching Regulation Agency. Section 13 of our Safeguarding and Child Protection Policy sets out the procedure.

8. Records and data protection

Recruitment and compliance records are held securely in Hello Edun and Microsoft 365, with access limited to authorised staff. DBS certificate information is handled under the DBS Code of Practice and is not kept beyond six months after the suitability decision. Right to work records are kept for the duration of engagement plus two years, and placed workers' compliance files for six years after their last assignment, as set out in our Data Retention Schedule.

9. Monitoring and review

The Designated Safeguarding Lead audits a sample of worker compliance files every month against this policy and reports the results to the directors. This policy is reviewed every year, or sooner if KCSIE, legislation, framework requirements or an audit finding require it.

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