Recruitment, Selection and Vetting Policy 


1 Introduction  

County Teachers Ltd is an employment business supplying temporary workers to work within  the education sector. The work seekers that we engage must pass thorough and robust  vetting procedures before we can consider them for any placement or assignment with our  clients and this policy sets out our commitment to comply with the highest standards at each  stage of the recruitment process. 

Our processes are compliant with relevant legislation and the Department for Education’s  statutory guidance: Keeping Children Safe in Education. We ensure our temporary workers  remain compliant throughout their time with County Teachers Ltd by undertaking the checks  set out in this policy.  

We have processes in place whereby we obtain feedback from our clients once placements  are made. 


2 Recruitment and Selection 

2.1 Face to face interviews 

Before placing any work seekers on assignments, County Teachers Ltd meets with them face  to face. Before meeting the work seeker, we ask them to forward a copy of their CV and  advise them of the documentation they are required to bring with them to the interview. 

During the interview, a qualified consultant will assess the work seekers suitability for the role  by discussing their previous work history and qualifications.  

Provided the outcome of the interview is satisfactory, County Teachers Ltd will then start the  pre-employment checks. 

2.2 Right to work checks 

County Teachers Ltd conducts right to work checks on every work seeker we intend to supply  to our clients in order to comply with immigration and equality law. We follow the three-step  process set out in the Home Office Guidance: An employer’s guide to right to work checks: 

  • Step one: 

We obtain the work seekers original documents. The work seeker must provide us with either  one document from LIST A of the Home Office right to work checklist or any of the  documents or combination of documents from LIST B of the checklist. We only accept  original documents. Photocopies or electronic scans are not acceptable. 

  • Step two: 

We take reasonable steps to check that the document is valid and that the work seeker is  the person named in the document. 

For each document we complete the following checks: 

  • check any photographs are consistent with the appearance of the work seeker; check any dates of birth listed are consistent across documents and that we are  satisfied that these correspond with the appearance of the work seeker; 
  • check that the expiry date for permission to be in the UK has not passed; 
  • check that the documents are valid and genuine, have not been tampered with  and belong to the holder; and 
  • if given two documents which have different names, we ask for a further document  to explain the reason for this. The further document could be a marriage certificate, a  divorce decree absolute, a deed poll or a statutory declaration. 


  • Step three: 

We make a copy of the relevant page/s of the document in a format which cannot be  subsequently altered. This can include a photocopy or a scan or where we take an  electronic copy, this will be in a non-rewritable format. 

Where the work seeker has provided us with a passport, we will photocopy or scan the  following: any page with the document expiry date, the holder’s nationality, date of birth,  signature, leave expiry date, biometric details, photograph and any page containing  information indicating that the holder has an entitlement to enter or remain in the UK and  undertake the work in question. 

For all other documents, we make a clear copy or scan of the document in full, including  both sides of a Biometric Residence Permit. 

All copies of documents taken will be kept securely for the duration of the work-seekers  engagement with County Teachers Ltd and for two years afterwards. The copy will then be  securely destroyed.  

2.3 ID checks and proof of address 

In addition to the above right to work documents, we also require the work seeker to provide  us with two documents to confirm their identity and proof of address. The type of documents  that we accept are: driving licence, utility bill, bank statement, government document/letter  which includes the work seekers national insurance number. 

Copies of documents will be taken and noted with the date the documents were checked.  Copies will be kept securely for the duration of the work-seekers engagement with County  Teachers Ltd and for at least 1 year after. The copy will then be securely destroyed. 

2.4 References 

In accordance with Regulation 22 of the Conduct of Employment Agencies and  Employment Businesses Regulations 2003 (and the terms of the Crown Commercial Service  (CCS) Framework), we require (at least) two references that must cover the previous two  years of employment for all work seekers. One reference must be from the work seekers’  most recent employer. References must be from non-family members who give their consent  for the reference to be forwarded to our clients.

We will verify all references by contacting the referees directly, either by telephone or email. 

Verbal references will be recorded, and a copy of the record will be sent to the referee via  their school email address to obtain their written confirmation that the record is correct and  their consent to forward it to a third party. If the referee does not provide their written  confirmation that the record is correct and give their consent, the reference will not be  accepted. 

Open references may be accepted, provided that they include the following information: 

  • the dates between which the work seeker worked for or with the referee; 
  • the role the work seeker undertook; 
  • whether the work seeker is deemed suitable to work with children; 
  • whether the referee would re-employ the work seeker; and 
  • whether the work seeker was subject to any disciplinary action and the circumstances, if  any. 

References from other employment businesses must, as a minimum, include dates of  employment and details of any safeguarding issues if they are known. 


3 Vetting 

3.1 Rehabilitation of Offenders Act Declaration 

During the registration process, all work seekers are required to complete our Rehabilitation  of Offenders Act Declaration and, as required for regulated sectors, disclose all spent and  unspent convictions, subject to the filtering rules. 

If a work-seeker discloses any convictions, County Teachers Ltd will consult with the Teacher  Regulation Agency, or for Wales, the Education Workforce Council, and the REC’s legal  helpline to obtain advice and guidance on whether the work seeker can work in the  education sector. 

3.2 Rehabilitation of Offenders Policy 

As an organisation assessing applicants’ suitability for positions which are included in the  Rehabilitation of Offenders Act 1974 (Exceptions) Order and using criminal record checks  processed through the Disclosure and Barring Service (DBS), County Teachers Ltd fully with  the DBS code of practice and undertakes to treat all applicants for positions fairly. 

County Teachers Ltd undertakes not to discriminate unfairly against any subject of a criminal  record check on the basis of a conviction or other information revealed. 

County Teachers Ltd can only ask an individual to provide details of convictions and  cautions that County Teachers Ltd are legally entitled to know about. Where a DBS  certificate at either standard or enhanced level can legally be requested (where the  position is one that is included in the Rehabilitation of Offenders Act 1974 (Exceptions) Order  1975 as amended), and where appropriate (Police Act Regulations as amended), 

County Teachers Ltd can only ask an individual about convictions and cautions that are not  protected.


County Teachers Ltd is committed to the fair treatment of its staff, potential staff, or users of its  services, regardless of race, gender, religion, sexual orientation, responsibilities for  dependents, age, physical/mental disability, or offending background. 

County Teachers Ltd has a written policy on the recruitment of ex-offenders, which is made  available to all DBS applicants at the start of the recruitment process. 

County Teachers Ltd actively promotes equality of opportunity for all with the right mix of  talent, skills and potential and welcome applications from a wide range of candidates,  including those with criminal records. 

County Teachers Ltd select all candidates for interview based on their skills, qualifications,  and experience. 

County Teachers Ltd ensures that all staff of County Teachers Ltd who are involved in the  recruitment process have been suitably trained to identify and assess the relevance and  circumstances of offences. 

County Teachers Ltd also ensures that they have received appropriate guidance and  training in the relevant legislation relating to the employment of ex-offenders, e.g., the  Rehabilitation of Offenders Act 1974. 

At interview, or in a separate discussion, County Teachers Ltd ensures that an open and  measured discussion takes place on the subject of any offences or other matter that might  be relevant to the position. Failure to reveal information that is directly relevant to the  position sought could lead to withdrawal of an offer of employment/assignment. 

County Teachers Ltd undertakes to discuss any matter revealed on a DBS certificate with the  individual seeking the position before withdrawing a conditional offer of employment. 

3.3 Disclosure and Barring Service and Update Service checks 

County Teachers Ltd requires all our work seekers to have an enhanced Disclosure and  Barring Service (DBS) check which includes a check on the Children’s Barred List.  

We view and take a copy of the original DBS certificate and, with consent from the work  seeker, carry out a status check on the DBS Update Service. We record details of the check  and the date the check is undertaken on the work seeker’s file. If the Update Service check  states that there is new information, we will require the work seeker to apply for a new DBS  certificate before proceeding with their registration. 

If a work seeker wishes to register with County Teachers Ltd and they are not already on the  Update Service, a new DBS check will be required, and we would encourage the work  seeker to subscribe to the Update Service. If they do not subscribe to the Update Service,  we will require a new DBS check to be undertaken at least once a year. 

County Teachers Ltd will undertake repeat status checks on the Update Service at least  once a year, or more often if required by our clients, but no more than four times a year. We  always obtain the work seeker’s consent to undertake a status check. 

If the DBS check shows details of a conviction or caution, in line with the Rehabilitation of  Offenders Act 2014, we must email a copy of the DBS to the school. 

Following the decision of the Department for Education to remove access to the stand-alone  Barred List checking system for employment businesses from 1 April 2021, we cannot conduct  this standalone check and we will not place any work seekers in a role without a full  enhanced DBS check being completed. This check includes a Barred List check. 

When reviewing a work seeker’s DBS certificate, County Teachers Ltd will check that the  certificate is for Child Workforce only and status checks on the Update Service will only be for  Child Workforce. 

The definition of ‘work with adults’, as set out in the Police Act 1997 (Criminal Records)  Regulations is narrower than the definition of ‘work with children’ and refers to providing  personal care to the adult. It is, therefore, not always the case that we will be entitled to  view information relating to the adult barred lists. If there is any uncertainty as to whether a  particular role is eligible for a criminal record check, we can use the DBS eligibility tool and, if  necessary, obtain guidance from the DBS.  

If a particular role is not eligible for an enhanced check against both the child and adult  barred lists, we must not proceed with the check and if the work seeker has an existing DBS  certificate covering both child and adult workforce, we will require them to undertake a new DBS for child workforce only. 

3.4 Overseas Police Checks 

All work seekers who have lived and worked in a single overseas country for more than six  months in the last five years must provide an overseas police check. 

If the work seeker is unable to provide a police check from the relevant country (for  example, if the relevant country does not provide police checks), County Teachers Ltd may  accept a statement of good conduct from the work seeker’s previous employer within the  relevant country. We would require the statement to include confirmation that, to the best  of their knowledge, the work seeker has no criminal convictions and that they know of no  reason why the work seeker should not work with children. 

If we are unable to obtain a police check or a statement of good conduct, we will not  proceed with the registration of the work seeker. 

3.5 Letter of professional standing for work seekers that have lived or worked overseas 

For work seekers seeking teaching roles, that have lived or worked overseas, County  Teachers Ltd will request sight of a letter of professional standing issued by the professional  regulatory authority where the individual worked. This check is completed to confirm the  work seekers suitability for the role in line with County Teachers Ltd obligations under the  Conduct Regulations.  

Where the letter cannot be obtained and all reasonably practicable steps have been taken  to obtain it, County Teachers Ltd will request the work seeker to provide an alternative  document which confirms their suitability for the role. This may be a letter of good standing  from the head teacher in the school that they worked in or additional professional references. In such a case where the letter of professional standing cannot be obtained,  County Teachers Ltd may also refer to the Teacher Regulation Authority Country Evidence  table for guidance on what other document/s might confirm suitability.  

County Teachers Ltd will then inform the client of the steps taken to comply with the  suitability requirements which are set out in Regulation 22 of the Conduct Regulations. 

3.6 Qualifications and early career teachers (ECTs) 

Where the client, legislation or any professional body requires the work seeker to have a  particular qualification or authorisation to work in the position offered by the client, we will  obtain copies of original qualifications and authorisations and these will be available to our  clients upon request. 

Under the Education (School Teacher’s Qualifications) (England) Regulations 2003, work  seekers being supplied into a teaching position must be qualified to teach. In addition to  checking the qualifications, we will also check the teacher’s qualified teacher status via the  Teacher Regulation Agency online portal. Please see further details below. 

We will check overseas qualifications via the UK’s National Recognition Information Centre. 3.7 Teacher Regulation Agency / Education Workforce Council (Wales) 

County Teachers Ltd will undertake checks via the Teacher Regulation Authority (TRA), or in  Wales, the Education Workforce Council (EWC), to check a teachers UK qualified teacher  status to ensure that qualification certificates are genuine and that there are no prohibitions  or sanctions imposed against the work seeker. We will retain a screen print on the teacher’s  file as a record of these checks. 

Additionally, we will undertake a check for all non-teaching support staff to ensure that there  are no prohibitions or restrictions. A record of this check will be noted on the work seeker’s  file. If a prohibition or restriction is imposed, we will retain a screen print. 

3.8 Referrals 

County Teachers Ltd as an employment business is a ‘personnel supplier’ and has a legal  requirement under the Safeguarding Vulnerable Groups Act 2006 to refer information to the  DBS about individuals who have either harmed, or placed at risk of harm, a child or  vulnerable adult. 

Where County Teachers Ltd supplies or introduces a work seeker to a client, and the client  subsequently removes the work seeker from carrying out ‘regulated activity’ because the  client believes that the person has engaged in ‘relevant conduct’ or the ‘harm test’ is  satisfied, County Teachers Ltd must provide information to the DBS about this matter.  Additionally, if County Teachers Ltd decides to withdraw our services from the work seeker  because we believe that the work seeker engaged in ‘relevant conduct’ or that the ‘harm  test’ is satisfied, we must provide information to the DBS about this.

‘Relevant conduct’ is defined as: 

  • Conduct which endangers a child or vulnerable adult or is likely to endanger a child  or vulnerable adult, 
  • Conduct which, if repeated against a child or vulnerable adult would endanger or  would be likely to endanger him, 
  • Conduct involving sexual material relating to children (including possession of such  material), 
  • Conduct involving sexually explicit images depicting violence against human beings, Conduct of a sexual nature involving a child or vulnerable adult. 

County Teachers Ltd has a duty to refer information to the DBS if the ‘harm test’ is satisfied,  i.e. if County Teachers Ltd thinks that that the person may: 

  • Harm a child or vulnerable adult, 
  • Cause a child or vulnerable adult to be harmed, 
  • Put a child or vulnerable adult at risk of harm, 
  • Attempt to harm a child or vulnerable adult,  
  • Incite another to harm a child or vulnerable adult. 

To ensure compliance with the DBS referral rules, we have processes in place to ensure that  all staff are aware of the legal duty to make a DBS referral where necessary and know the  process for doing so.  

3.9 Fitness to teach 

To ensure compliance with the Education (Health Standards) (England) Regulations 2002, County Teachers Ltd will ask all work seekers to advise us of any health or disability issues that  they believe are relevant to the role and which make it difficult for them to carry out  functions that are essential to the role.  

If a declaration is made, with consent from the work seeker, we will obtain confirmation from  the work seeker’s doctor that the work seeker is fit to teach. If we are unable to obtain this  confirmation we will not proceed with the registration. 

If a teacher has been retired on medical grounds by the Department of Education after 1  April 1997, the teacher will not be able to teach as they have been considered medically  unfit. However, if the retirement was before 1 April 1997, the teacher may be able to work if  they can evidence that they have the health and physical capacity to teach. This can be  achieved by obtaining confirmation, in writing, from a GP. In these instances, they can only  work a maximum of 2.5 days per week. 

3.10 Disqualification 

In order for County Teachers Ltd to comply with our obligations under the Childcare Act 2006 and the Childcare (Disqualification) and Childcare (Early Years Provision Free of Charge)  Extended Entitlement (Amendment) Regulations 2018, we must carry out appropriate checks  to ensure that work seekers are not disqualified from teaching. Under the rules, individuals  can either be disqualified from carrying out work with children in their own right, or  disqualified by association because they live with somebody, or have somebody working in  their home, who is disqualified. 


3.10.1 Disqualification by association checks  

Changes to the disqualification rules were introduced in 2018 and since then, disqualification  by association only applies to those who work in childcare in a domestic setting, such as in a  childminder’s home (previously it applied in schools and non-domestic settings such as  nurseries).  

For roles involving childcare which is carried in a domestic setting only, we will require a  disqualification by association declaration to be signed by candidates before we place  them in any roles. 

3.10.2 Disqualification checks  

Disqualification checks are required for all candidates who are seeking work which involves  ‘relevant childcare roles’, such as: 

  • provision of early years childcare 
  • later years childcare in nursery, primary or secondary school settings 
  • staff directly concerned with the management of the above.  

For candidates who do not work in these ‘relevant childcare roles’, we will not conduct  disqualification checks. For example, the following roles are not covered, staff who: 

  • only provide education, childcare or supervised activity during school hours to children above reception age; or 
  • only provide childcare or supervised activities out of school hours for children who are aged 8 or over; and 
  • are not involved in the management of relevant provision. 


4 Other checks 

4.1 Continued suitability 

In order to ensure that all work seekers registered with County Teachers Ltd meet  safeguarding and suitability requirements on an ongoing basis, at least once a year we will  conduct status and Teacher Regulation Authority/Education Workforce Council checks  (subject to any shorter period imposed by a client). 

Where a work seeker has not worked with us for a period of three to six months, we will  conduct status and Teacher Regulation Authority/Education Workforce Council checks and  obtain an additional reference/s to cover the period in question.  

Where a work-seeker has not worked with us for over a year the registration process will be  repeated in full.


Right to work checks  

On 31 March 2020, the Government announced adjustments to right to work checks, making  it easier for employers to recruit. The changes allow agencies to carry out checks remotely;  whereby the candidate first submits a photo or scanned copy of the original document and  then, during a video call, holds up the original document to the camera for the employer to  see and compare to the photo or scanned document.  

Alternatively, where applicable, you can use the Home Office right to work online service,  where information is provided in real-time direct from Home Office systems and does not  require you to see or check the individual’s physical documents. However, employers cannot  insist individuals use this service or discriminate against those who choose to use their  documents to prove their right to work.