Policy owner: HR Compliance / Safeguarding Team
Applies to: HR managers, recruiting managers, countersignatories, and any colleague responsible for initiating or submitting Disclosure and Barring Service (DBS) applications.
1. Purpose
This policy explains when and why the organisation may reject, withdraw, or return DBS applications where HR managers or other authorised submitters provide incorrect, incomplete, inconsistent, or unsupported information. The aim is to protect applicants, maintain safeguarding standards, avoid unnecessary delays, and ensure DBS checks are completed using accurate information.
2. Policy statement
The organisation will not knowingly submit a DBS application that contains inaccurate, incomplete, or unverified information. Where an application has already been started or submitted internally and errors are identified before final submission to DBS or the umbrella body, the application may be rejected or returned for correction. Rejection is a quality-control step and does not, by itself, indicate any concern about the applicant's suitability.
3. Scope
This policy applies to all DBS application types processed by or on behalf of the organisation, including Basic, Standard, Enhanced, and Enhanced with Barred List checks, where applicable. It applies to new starters, existing staff, agency workers, contractors, volunteers, and any other individuals for whom the organisation requests a DBS check.
4. Why accurate DBS information matters
DBS checks support safer recruitment decisions and rely on accurate identity, role, address, and eligibility information. Incorrect information may prevent DBS from completing a full and accurate check, may delay recruitment or onboarding, and may create safeguarding, compliance, data protection, and audit risks for the organisation.
5. Grounds for rejecting an application
An application may be rejected, withdrawn, or returned for correction where one or more of the following issues are identified:
- Incorrect applicant identity information: name, previous names, date of birth, address history, National Insurance number, passport details, driving licence details, or other identity data does not match the evidence provided.
- Incomplete address history: the applicant's address history does not cover the required period, contains unexplained gaps, or is inconsistent with supporting documents.
- Wrong DBS check level: the requested check level does not match the role's eligibility or legal requirements. Where the wrong level of DBS check has been selected, the HR manager must follow the DBS eligibility guidance published on GOV.UK before the application is corrected or resubmitted.
- Incorrect workforce or barred list information: the application identifies the wrong workforce category or requests a barred list check that is not appropriate for the role.
- Incorrect role title or employer details: the position applied for, employing entity, or location is wrong or misleading.
6. Responsibilities
HR managers / recruiting managers
Ensure all application information is accurate, complete, role-appropriate, and supported by the correct identity evidence before submission.
Applicant
Provide accurate personal information, full address history, previous names, required identity documents, and consent.
HR Compliance / Safeguarding Team
Review applications, identify errors, reject or return applications where required, and maintain records of decisions.
Countersignatory or authorised submitter
Confirm the application is complete, accurate, eligible, and submitted in line with DBS requirements and internal policy.
Senior HR lead
Review escalated or repeated errors and approve any exceptions where permitted by law and internal governance.
7. Rejection and correction process
- Initial review: HR Compliance reviews the application against DBS requirements, role eligibility, identity evidence, and internal records.
- Error identified: if information is incorrect, incomplete, or unsupported, HR Compliance records the issue and determines whether it can be corrected or whether the application must be rejected and restarted.
- Notification: the HR manager is notified of the reason for rejection or return, the corrective action required, and any impact on start date or deployment. Where the information submitted is otherwise correct but the application is still rejected or returned, the specific reason for that decision will be relayed clearly to the HR manager.
- Applicant involvement: where applicant information is affected, the applicant must be asked to confirm or correct the information. Application details must not be amended without the applicant's knowledge and agreement.
- Resubmission: the application may only be resubmitted once all required corrections, documents, consents, and approvals have been completed.
- Escalation: repeated errors, disputed decisions, or urgent safeguarding concerns must be escalated to the Senior HR lead or designated safeguarding lead.
8. Communication standards
All rejection or return communications must be factual, respectful, and limited to the reason for the application issue. Where application information has been correctly submitted, the organisation will still explain the reason for any rejection, return, or request for further action. Communications must avoid implying that the applicant has failed a DBS check where the issue relates only to application information or DBS check eligibility.
9. Records and audit trail
The organisation will keep an audit record of rejected or returned applications, including the applicant reference, role, submitting manager, reason for rejection, corrective action requested, date of decision, and resubmission outcome. Records must be retained in line with the organisation's data protection and retention policies.
10. Repeated errors and training
Where an HR manager repeatedly submits incorrect DBS applications, the organisation may require refresher training, closer pre-submission checks, or temporary removal of DBS submission access. The purpose of this action is to improve compliance and reduce safeguarding and operational risk.
11. Exceptions
Exceptions to this policy may only be approved where permitted by DBS rules, safeguarding requirements, and internal governance. Exceptions must be documented, justified, and approved by the Senior HR lead or another authorised senior decision-maker.
12. Review and governance
This policy will be reviewed at least annually or sooner if DBS guidance, safeguarding legislation, recruitment processes, or internal governance requirements change.