Security Industry Authority (SIA) said enhanced Disclosure and Barring Service (DBS) checks could lead to an extra £20 per case for Door Supervisor (DS) and Close Protection (CP) licence applicants.
As part of the government’s strategy to tackle violence against women and girls, the Home Office commissioned Simon Bailey, the National Police Chiefs’ Council lead for child protection and abuse investigation and a former Chief Constable of Norfolk Constabulary, to carry out a review of the effectiveness of the disclosure and barring regime in safeguarding children and vulnerable adults.
In his review, Mr Bailey said: “Door supervisors in premises licensed to supply alcohol are very often working in what is referred to as ‘the night-time economy’.
“Their position invests them with a degree of apparent power and authority.
“They may be dealing with people who have become intoxicated, whether voluntarily or involuntarily, by alcohol or drugs or both and in that condition may be extremely vulnerable.
“This contact is not limited to within the premises where they are working but can also take place in the surrounding area.
“Their work may also bring them into contact with children in premises licensed to supply alcohol or musical entertainment.”
Mr Bailey stated that it is obvious that this would provide an opportunity for abusive conduct: “The question is whether the risk presented by the existence of that potential opportunity requires an enhanced check with barred list check that, in addition to the criminal record disclosed in a standard check, would disclose whether the applicant was on a barred list and relevant information held by police forces about the applicant.”
Therefore, the SIA was consulted as part of this review and presented both the benefits and consequences of a decision taken to move to enhanced checks for DS and CP licences.
The SIA stated that applying enhanced checks to applicants for DS licences has significant financial implications and raises a number of potential difficulties as follows:
Cost to the applicant
A standard DBS check costs £18 and an enhanced check £38. The £20 extra per case would need to be passed on to licence applicants even where it would bring back no more information than a standard check.
Actual number of door supervisors as against the number of applicants
Less than 20% of applicants for door supervisors’ licences intend to work as such.
Reduction in labour supply due to cost and intrusion
Labour supply may also be affected through potential licence applicants being deterred by any additional cost and the intrusiveness of enhanced checks and choosing more attractive alternatives in a labour market favouring job seekers.
Delay in processing enhanced checks
The processing of enhanced checks will inevitably result in delays in some cases.
Use of SIA resources
There would also be further time, personnel resource and processing consequences for the SIA assessing any non-conviction information disclosed and needing to seek further information in order to make a licensing decision. (Words taken directly from the written submissions.)
Following the submissions of SIA, Mr Bailey concluded that “extra cost is unjustified because relevant information will only be disclosed in a small number of cases. If such an argument were valid, it would apply to all enhanced certificates.”
On the subject of actual number of door supervisors as against the number of applicants, Bailey concluded that this “cannot provide a basis for not extending enhanced checks to this licence, which authorises the holder to work in that capacity and provides evidence that they are considered fit and proper so to do.”
In conclusion, Mr Bailey said that “the potential risk to both adults and children posed by encounters with door supervisors justifies, indeed requires, the extra level of safeguarding provided by enhanced DBS checks together with barred lists checks.”
Mr Bailey added: “I recommend that enhanced DBS checks together with barred lists checks are made mandatory for applicants for the grant or renewal of a door supervisor’s licence.”
Mr Bailey repeated his recommendation for Close Protection licences as well.
The SIA has noted the review’s recommendations for enhanced DBS checks to be carried out on individuals applying for either a door supervisor or close protection licence.
The recommendations of this review are now with the Home Office for their consideration.
(Source: SIA and The Independent Review of the Disclosure and Barring Regime)
