Specialist Vetting & Criminal Records Policy

Remarkable Minds introduces families, schools and local authorities to specialists and tutors who support neurodivergent children and young people. That work is often one to one, sometimes in a child’s own home, and always with children who may be more vulnerable to harm than their peers.

Safer recruitment is the single most effective thing we can do to prevent harm. Nobody takes a booking through Remarkable Minds until their vetting is complete and verified by a person, not by an automated process. This policy explains what we ask for, what we do with it, how long we keep it, and what happens if something is disclosed.

It should be read with our Safeguarding and Child Protection Policy, the Specialist and Tutor Agreement and our privacy policy.

Five things are collected through the specialist’s Remarkable Minds account. The first three are required of everyone before we will verify them. The last two are asked for but not insisted on at this stage, because a DBS held on the Update Service can be checked online without a copy, and not every specialist carries their own cover:

• Photo identity. A government-issued document showing their photograph: a passport photo page, a UK or EU photocard driving licence, or a national identity card.
• Proof of right to work in the UK. Evidenced in its own right, separately from photo identity, even where one document could cover both. A UK or Irish passport, a Home Office share code, a biometric residence permit, or a certificate of registration or naturalisation.
• A CV or LinkedIn profile showing tutoring or teaching history and experience of working with neurodivergent children. A public LinkedIn address is an acceptable substitute for a file.
• A DBS certificate. An Enhanced DBS certificate with a Children’s Barred List check for England and Wales, a PVG scheme record for Scotland, or an AccessNI Enhanced disclosure for Northern Ireland. Where a specialist subscribes to the DBS Update Service we run an online status check instead of taking a copy.
• Proof of insurance. A certificate or schedule showing a minimum of £1m Professional Indemnity and £5m Public Liability cover, with the limits and the expiry date visible.

Alongside the documents, every specialist reads and accepts a set of agreements, and we record which version they accepted and when:

• The Specialist and Tutor Agreement
• Their Key Information Document, personalised to them, setting out what they will be paid, who pays them and what comes out of it
• Consent to session recording under our Session Recording and Transcription Policy
• Our Safeguarding and Child Protection Policy
• Our Code of Conduct and Online Tutoring Rules

Accepting the Specialist and Tutor Agreement carries a continuing duty to tell us straight away if anything changes that we would want to know about: a DBS that lapses, insurance that lapses, a caution or conviction, or action by a professional regulator.

Identity and right to work

We check the identity document is intact and unaltered, that the photograph matches the person on a live video call, and that the name matches the rest of the pack. Right-to-work evidence is checked in line with Home Office guidance, including validating a share code online where one is given. We record that the check was done, by whom and on what date.

The DBS check

We verify a DBS in one of two ways, and we record which:

• Original certificate sighted. A named member of our team views the original paper certificate, in person or on a live video call where the certificate is held up and read.
• Update Service status check. Where the specialist subscribes to the DBS Update Service and gives us their consent and certificate number, we run an online status check and rely on the result.

Against the check we record only: the scheme (DBS, PVG or AccessNI), the certificate number, the level of check, the workforce it covers, the issue date, the method used, the name of the person who verified it, and the date they verified it. We satisfy ourselves that the level and workforce are right for the work, which for one-to-one work with children means an Enhanced check with a Children’s Barred List check.

We do not keep a copy of the certificate. See section 6.

Qualifications and what a specialist may claim

We verify qualifications and registrations with the awarding body or the regulator directly, not from the certificate alone. Verified status then gates the language a specialist is allowed to use on their profile and with families:

• No use of the words assessment, assess, diagnosis or diagnose without a current Level 7 Assessment Practising Certificate or an equivalent recognised practising certificate
• No clinical or therapeutic titles or language without current registration with the HCPC, the British Psychological Society or the BACP, and the register is named on the profile
• Qualified Teacher Status, SENDCo status and specialist qualifications are shown only where we have confirmed them

Remarkable Minds itself does not carry out assessments or diagnosis of any kind and is not a clinic or a healthcare provider. Gating claims is how we keep that promise honest.

Insurance

We check the limits and the expiry date, record the renewal date, and prompt the specialist before it lapses. Cover must be continuous for as long as they take work through us.

Uploaded documents go into a private store that is not linked from any public page, is not indexed, and cannot be reached by guessing an address. Documents are encrypted in transit and at rest and are held in the United Kingdom or the European Economic Area.

Access is limited to the named person carrying out the check and to the Designated Safeguarding Lead. There is no browsing access: every document is retrieved through a short-lived link generated for a named, authenticated staff member at the moment they need it, and that link expires within minutes. Every upload, view, decision and deletion is written to an audit log with the person, the action and the timestamp.

Documents are never emailed, never copied to a personal device, never placed in a shared drive, and never sent to a client. A family or a school is told that a specialist is verified, not what they sent us.

We hold two different things for two different lengths of time.

• Documents (identity, right to work, CV, insurance) are kept while a specialist is active in the network and are deleted within six months of them leaving, unless a safeguarding matter, complaint or legal claim requires us to keep them longer.
• The audit record of the checks (what was checked, by whom, on what date, and the DBS certificate details) is kept for at least one year after the last introduction ends, and normally for six years, so that we can evidence that a proper check was carried out if a concern is raised later. This reflects safer-recruitment expectations and the limitation period for a civil claim.
• Copies of DBS certificates are deleted as soon as the check is verified. See section 6.
• Records of acceptance of the agreements (which document, which version, which date) are kept for as long as the audit record.

An unfinished application from someone who never joins is deleted within twelve months of their last activity.

This section is our Appropriate Policy Document for the purposes of Schedule 1, Part 4 of the Data Protection Act 2018. It applies to our processing of criminal-offence data under Article 10 of the UK GDPR, and to special-category data processed under a Schedule 1 condition.

6.1 The data we process and why

We process criminal-offence data in the form of DBS, PVG and AccessNI certificate information about people who apply to work with children through Remarkable Minds. This includes the fact and level of a check, the certificate number and issue date, barred-list status, and anything disclosed on a certificate. We process it for one purpose only: deciding whether a person is suitable to work with children and young people through our service, and evidencing that decision.

6.2 The condition we rely on

For criminal-offence data our lawful basis under Article 6 is our legitimate interests in protecting children, and our condition under section 10(5) of the Data Protection Act 2018 is the condition for safeguarding of children and of individuals at risk in paragraph 18 of Part 2 of Schedule 1. Processing is necessary to protect people under 18 from neglect and from physical, mental or emotional harm, it is in the substantial public interest, and asking for consent would not be an appropriate safeguard because consent could not be freely given in a recruitment context.

Where we process special-category data as part of vetting, for example health information a specialist volunteers about a reasonable adjustment, we rely on the employment condition in paragraph 1 of Part 1 of Schedule 1, or on the same safeguarding condition where a safeguarding purpose applies. Right-to-work checks are carried out to comply with our obligations under the Immigration Act 2016 and associated Home Office guidance.

6.3 Procedures for complying with the data-protection principles

• Lawfulness, fairness and transparency. We publish this policy, we tell every applicant what we will ask for and why before they upload anything, and we tell them the outcome of the check and the reasons for it.
• Purpose limitation. Vetting data is used only to decide suitability and to evidence that decision. It is never used for marketing, for profiling, for training artificial intelligence models, or for any automated decision-making. A human always makes the decision.
• Data minimisation. We ask for the smallest set of documents that lets us make a safe decision, we record certificate details rather than keeping certificates, and we do not ask about spent cautions and convictions that are protected from disclosure under the filtering rules.
• Accuracy. Details are entered from the original document or the Update Service result by the person verifying, are checked against the applicant’s own entry, and can be corrected on request. Specialists are under a continuing contractual duty to tell us if anything changes.
• Storage limitation. Retention periods are set out in sections 5 and 6.4, deletion of DBS copies is carried out at the point of verification, and retention is reviewed annually.
• Integrity and confidentiality. Encryption in transit and at rest, a private store, access limited to named individuals on a need-to-know basis, short-lived retrieval links, multi-factor authentication, and a full audit log of every access and deletion.
• Accountability. The Designated Safeguarding Lead owns this policy, holds the record of processing activities, reviews the audit log, and reviews this document at least annually.

6.4 Retention and erasure of criminal-offence data

We do not retain scans or photographs of DBS, PVG or AccessNI certificates. Where a certificate is uploaded so that we can verify it, the uploaded copy is deleted from the private store as soon as the verification is recorded, and in any event within 28 days of the check being completed. The deletion is logged.

What we keep is the record of the check itself: the scheme, the certificate number, the level, the workforce, the issue date, the verification method, the verifier and the date verified. That record is kept for at least one year after the specialist’s last introduction ends, and normally for six years, so that we can show a proper check was made if a question arises later.

Where something is disclosed on a certificate, we record only a short note of the decision we reached and the reasons for it, not a copy of the disclosure. That note is kept for the same period and then deleted. Nothing is kept indefinitely, and deletion is scheduled rather than left to memory.

A caution or a conviction does not automatically stop someone working through Remarkable Minds. Everything is considered individually. A person on a barred list is the one absolute bar, because it is a criminal offence for them to work in regulated activity with children.

Otherwise, we look at:

• Whether the matter is relevant to working with children and young people
• How serious it was, and whether there is a pattern rather than a single incident
• How long ago it happened and how old the person was at the time
• The circumstances, including anything that explains or mitigates it
• Whether it was declared openly at the start, or only came to light through the check
• What has changed since, including training, references and current practice
• Whether a risk assessment and any conditions could make the work safe

Before any decision is made, the person is told what has been disclosed and is given a fair opportunity to explain it in writing or on a call. The decision is made by the Designated Safeguarding Lead, recorded with reasons, and communicated in writing. We do not ask about protected cautions and convictions that are filtered from disclosure, and we do not take them into account.

Where a decision goes against someone, they can ask us to look at it again through our complaints policy. Where a check itself appears wrong, they should raise a dispute directly with the DBS, Disclosure Scotland or AccessNI, and we will pause our decision while that is resolved.

Vetting is a continuing process, not a one-off gate. A DBS certificate has no expiry date, so we treat currency as a live obligation:

• Where a specialist is on the DBS Update Service, we run a status check at least annually and before any return after a long break
• Where they are not, we ask for a fresh Enhanced check every three years
• Insurance is re-evidenced at every renewal, and we prompt before the expiry date we hold
• Right to work is re-checked before any time-limited permission expires
• Qualifications and registrations are re-verified where a register shows a change or a specialist adds a new claim to their profile
• Every specialist has a contractual duty to tell us immediately if a certificate, insurance policy or registration lapses, if a caution or conviction arises, or if a regulator takes action

A specialist whose vetting has lapsed is suspended from taking new bookings until it is back in place. Suspension for a lapse is an administrative step, not a finding against anyone.

If you are a specialist or applicant, you have the right to be told what we hold about you, to have a copy of it, to have inaccurate details corrected, to object to processing based on legitimate interests, and to ask for erasure where we no longer need something. Some of those rights are limited where we must keep a record to evidence a safeguarding decision, and we will always explain which limit applies and why.

You also have the right not to be subject to a decision based solely on automated processing. Vetting decisions at Remarkable Minds are always made by a person.

Data-protection questions and requests go to hello@remarkableminds.app, and we respond within one month. Complaints about how we have handled a vetting decision go to complaints@remarkableminds.app and are handled under our complaints policy. Safeguarding matters go to the Designated Safeguarding Lead, Jake Owen, at jake@remarkableminds.app.

You do not have to come to us first. You can complain to the Information Commissioner's Office at any time about how we handle personal data, at www.ico.org.uk or on 0303 123 1113.

This policy, including the Appropriate Policy Document at section 6, is owned by the Designated Safeguarding Lead and approved by the directors of Remarkable Minds Ltd. It is reviewed at least annually while criminal-offence data is being processed, and sooner if legislation, DBS guidance or our own practice changes. We keep the superseded versions so that we can show what was in force at any date.