Criminal record checks form a vital part of any safer recruitment process, but it can be confusing which types to do when. Here, in partnership with ACRO and The Safeguarding Alliance, COBIS has compiled a useful Q&A on criminal record checks for overseas schools.

1. Who needs a criminal record check?

All staff members in the school.

2. Do we need a criminal record check for a volunteer at the school?

Yes, if you have anyone working voluntarily in the school a criminal record check is a requirement.

3. What criminal record checks are available for all staff members in an overseas school?

The criminal record checks available are:

• The International Child Protection Certificate (ICPC) for all staff that have lived and or worked in the UK.
• Overseas police checks:
  • Local police checks, these are criminal record checks available in the host country.
  • International police checks, these are criminal record checks for those who have been working in overseas schools in other countries prior to moving to the current host country and for those who do not meet the criteria for an ICPC.
• You can get further advice how to obtain overseas criminal background checks from the National Protective Security Authority (NPSA) and the UK Home Office.
  • NPSA (National Protective Security Authority) Overseas criminal record checks
  • UK Home Office guidance for overseas criminal record checks

4. In addition to criminal record checks, what other safer recruitment checks should form part of our safer recruitment process?

Other checks that COBIS recommends and would expect to see evidence of on a school’s Single Central Record (SCR) as part of COBIS Accreditation visit, are:

• ID checks in person or by video call.
• At least 2 references which should be verified by a follow up call. One of which should be the current employer or headteacher if the current employer is a school.
• Prohibition Order check for teachers (for those that have lived and/or worked in the UK) is highly recommended.
• Section 128 check (for those that have lived and/or worked in the UK and are taking up leadership positions in independent schools) is highly recommended.
• It is also highly recommended you conduct qualification checks in other professional areas for those staff joining the school from outside the education sector. You can find a list of helpful resource material in our website in the member’s area.
• Safeguarding Annual Declaration.

5. What is the Single Central Record (SCR)?

The SCR is evidence that the required pre-appointment checks have been conducted on all staff at schools and colleges before the start date. The SCR is a log of all staff and is updated on a regular basis in line with your safer recruitment policy. All aspects of the SCR checks should be dated and initialled by the person who receives them. It is good practice to align staff files with the SCR headings and to record ongoing safeguarding training on the SCR.

6. What is the ICPC (International Child Protection Certificate)?

The International Child Protection Certificate (ICPC) is a criminal record check for anyone who lives, or has lived, in the UK and who is looking to work with children overseas. It confirms whether the applicant has a criminal history and provides details, including relevant conviction and non-conviction data. The ICPC effectively serves the same purpose for international school placements for anyone with a UK background as the Enhanced DBS does for placements in England and Wales. They are not interchangeable though: ICPC for international placements and DBS for ones in England and Wales.

COBIS and ACRO (Criminal Records Office) have partnered to help overseas schools access these checks and make the ICPC a fundamental aspect of the recruitment process for individuals, with a UK background, wanting to work with children overseas. COBIS is the Global Ambassador for the ICPC. 

7. Is a Prohibition Order check the same as an ICPC?

No, they are two different checks. For all teaching staff who are registered and have taught in England, the Prohibition Order check is available through the Teaching Regulation Agency (TRA). There are other search registers you can check for those individuals registered in Scotland, Wales and Northern Ireland. It is highly recommended even where the position applied for is not a teacher, to identify whether the person applying has ever registered as a teacher and has a Teacher Reference Number (TRN). COBIS has access to the TRA database and can administer checks on behalf of overseas schools. Please contact the COBIS Safeguarding Officer for more information.

8. If a staff member is a new starter, should a school ask for a new ICPC or other equivalent criminal record check?

Yes, any new starters should apply for a new ICPC if applicable or equivalent criminal record check in other countries. The HR staff managing the Single Central Register (SCR) should see original certificates and not outsource this role. It is also recommended that all staff submit a Safeguarding Annual Self-declaration form to confirm that their criminal record status remains unchanged. This forms part of a school wider and ongoing safer recruitment commitment.

9. What is a Safeguarding Annual Self-declaration form?

It is a formal document used in schools which typically includes:

• Training and policy awareness: confirmation of receiving safeguarding training and awareness of current policies.
• Commitment to safeguarding: agreement to follow safeguarding procedures and report concerns.
• Disclosure of convictions or cautions: declaration of any new convictions or cautions since the last annual declaration and/or police check. 
• Reporting responsibilities: understanding of reporting procedures for safeguarding concerns.

This declaration ensures accountability and helps maintain a safe environment and on-going vigilance for schools. 

10. How often do you have to renew an ICPC?

There are no rules in renewing an ICPC for existing staff unless concerns are raised. COBIS recommends at least every 3 years, but schools should form their own safer recruitment policy including renewal timelines, in line with new contracts if they stipulate less than every 3 years. Remember, a criminal record check is only valid on the day it is issued. For local police checks they might be renewed annually anyway to meet visa needs.

11. What if a staff member has never lived or worked in the UK?

An overseas school would then need to conduct a local police check (a police check in the host country if relevant) and international police checks (criminal record checks the school can conduct based on that person’s country of prior residence).

COBIS recommends police checks from any countries the person has lived in from at least the last 5 years.

Useful links to international criminal background checks are on our website here.

12. What is the Police Certificate issued by ACRO?

The Police Certificate issued from ACRO is for people who want to emigrate from the UK, need a visa to live and/or work abroad, or are looking to obtain citizenship or residency in another country. To access the Police Certificate for visa purposes please visit the ACRO website.

13.  Is the Police Certificate from ACRO the same as an overseas police check?

No, an overseas police check is a local police check in the host country or an international police check in other countries and they are criminal record checks conducted overseas to cover where the staff member lives or has lived overseas. Useful links to international criminal background checks are on our website here.

14. Do we need an ICPC as well as the Police Certificate?

Yes, the ICPC is for those working in a school as there are extra safeguarding and children services checks that the Police Certificate does not cover.

15. What is the Standard and Enhanced DBS (Disclosure and Barring Service)?

The Enhanced DBS is a criminal record check for schools based in England and Wales and making the recruitment decision in England and Wales. The DBS is for placements in England and Wales. It can include the Barred List for those working with children in regulated activity. Overseas schools cannot access the Enhanced DBS. The Standard or Basic DBS is not suitable for those working in schools and with children in regulated activity and it does not include the Barred List.

16. If a staff member has a DBS from their current school in the UK, can we accept this?

No, an overseas school should ask the staff member to apply for a new ICPC.

17. What is the Barred List (formerly the List 99)?

The Barred List is a list managed by the DBS and lists all those deemed unsuitable to work with children. It forms part of the Enhanced DBS. This is not available to overseas schools. When an individual applies for an ICPC, the National Crime Agency (NCA) will have access to the intel of those individuals included on the Barred List.

18. What is a Section 128 check?

For managers and anyone making management decisions in an independent school, a Section 128 is available from the TRA. The only criteria is that the person has lived and/or worked in the UK. COBIS has access to the TRA database and can administer checks on behalf of overseas schools.

19. Does a staff member need a new criminal record check before starting employment at the school?

Yes. The current turnaround for an ICPC is 20 working days. ACRO offers overseas postal delivery of the certificate, allow for postal timescales. The types of overseas criminal record checks will differ from country to country.

20. Do you have more details on the overseas delivery service that ACRO offers for the ICPC?

Delivery times- Please note that postal days are Monday – Saturday:

• Standard UK (free of charge): Up to 8 postal days.
• Standard Overseas within Europe (free of charge): Up to 10 postal days.
• Standard Overseas Rest of the World (free of charge): Up to 20 postal days.
• Tracked Delivery Overseas within Europe (£9 additional fee): Up to 10 postal days.
• Tracked Delivery Overseas Rest of the World (£9 additional fee): Up to 10 postal days.
• International Courier (£48 additional fee): Delivery times vary depending on geographical location however, usually delivered within 2-7 days.

21. What if a staff member is due to start employment at a school and we have not received the criminal record check yet?

It is not recommended that a staff member starts work at the school until the recommended checks have been completed.

22. What should we do if a person has not lived in the UK recently?

You still need the individual to apply for an ICPC if they have ever lived or worked in the UK.

23.  Do we need a criminal record check for a trustee/governor/ board member?

Yes, they are working for the school therefore a criminal record check is a requirement.

For further information and to apply for an ICPC click here.

We would like to thank the colleagues from The Safeguarding Alliance and ACRO for their contributions. Any questions on this guidance please contact the COBIS Safeguarding team.