Most DBS checks follow a straightforward process, but some applications require additional attention. Unusual address histories, discrepancies in personal information, overseas residence or questions about identity can make a screening case more complex. Having a clear DBS escalation process helps employers deal with these situations consistently while reducing avoidable delays.
What Counts as an Unusual DBS Case?
An unusual case does not necessarily mean there is a safeguarding concern. It may simply mean that an applicant’s circumstances do not fit neatly into the standard application process.
Examples include applicants who have lived overseas, stayed in student accommodation, worked away from home, had no fixed address or lived in temporary accommodation. The DBS has specific guidance for unusual address histories and still requires a complete five-year address history.
Other situations may include differences between an applicant’s identity documents and application form, previous names, unexplained gaps in address history or information that does not appear consistent with employment records.
Create Clear Escalation Levels
A good escalation process should define what happens at each stage. For example, straightforward applications can be handled by the normal screening team. Minor discrepancies should be returned to the applicant for clarification, while more complicated cases can be referred to a senior member of the recruitment or compliance team.
The DBS states that discrepancies should be discussed with the applicant when fraud is not suspected, and legitimate explanations should be established. Relevant name and address information should then be properly captured on the application.
Document Every Decision
Documentation is an important part of managing unusual screening cases. Record what was identified, what information was requested, who reviewed it and what decision was made.
For identity checks, DBS guidance requires organisations to keep records of documents used to validate identity for a minimum of two years. Where discrepancies are discussed, relevant notes should also be retained.
A consistent record-keeping process makes it easier to demonstrate that applicants have been treated fairly and that checks have been completed properly.
Know When to Seek Further Guidance
Some cases cannot be resolved internally. If an organisation is uncertain about how an unusual address history should be recorded, it should consult the relevant DBS guidance or contact DBS for advice.
Employers should also remember that a DBS check does not provide a complete picture of criminal records held overseas. Where an applicant has previously lived abroad, additional overseas checks may therefore be appropriate.
For general information about DBS checks and screening, visit ClearCheck.
Keep Safeguarding Separate from Administrative Issues
An unusual application should not automatically be treated as suspicious. A student with multiple addresses, an employee who worked remotely or someone who previously lived abroad may simply have a more complicated history.
The escalation process should therefore distinguish between administrative discrepancies, information that needs clarification and genuine safeguarding concerns. This helps organisations avoid unnecessary assumptions while ensuring potentially important issues receive appropriate attention.
Review the Process Regularly
DBS guidance can change, so organisations should periodically review their screening procedures. The DBS regularly updates its guidance covering identity checking, applications, referrals and other aspects of the checking process.
A documented escalation pathway, trained staff and consistent record keeping can make unusual DBS applications much easier to manage. The objective is not simply to complete the check quickly, but to ensure that information is accurate, relevant issues are properly investigated and decisions are appropriately documented.
Frequently Asked Questions
What is a DBS escalation process?
A DBS escalation process is an internal procedure for dealing with applications that cannot be resolved through normal screening. It identifies when a case should be reviewed by a more senior or specialist member of staff.
What can make a DBS application unusual?
Examples include complex address histories, overseas residence, previous names, identity-document discrepancies and differences between address or employment information.
Does an unusual DBS application mean something is wrong?
No. An unusual application may simply reflect an applicant’s circumstances. For example, students, frequent travellers and people who have lived overseas may have more complicated address histories.
Should discrepancies be discussed with the applicant?
Yes. Where fraud is not suspected, DBS guidance says discrepancies should be clarified with the applicant and legitimate explanations established.
Can DBS checks identify overseas criminal records?
No. DBS cannot access criminal records held overseas, so employers may need to obtain additional checks where an applicant has lived outside the UK.
