Employees’ responsibilities can change significantly as a business grows or organisational needs evolve. Someone initially hired for an administrative role may later supervise staff, work with vulnerable people or take on additional safeguarding responsibilities. These changes can affect whether a new Disclosure and Barring Service (DBS) check is appropriate.
Understanding DBS Checks When Job Duties Expand During Employment helps UK employers maintain suitable screening procedures while ensuring that any additional checks are legally justified.
When Do Expanded Job Duties Require a New DBS Check?
A change in job title does not automatically mean an employee needs another DBS check. Employers should assess the employee’s new responsibilities and determine whether the role’s eligibility for criminal record screening has changed.
For example, an office administrator who begins undertaking duties involving children or adults in regulated activity may require a different level of screening, depending on the specific responsibilities. Employers should review the relevant DBS eligibility rules before requesting a new check.
The key consideration is what the employee actually does, rather than their job title or seniority.
Assess the New Responsibilities Carefully
When duties expand, employers should review the updated job description and identify any changes affecting safeguarding, access to sensitive environments or contact with particular groups.
Consider whether the employee will begin providing personal care, supervising children, undertaking eligible teaching activities or performing other duties that may qualify for a higher-level DBS check.
Employers should consult the official DBS eligibility guidance to establish which checks are legally available for the revised role. A Standard or Enhanced DBS check must not be requested unless the position meets the relevant eligibility requirements.
Can an Existing DBS Certificate Still Be Used?
An existing DBS certificate may remain useful when an employee takes on additional responsibilities, but it does not automatically establish eligibility for every new role.
The appropriate approach depends on the certificate’s level, the information it covers and the requirements of the employee’s revised duties. Employers should assess whether a new check is necessary rather than automatically repeating screening whenever responsibilities change.
If the employee uses the DBS Update Service, employers may be able to check whether the certificate remains current, subject to the service’s requirements and the employer’s eligibility to access the relevant information. The Update Service does not replace the need to assess whether the certificate is suitable for the new role.
Communicate Changes to Employees
Employees should understand why additional screening may be required and how the process relates to their revised responsibilities.
Employers should explain the type of check being considered, the information applicants need to provide and how criminal record information will be handled. Clear communication can prevent confusion and help employees complete any required application accurately.
Any decision to request a check should be based on the role’s legitimate requirements, not assumptions about an employee.
Maintain Accurate Records and Review Procedures
Employers should document changes to job duties, the eligibility assessment and the reasons for requesting an additional DBS check. Records should be stored securely and retained in line with applicable data protection requirements.
Reviewing screening procedures during promotions, internal transfers and restructuring can help organisations identify when a role’s requirements have changed. A consistent approach also supports safer recruitment and helps prevent unnecessary checks.
For further information about DBS screening and application support, visit ClearCheck.
Frequently Asked Questions
Do employees need a new DBS check every time their duties change?
No. Employers should assess whether the revised responsibilities create a legitimate need for a new check. A change in job title alone does not require one.
Can an employee move from a Basic to an Enhanced DBS check?
Potentially, if the revised role meets the legal eligibility requirements for an Enhanced check. The new duties must justify that level of screening.
Does promotion automatically require a new DBS check?
No. Promotion alone does not determine eligibility. Employers should assess the actual responsibilities associated with the new position.
Can employers use the DBS Update Service after an employee changes roles?
The service may help employers check whether an existing certificate is up to date, provided the relevant conditions are met. However, employers must still determine whether the certificate is suitable for the new role.
What should employers document when duties expand?
Employers should record the revised responsibilities, their eligibility assessment, the reason for any additional check and how relevant information is handled securely.
