Safer Recruitment Policy

Safer Recruitment Policy

Introduction

Swift recognises that all forms of abuse are relevant and important to keep in mind when recruiting. We are also aware that people who are sexually interested in children are motivated to apply for roles working with children because of the access these roles provide and the opportunity to offend. As such, we have a duty to explore the risk we are trying to mitigate by implementing safer recruitment practice and having an open safeguarding culture.

Swift is committed to ensuring all Learners, Employees and Employers are safeguarded during their working or learning relationship with our organisation.

It is essential that everyone at Swift is recruited with safeguarding in mind, so that they share Swift’s safeguarding values and receive the right messages about our safeguarding approach and culture.

Swift understands the importance of operating a robust safer recruitment and selection process to deter and prevent people who might be unsuitable to work with children or vulnerable adults or are otherwise unsuited to work with them in line with the Disclosure and Barring Service requirements.

Swift is a responsible employer and ensures that it engages staff and associates in a way that is compliant with the Keeping Children Safe in Education legislation, and in particular that which exempts people with specific convictions from applying for or holding a particular job role where there is an acknowledged risk associated with access to young people or vulnerable adults.

All applicants and potential Swift employees go through the same recruitment process, which includes the completion of our robust application pack along with submitting their CV. Employees go through right to work eligibility and identity checks, along with enhanced DBS checks prior to joining the company, with any identified risks assessed and managed swiftly.

Should a prospective employee or candidate give false or untrue information, this would result in an immediate withdrawal of the offer of employment. Failure to disclose or the provision of a false statement of disclosure by a potential employee or an employee in post may result in disciplinary action, and possible dismissal of the employee, or termination of the associate’s agreement.

Swift has a robust recruitment process in place which maintains and protects our safeguarding duty, culture and beliefs, along with the reputation of the organisation.

The emphasis on safeguarding throughout the process is designed to deter any individual from applying who may have ulterior reasons for working within the education sector. To be confident in our selection of appropriate employees, we adhere to the 5 stages of safer recruitment, to ensure that all recruitment is consistent, fair and transparent.

The five stages are:

1. Preparing to recruit	Advertising Job Description and Person Specification Application form Application pack Self-disclosure Safeguarding statements
2. Selecting the right people	Checking applications Shortlisting process Clear Defined criteria
3. Choosing wisely	Selection tools Interview process Interview skills and training Assessment process
4. Checking thoroughly	Reference process Checking identity Right to work Criminal record checks Overseas checks Online search Health checks
5. Remaining vigilant	Induction Training Probation period Supervision Appraisal Safer culture

1. Preparing to recruit:

Once a need for recruitment has been identified, the recruiting manager must firstly define the role, and consider whether the role could be performed within existing resources in the Company.

Once approval has been gained from the Managing Director to begin recruitment the process can continue.

Dedicated time is set aside to plan and prepare each stage of the process.

To assess the most effective means of obtaining suitable candidates, the following options should be considered:

Internal advert within the Company
Examination of previous applications, or those held on file with the relevant Line Manager
External advert on job sites/social media (where appropriate)
External advert in the appropriate technical / professional Journal
For some posts, the use of a recruitment agency (with SLT approval)

The Advert

All roles should be advertised both internally and externally, to attract the most diverse group of applicants and ensure a fair, transparent and structured process.

Swift will word advertisements to emphasise our strong and positive safeguarding culture, demonstrating our commitment to protecting children and young people, with clear lines of accountability and supervisory arrangements, and our mandatory safeguarding training framework.

For an advertisement to be appropriate it must contain as much information as possible to ensure the correct audience is targeted and reduce unsuitable applications, while remaining as cost-effective as possible.

This includes the required:

Skills
Abilities
Experience
Attitude and behaviours

Alongside these requirements, all adverts will contain to what extent the role will involve contact with children and young people and any regulated activity relevant to children.

All Swift adverts will contain:

Our commitment statement to safeguarding and promoting the welfare of children and young people:

Our safeguarding system is underpinned by a range of policies and procedures which encourage and promote safe working practice across the organisation. Our recruitment checks are robust and thorough in order to employ the most suitable people for the roles available. We make sure that all our staff are trained and supervised to a high standard so they can provide safe, effective practice.

Please note: It is an offence to apply for a role if you are barred from engaging in regulated activity.

A clear message that safeguarding checks will be undertaken,
The safeguarding responsibilities of the post as per the job description and person specification,
Whether the post is exempt from the Rehabilitation of Offenders Act (ROA) 1974.

External adverts to be submitted to a senior Director for approval before being placed. Use of external recruitment agencies is only permitted with Senior Director approval and authorisation of costings.

Applications received are subject to GDPR regulations and should be treated in strict confidence, e.g., secure filing and limited sharing with appropriate colleagues involved in the recruitment process. For this purpose, a GDPR consent and information form is part of the application pack sent out to all candidates.

To define the role, the job description and person specification will be reviewed and updated as required.

The job description should document:

Reporting lines and/or management duties,
Any risks for info ration sharing within the role,
The boundaries of the role,
A full range of the expected duties,
Responsibility to safeguarding,
Safeguarding training required (if applicable)
Any mandatory safeguarding training

The person specification should document:

Safeguarding skills, experience, knowledge required
Safeguarding values, behaviours, attitudes
Motivation for working with vulnerable groups,
Required qualifications and/or professional status,

Swift will always provide details of essential and desirable attributes/qualifications/experience in the person specification, such as safeguarding understanding, demonstrating the ability to raise concerns, evidence that the applicant will uphold Swift’s whole organisational approach to safeguarding, our culture and the Swift Way, and a knowledge and understanding of legislation, policy and guidance.

The Application Pack:

The Swift Application pack advises applicants that that it is an offence to apply for a role if the applicant is barred from engaging in regulated activity relevant to children.

The pack also contains links to our child protection policy and practices, along with our policy covering the employment of ex-offenders which are held on our website.

Within the application pack, applicants can find:

A clear advert, highlighting our organisational commitment to safeguarding,
A detailed job description and person specification to assess candidates against
Our safeguarding statement
An application form which requests relevant information and doesn’t allow for gaps/ambiguity
A reference proforma outlining key safeguarding questions that will be asked of all referees,
A self-disclosure form that highlights the depth of checking undertaken,
A definitive overview of the recruitment process to outline each stage and what will be required of candidates, which also supports the consent process for GDPR.
personal details: current and former names,
current address,
national insurance number,
details of their present (or last) employment and reason for leaving,
full employment history, (since leaving school, including education, employment and voluntary work) including reasons for any gaps in employment,
qualifications, the awarding body and date of award,
details of referees/references and
a statement of the personal qualities and experience they believe are relevant to their suitability for the post advertised and how they meet the person specification,

Alongside the application pack, an anonymous Equality and Diversity questionnaire is requested.

Self-disclosure:

Swift requests the completion of a self-disclosure form as an additional means of obtaining relevant information to determine a person’s suitability for the role.

Swift will make the requirement clear at the beginning of the recruitment process and share the form with applicants during the initial application stage, however, the form will not be reviewed until an offer has been decided upon. Applicants will be advised to provide the form, in a sealed envelope marked confidential.

This form will be:

Seen by only those who need to see it as part of the recruitment process,
Considered carefully and explored further before making a final decision,
Treated in strict confidence, securely stored and kept only for as long as necessary.

Under the Rehabilitation Offenders Act (ROA) 1974 (Exceptions) Order 1975 (as amended in 2013 and 2020) (ROA), applicants will be requested to disclose details relating to their criminal history, the questions will be relevant to the role being advertised.

Referencing

Swift understands that best practice is to request references prior to interview. Two references will be obtained, ensuring they cover an appropriate time period. If the applicant is not currently working or volunteering with children, but has done so in the past, Swift will also obtain an additional reference from the organisation the person was most recently engaged with in a role that had contact with children or young people.

Swift will:

Approach referees for all shortlisted applicants,
Seek references for internal applicants,
Use a reference pro-forma, which includes the job description and person specification,
Obtain references ourselves,
Call the referee for further discussion,
Use a verbal reference pro-form
Ask for further information if required

Swift will not:

Accept open/photocopied references (‘To whom it may concern’ or testimonials),
Be misled by glowing references,
Be complacent or make assumptions because of the status of the referee,
Accept basic references with no useful character information,

When scrutinising references Swift will consider:

How the referee knows the applicant and for how long,
Whether the applicant is suitable for the role,
Whether we are satisfied the applicant is suitable to work with children,
Any sanctions relating to the welfare/safety of children,
Any substantiated allegations which have bearing on children’s safety and wellbeing,
Any ongoing investigations at the time of leaving.

When following up with Referees Swift will:

follow-up with a telephone call to referees to discuss some of the information they have provided in more detail if required,
verify the references on receipt by asking additional questions to capture all detail in one discussion.
Prepare a verbal reference pro-forma before calling referees for a discussion.
Make a note of any vague or ambiguous statements, unanswered questions, discrepancies in information from applicant vs. referee or any concerns about safeguarding attitudes, values, behaviours in preparation for verbal reference calls.

If a referee refuses to provide a reference Swift will explore the reasons for this. Swift also understands that sometimes it is not easy to obtain references, when this happens, we will keep evidence of all attempts made and alternative referees or a risk assessment will be carried out to explore any outstanding risk and possible mitigations.

Swift understands that there is no legal requirement for previous employers to provide a reference unless expressly stated in the contract of employment, however, within the children’s workforce there is a shared understanding of the need for detailed references to determine suitability and keep children safe, Swift will do everything possible to encourage referees to support the recruitment process and co-operate.

Self-Disclosure

Swift will follow the self-disclosure process to ensure there is an additional means of obtaining relevant information to determine a person’s suitability for the role.

The form should be shared with applicants during the initial application stage, however, you are not entitled to review the information provided by the applicant in the self-disclosure form until the decision has been made to offer them the role.

As an employer, you are entitled to ask applicants to disclose details relating to their criminal history but the question you ask will depend on the role you are recruiting for.

The legislation that entitles you to ask for this information is under the terms set out in the Rehabilitation Offenders Act (ROA) 1974 (Exceptions) Order 1975 (as amended in 2013 and 2020) (ROA).

The new rules mean more details will have to be filtered from DBS checks and individuals do not have to disclose all criminal history. It is very important that employers are clear from the outset of recruitment that self-disclosure will be used and why it is being used.

Make it clear in your supporting guidance from the outset:

What information is being requested and why
What stage of the application this information will be reviewed (once the suitable candidate has been selected)
It will be used to inform the overall assessment on their suitability of the role
That the form must be returned in a sealed envelope marked confidential/password protected and will not be opened and viewed unless they are successful .

In the handling of such information make clear that it will be:

Seen by only those who need to see it as part of the recruitment process
Considered carefully and explored further before making a final decision
Treated in strict confidence, securely stored and kept only for as long as necessary

Including this form at the application stage gives the candidate an opportunity to see what information you will be requesting further along in the recruitment process.

As part of Swift’s safer recruitment process, an online search will be also carried out for all candidates by our DDSL (unless it is the DDSL who is recruiting, then the task will move to the DSL), on social media sites, YouTube, Google. All shortlisted candidates will be informed of this search.

The search will go back 3 years from the date of application.

There are 2 main reasons for these online checks:

To safeguard our Learners, Employers and Employees.
To maintain a positive reputation for the organisation and all who are involved with Swift.

We will use the following criteria when carrying out searches for ALL candidates:

Evidence of offensive or inappropriate behaviour, jokes, or language
Discriminatory comments
Inappropriate photos
Drug or alcohol misuse
Any content that would suggest the candidate may not be suitable to work with children

All findings are recorded and discussed with the individual.

2. Selecting the right person:

The recruitment and selection decision is of prime importance as the vehicle for obtaining the best possible person-to-job fit that will, when aggregated, contribute significantly towards the Company's effectiveness.

The Recruitment & Selection procedure will:

be fair and consistent.
be non-discriminatory on the grounds of sex, sexual orientation, pregnancy and maternity, marriage and civil partnership, gender reassignment, race, age, religion or belief, or disability.
conform to Keeping Children Safe in Education 2023 legislation, along with all other statutory regulations and agreed best practice.

When reviewing applications, at least 2 people will be involved in the decision making, but in particular, both the safer recruitment trained member of staff, and the recruiting manager.

It is important to be objective in recording evidence regarding how each candidate meets the criteria of the person specification.

Those involved in shortlisting will check that:

All sections are fully completed,
Sufficient evidence has been provided,
All gaps in work history have been explained,
Appropriate referee details are included,
The most recent employer referee has been provided,
References cover a suitable timescale.

The shortlisting staff will look for inconsistencies and gaps in employment, and the reasons for these, along with any significant changes or risks, making sure further questioning is carried out, and explanations are satisfactory, for example:

Significant salary drops,
Change of career path,
Overlaps,
Inconsistencies,
Discrepancies between work history and reference information or online searches,

The shortlisting panel will record all shortlisted candidates, scoring individually and record decisions on a scoring sheet.

Swift will not be discriminatory or prejudice in its recruitment of new employees. All decisions will be based on evidence and constructive discussion to ensure our process is inclusive and unbiased at all times.

Swift will ensure it provides equal opportunities and will always consider relevant legislation (Equality Act 2010) when carrying out recruitment. All interviewers will ensure the focus remains on the criteria and the candidate’s behaviour in the situation being explored, rather than exploring any personal information that they may have revealed that has no bearing on the role or questioning.

3. Chosing wisely

Equality of Opportunity: Swift understand the importance to apply equal opportunities to protect applicants from discrimination throughout our recruitment drives.

To maintain equality in Interviews Swift will ensure that:

Topics covered with each applicant are consistent, relevant to the role and selection criteria, and justifiable
Questioning relates to the criteria and is conducted in a non-discriminatory way
Prejudice is avoided
Assumption is never used
Key comments or reactions are explored, and evidence obtained
Marking criteria is in place and use consistently for decisions

Swift is aware that all applicants have the right to equal access to employment, equal pay and access to training and development.

Swift agrees with the below definition of equality and diversity in the recruitment context:

‘Equality ensures that every single individual has equal opportunities, regardless of their background, identity or experience. Diversity recognises that, though people have things in common with each other, they are also different in many ways. Inclusion is where those differences are seen as a benefit and where perspectives and differences are shared, leading to better decisions. Everyone should have equal access to employment.’
(Chartered Institute of Personnel Development 2023)

Swift will use a range of selection methods, to represent the role being recruited, to provide a consistent approach to recruitment, and to ensure the most suitable applicant is employed.

Depending on the role, Swift will use the below selection methods:

Technical/competency-based interview
Safeguarding/values-based interview
Learner involvement, as recommended in KCSiE23 (‘Pupils and students should be involved in the recruitment process in a meaningful way. Observing short listed candidates and appropriately supervised interaction with pupils/students is common and recognised as good practice’ KCSIE, paragraph 228)
Practical/technical tests
Presentations
Scenarios

Preparing to interview: Interviews will always be face-to-face, however, due to our national geographical coverage, we may sometimes carry out remote discussions first in order to shortlist for face-to-face interviews.

All candidates will have their identity checked during their interview, by being asked to bring documentary proof of their identity to the interview. They will also have their right to work in the UK checked at this point. This process applies to ALL candidates, whether external and internal applicants.

Safeguarding:

Swift will ensure that all candidates are aware of our commitment to safeguarding, through our safeguarding culture. with the invite for interview, the safeguarding culture will be shared, along with our safeguarding policy. Following the Warner Report, it is vital that we explore a candidates attitude towards safeguarding children and young people, and their motivation for working with children and young people.

As part of this area of the recruitment process, Swift will be vigilant in monitoring cause for concern, and will be exploring a candidates:

High level of resilience
Passion to help children rather than help themselves through children,
Level of self-awareness and how their behaviour impacts on children,
Openness to sharing information and not work in isolation,
Proactiveness and courage to take action to protect children from harm.

Recording Evidence and Storing Information

Swift will ensure that any decisions made are justifiable and defensible, and will record all information to support this. Swift is confident in its approach and open to challenge should this arise.

Interview notes will made by all interviewers, using pen to ensure notes cannot be changed at a later date.

Interviewers will:

Record only quotes - not interpretations, own perception or assumptions,
Use their own notes to make assessment of suitability,
Respect data protection,
Only note down information to be used as evidence for assessment,
Pass completed notes to the HR managed to store securely,
Share only with those authorised to review,
Keep copies of notes for unsuccessful applicants for six months then securely destroy

Making a Decision

Once all interviews have been completed, each panel member will review their own notes and cross reference with the set indicators to ensure clarity, consistency and fairness.

Once individual assessment is complete, the full panel will meet to compare outcomes and discuss findings and scores. This is the opportunity for further discussion, constructive challenge and debate.

The top candidates will be identified, and a decision agreed upon.

4. Checking thoroughly

Any offer of appointment made to a successful candidate must be conditional on satisfactory completion of vetting checks. This is the process of obtaining personal details of successful applicants to help assess their suitability for the role.

It is the minimum safeguard that must be used to prevent unsuitable people from obtaining a role that provides them with access to vulnerable groups.

Swift complete the following checks:

Identity Checks:
- Requesting original identity documents
- Checking the authenticity of the original identity documents
- Conducting a face-to-face meeting
- Validating personal details against external reliable sources
- Digital ID checks
Right to Work Checks:
- To ensure the candidate has the right to work in the UK
References
- X2, one of which must be their current/last employer
Online Search
- Searching social media sites, Google etc
Self-disclosure
Qualifications and Professional Membership/Registration
Criminal Record Checks
- Enhanced DBS check
Overseas Criminal Record Checks:
- If the candidate has been resident overseas for three months or more in the past five years
- has ever worked with children overseas
- was born overseas
Health Checks:
- An initial assessment to gather information determine that a person is fit to carry out the role offered
- To identify any reasonable adjustments needed to support employees with a disability
Childcare Disqualification
Prohibition from Teaching
- To identify any unacceptable professional conduct, conviction or behaviour that could bring the profession into disrepute
Prohibition from Management/Section 128

Any gaps in information, or information found to pose a risk to the organisation will be subjected to a risk assessment.

5. Remaining vigilant

Swift has robust policies and procedures in place to support our commitment to safer recruitment. All staff are aware of, and have had CPD, and all those involved in recruiting receive regular updates, CPD sessions and information.

The HR Manager is safer recruitment trained and is present at all interviews.

The following documents support our safeguarding culture and ensure our Learners are protected from risk as far as possible.

Safeguarding Policies and Procedures
Safeguarding Snippets CPD series
Staff Code of Conduct
Managing Allegations and Low-Level Concerns
Whistleblowing Policy
Robust induction process for new employees
Supervision of Newly Appointed Staff
Equality, Diversity and Inclusion Policy
Disciplinary and Capability Policies
Acceptable use of Technology/e-Safety Policy

Induction

Swift has a clear induction policy in which safeguarding features prominently.

The Induction programme will:

Provide information about safeguarding policies, procedures and code of conduct,
Set up CPD sessions relating to all aspects of the business, and role,
Allocate a buddy to the new employee,
Monitor performance in order to be able to recognise concerns immediately,
Deliver safeguarding training for all new starters,
Explain and ensure clear lines of communication to DSL and Safeguarding team.

Probation Period

To ensure Swift has recruited the right person for the right role, all new employees have a 6-month probationary period. This helps us to assess their ability and suitability for the role. Throughout the probationary period, there are monthly reviews, KPIs set, and ongoing perform discussion.

Dealing with low level concerns:

Swift has a robust process in place for raising and dealing with concerns and allegations consistent with local safeguarding procedures.

These include:

Disciplinary Procedure
Performance and capability procedures
Whistleblowing Process
Local Safeguarding Partnership Procedures

Managing allegations

Swift adheres to local safeguarding board processes for managing allegations to ensure that:

Children and young people are protected and supported,
A fair, consistent and robust approach is applied,
There is an appropriate level of investigation,
Swift applies their responsibilities towards members of staff or volunteers subject to allegations.

If staff have concerns regarding another staff member who may pose a risk of harm to children, they can speak to the Designated Safeguarding Lead.

In the event of the concerns/allegations being about a senior leader, or where they are also the sole proprietor, allegations will be reported directly to the LADO.

Swift also understands that abuse can be reported no matter how long ago it happened, as documented in KCSIE, paragraph 422.

All non-recent allegations will be dealt with as soon as they are reported, by the DSL, in conjunction with the local safeguarding partnership, following their processes and guidance.

Low Level Concerns:

Concerns that do not meet the thresholds for a safeguarding allegation but still require investigation and action will be recorded as Low level Concerns.

Swift promotes a culture of vigilance and openness, encouraging people to share any concerns, no matter how big or small they may seem.

Low level concerns include instances where an adult may have acted in a way that is inconsistent with the Swift Way, ethos or code of conduct, including appropriate conduct outside of work, and does not meet the allegations threshold or is otherwise not considered serious enough to consider a referral to the LADO.

These cases are recorded and managed in line with our safeguarding and HR policies and procedures.

If appropriate, performance management and capability, and disciplinary procedures may be instigated.

Swift has an open, reflection-based culture, where we learn from past mistakes, and use them as future learning.

All Swift staff have the same ethos, commitment and understanding of their safeguarding responsibility.

Version: 2

Board Approval:

Managing Director Name: Gregory Morrall

Date: 16/02/2022

Reviewed on: 05/12/2023

Review Due: 04/12/2024

Reviewed by: Jayne Hipkiss