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Homepage > Corporate Area > Board minutes > Board 27 January 2004 > Board and staff vetting
 

Board and staff vetting policy

Introduction
The objectives of the Internet Watch Foundation (IWF) are to:
The types of content covered by IWF activities are child abuse images hosted anywhere in the world and UK hosted criminally racist and criminally obscene content. The precise terms of the IWF’s remit and objectives are determined by its Board according to the procedures in the constitution and are recorded in a separate document.
 
IWF works in partnership with the police, government and internet and mobile industry and other interested parties. We have close working ties with a number of national police units and with most Constabularies. We have regular meetings with Ministers and officials from the DTI and Home Office with specific responsibility for internet affairs and we are a member of the police led Internet Crime Forum and the Home Secretary’s Internet Task Force for the Protection of Children on the Internet.
 
A Memorandum of Understanding, endorsed by the Director of Public Prosecutions (DPP) and the President of the Association of Chief Police Officers (ACPO) under the auspices of Section 46 Sexual Offences Act 2003 determines that the IWF can assess and judge child abuse content in accordance with the UK law and reports made to the IWF in line with its procedures will be accepted as a report to a relevant authority.
 
Board has a responsibility for monitoring and reviewing IWF’s remit, strategy, policy and budget in order to enable the IWF to achieve its objectives. During the 2002 review of IWF governance, Board expressed their determination to ensure that IWF is a robust and professional organisation aspiring to best practice and at the Board meeting on 11thFebruary 2003:
 
"That the Board endorse a formal approach by the IWF to the Home Office to seek provision for IWF’s inclusion as an organisation for staff and Board members to have Enhanced Disclosures from the Criminal Records Bureau"
 
IWF wrote to the Home Office Minister on 10th June 2003 and met the Home Office CRB review team on 14th October 2003 in order to press its claim for Enhanced Disclosures for all staff and Board appointments.
 
The December 2003 Home Office Consultation Paper on the Criminal Records Bureau (CRB), Annex C paragraph 15 to the Regulations under Part 5 of the Police Act 1997, acknowledged the IWF’s position with regard to Disclosures for Hotline staff:
 
"15. With the advent of different ways of delivering services, and of different technologies, it is proposed that Enhanced Disclosures should be available in respect of people whose duties involve:
Earlier paragraphs in the consultation paper refer to senior managers and directors with responsibilities for managing services and sought views on their eligibility for Enhanced Disclosures. IWF has made representations with regard to the management of our organisation that the CRB carry out Enhanced Disclosures for IWF Hotline staff and their direct line management.
 
The regulations with regard to criteria for those eligible for CRB Disclosures are part of an ongoing review. IWF will continue to lobby for all staff and Board members to be eligible for Enhanced Disclosures.
 
An organisation which makes use of CRB Disclosures as part of its appointments process must adhere to the CRB Code of Practice and have a policy statement on appointing ex-offenders.
 
Under the amended Regulations outlined in the introduction above, Hotline staff and those responsible for its management are eligible for Enhanced Disclosures. All other staff and Board appointments are subject to police checks via an appointee’s local police force.
 
On that basis, IWF policy on the vetting procedures for staff and Board appointments is below at annex A.
 
Annex A
Policy on the use of criminal record checks and the recruitment of staff and Board members with criminal convictions

1 Scope and Purpose

1.1 This document outlines IWF’s policy on the use of criminal record checks, the storage and use of information which has been disclosed by the Criminal Records Bureau (CRB) and police checks and the recruitment of staff and Board members with criminal convictions. It should be read in conjunction with IWF’s policy on staff recruitment and selection in the Employee’s Handbook and the IWF Constitution and Board Members Handbook
 
1.2 This policy applies to all staff and Board members and will be given to applicants at the outset of the recruitment process where a CRB request for disclosure or police check will be required as part of the application process.

2 Introduction

2.1 IWF will not discriminate unfairly against applicants with a criminal record. Having a criminal record will not necessarily bar an applicant from working for IWF or from Board membership; the nature of a disclosed conviction, its relevance to the post in question and the length of time since the offence occurred, will be considered. Any conviction of a sexual offence, however, is likely to be incompatible with working for IWF or for being a Board member. The Rehabilitation of Offenders Act 1974 provides that ex-offenders are not required to disclose to prospective employers, convictions defined as spent under the Act. Given the nature of the work undertaken by the IWF, applicants for employment and Board positions must disclose any conviction, caution or inappropriate behaviour that could bring their personal and professional suitability for the appointment into question.
 
2.2 Where a conviction or caution has been disclosed in an individual’s application for a post at IWF, a discussion will take place at the end of the interview regarding the offence and its relevance to the position. Failure to reveal information relating to any conviction of a sexual offence could lead to withdrawal of an offer of employment or Board appointment.
 
2.3 IWF uses the Criminal Records Bureau (CRB) Disclosure Service and police checks to obtain information to enable it to assess the suitability of applicants for employment or Board membership. IWF complies fully with the CRB code of practice and does not discriminate unfairly against any subject of a CRB disclosure or police check on the basis of conviction or other information revealed.
 
2.4 IWF complies with the CRB code regarding the secure storage, handling, use, retention and disposal of CRB disclosures, disclosure information and police check information and with its obligations under the Data Protection Act.
 
2.5 In addition to the formal vetting procedures, all candidates for appointment to roles within the IWF must provide a minimum of two referees. IWF treats all information gained from referees, both previous employers and personal as private and confidential. All responses from referees are stored in the candidates file for the retention period.

3 Appointments requiring a CRB disclosure

3.1 An appointee will be required to submit to a CRB disclosure request only where they are seeking appointment to the Hotline or its line management. All other staff and Board appointments will be subject to a local police check. The further particulars of a post or Board appointment will contain an indication that a CRB disclosure or police check will be requested in the event of the individual being offered the position.   All subjects of a CRB disclosure request will be made aware of the CRB Code of Practice. Any information revealed in a disclosure or police check that is likely to lead to the withdrawal of a job offer or Board appointment will be discussed with the applicant before the offer is withdrawn.
 
Storage and Access
3.2 CRB disclosure and police check information will not be stored on an employee’s personnel file but will be stored separately in lockable storage with access limited to those who are entitled to see it as part of their duties. A record will be maintained of all those to whom disclosure and police check information has been revealed as it is a criminal offence to pass this information to anyone who is not entitled to receive it.
 
Usage
 3.3 CRB disclosure and police check information will only be used for the specific purpose for which it was requested and for which the applicant’s full consent will have been obtained.
 
Retention
 3.4 Once a recruitment (or other relevant) decision has been made, CRB disclosure and police check information will not be stored for longer than is necessary. This is generally for a period of up to six months to allow for consideration and resolution of any disputes or complaints. If, in exceptional circumstances, it is considered necessary to keep such information for longer than six months, consideration will be given to the Data Protection rights of the individual.
 
Disposal
 3.5 Once the retention period has elapsed, IWF will ensure that any CRB disclosure or police check information is destroyed and while awaiting destruction, the information will be kept securely. A record of the date of issue of a disclosure or police check, the name of the subject, the type of disclosure, the position for which the disclosure or check was requested, the unique reference number of the disclosure and the details of the recruitment decision taken, will however be securely stored for monitoring purposes.
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Page Created: Thu, October 7th, 2004
Page Modified: Wed, October 20th, 2004

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