Safer recruitment in care: the checks CQC expects

Governance · October 2026 · 4 minute read

Before anyone starts work in a regulated care service, Regulation 19 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 requires the provider to hold the information set out in Schedule 3. In short: proof of identity, a DBS check, evidence of conduct in previous care work and why it ended, a full employment history with gaps explained, relevant qualifications, and information about health as it affects the role. Right to work checks sit alongside this under immigration law. Missing any of them is one of the most common findings in staff files.

The Schedule 3 checklist

For each person employed, the provider must have:

1. Proof of identity, including a recent photograph.
2. A DBS certificate at the right level for the role, usually enhanced with the relevant barred list checks for care roles.
3. Satisfactory evidence of conduct in any previous employment involving health or social care, children or vulnerable adults. In practice, references.
4. Verification of why that employment ended, where the person previously worked in health or social care, or with children or vulnerable adults.
5. Evidence of relevant qualifications, as far as reasonably practicable.
6. A full employment history, with a satisfactory written explanation of any gaps.
7. Satisfactory information about any physical or mental health conditions relevant to the person's ability to do the role, after reasonable adjustments.

Where staff files usually fall short

From experience of running services and preparing them for inspection, the same gaps come up again and again:

• Employment history that isn't full. A CV that lists "2019 to 2022, various" isn't enough. Every month should be accounted for, with gaps explained in writing.
• References that don't cover the last care role. The reference must come from previous care work where there was any, and confirm why it ended.
• Character references used instead of employer references without a recorded reason.
• DBS at the wrong level, or the barred list not checked when it should be.
• No record of the decision when a DBS certificate or reference raises a concern. If you appoint, write down why, and what risk assessment you put in place.
• Health information collected before an offer. Ask about health after an offer is made, and only as it relates to the role.

DBS: making it quicker and cheaper

• Use the DBS Update Service. If a new starter is already registered for the right workforce and level, you can do a free online status check with their consent instead of a new check.
• Status checks every year. Ask staff to join the Update Service as a condition of employment, then check their status at least annually.
• Adult First, with care. An Adult First check lets someone start under supervision while the full certificate is pending, but it only covers the adults' barred list. It isn't suitable for anyone who will also work with children.

Keeping files ready for inspection

Inspectors will look at staff files, and they will want to see that you made safe decisions, not just that you collected paperwork. A good file:

• has every Schedule 3 item, dated;
• shows who checked each item and when;
• records any concerns and how you managed them;
• tracks renewals: DBS status checks, professional registration and time-limited right to work.

How Eviqa Assure helps

Eviqa Assure keeps competency, training and supervision records for every member of staff in one place, with reminders before anything lapses, so you can show an inspector the evidence in minutes. If you'd like to see how it works, book a demo.

Sources

• CQC: Regulation 19, fit and proper persons employed (opens in a new tab)
• legislation.gov.uk: Schedule 3, information required in respect of persons employed (opens in a new tab)
• GOV.UK: DBS Update Service employer guide (opens in a new tab)
• uCheck: Adult First checks (opens in a new tab)

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