SAFER RECRUITMENT POLICY
Contents
1. Introduction
2. Recruitment and Selection
2.1 Face-to-face interviews and screening
2.1.1 Trauma-Informed Interviewing
2.2 Right to Work checks
2.3 ID checks and proof of address
2.4 References
3. Vetting
3.1 Rehabilitation of Offenders Act Declaration
3.2 Rehabilitation of Offenders Policy
3.2.1 Open and honest discussions with Candidates
3.2.2 Supporting rehabilitation and safeguarding
3.2.3 Referral duties
3.2.4 Confidentiality and data handling
3.3 Disclosure and Barring Service and Update Service checks
3.4 Overseas Police Checks
3.5 Letter of professional standing for Candidates who have lived or worked overseas
3.6 Online and social media checks
3.7 Qualifications and professional registration
3.7.1 Safeguarding Training
3.7.2 Paediatric First Aid
3.8 Disclosure Service Duty to Refer
3.9 Fitness to work in early childhood education and childcare
3.10 Fitness to work as a nanny
3.11 Lone Working
4. Storing of Data
5. Other checks
5.1 Continued suitability in early education and childcare
6.Unsuitable Candidates
1.Introduction
Tinies UK Recruitment Limited (Tinies) is an employment agency and employment business supplying temporary and permanent workers to work in the education and childcare sector. From here on, they are referred to as a ‘Candidate’ prior to their first assignment and a ‘Caregiver’ from their first assignment.
The Candidates we engage must pass thorough and robust vetting procedures before we can consider them for any placement or assignment with our Clients. This policy sets out our commitment to complying with the highest safeguarding standards at each stage of the recruitment process.
Our processes are compliant with relevant legislation, including the Conduct Regulations 2003 and the Department for Education’s statutory guidance, Early Years Foundation Stage (EYFS) and Keeping Children Safe in Education (KCSIE). We ensure our Candidates are compliant and that our Caregivers remain compliant throughout their time with Tinies by undertaking the checks set out in this policy.
We have processes in place to obtain feedback from our Clients once assignments are completed.
Consultants ensure that Candidates are not recorded in our Central Register of Unsuitable Caregivers or Central Register of Unsuitable Candidates prior to starting the onboarding process.
2. Recruitment and Selection
2.1 Face-to-face interviews and screening
A detailed interview is conducted with all Candidates. Interviews are conducted face-to-face or via video call by our Consultants, according to strict standardised guidelines, to ensure equality of opportunity and comparability of information about each Candidate.
A trained Consultant assesses each Candidate’s suitability by reviewing their work history, qualifications, role knowledge, scenario responses and child protection understanding, using questions to ensure fairness. They also consider age and experience requirements, such as emergency nannies needing to be 18 with two years’ sole charge experience, apprentices potentially being accepted from age 16 depending on education and professionalism, unqualified temporary workers requiring six months’ experience and a minimum age of 18, and qualified L2/L3 temporary workers typically having at least one year of experience.
Consultants review each Candidate on a case-by-case basis to determine whether they demonstrate the relevant experience required to work as a Tinies Caregiver.
Provided the outcome of the interview is satisfactory, Tinies starts the pre-assignment checks.
2.1.1 Trauma-Informed Interviewing
Tinies adopts a trauma-informed approach to interviewing, recognising that some Candidates may have experienced adversity that could affect communication style or confidence.
Consultants will:
use respectful, strengths-based questioning
avoid re-traumatising questions and ensure Candidates feel safe and supported
focus on relevance to role requirements rather than past personal circumstances
2.2 Right to Work checks
Tinies conducts Right to Work checks for every Candidate to meet child protection, immigration and recruitment legislation requirements. These may include manual document checks, digital identity verification via approved IDSPs, online Home Office checks using share codes, or the Employer Checking Service where immigration status cannot otherwise be confirmed.
Manual checks require original List A or List B documents, as outlined on the government website. Once Tinies has verified that the documents or checks provided are genuine, consistent and valid, and has confirmed that the Candidate is permitted to undertake the work, Tinies records the result securely on the candidate platform.
Digital and online checks follow the Home Office three-step process, ensuring photographs and biographical details match the individual. Tinies securely stores all Right to Work results for the duration of the Candidate’s employment and for two years thereafter.
Where acceptable documents or online evidence are unavailable, Tinies will carry out an Employer Checking Service check. Only once a positive verification notice has been obtained can the Candidate start work.
2.3 ID checks and proof of address
In addition to the above Right to Work documents, we also require the Candidate to provide two original documents to confirm their identity and address. The types of documents we accept include a valid driving licence, passport, utility bill, bank statement or government document or letter. These documents must be dated within the previous three months.
Some Tinies branches use an IDVS to confirm the Candidate’s identity. We only use the services of IDSPs that can satisfy a minimum of a Medium Level of Confidence check.
Information is recorded on the candidate platform. No physical copies of notices are held at any Tinies branch. All documents are kept for the duration of the Candidate’s engagement and for two years thereafter.
2.4 References
In accordance with Regulation 22 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003, we require at least two references that must cover the previous five years of employment for all Candidates.
One reference must be from the Candidate’s most recent employer. If applicable, we will always obtain the most recent childcare experience reference. Reference forms should be sent to company email addresses where possible to add a layer of referee verification and minimise safeguarding risk.
If there are gaps of more than six months in the Candidate’s five-year employment record, additional references must be requested.
Some branches may use the services of an ID Service Provider to conduct references on behalf of Tinies. IDSPs send reference requests electronically to a Candidate’s referees through a secure link that only the named referee can access.
Verbal references are not accepted. We also seek a referee’s consent to forward their reference to a third party. Where no consent is given, this must be clearly listed on file.
References must, as a minimum, include dates of employment, the Candidate’s suitability to work with children and details of any child protection issues, if known.
We retain clear copies of the documents provided by the referees.
If a Caregiver has not taken any assignments for a period of up to twelve months, additional work references for that period are required. If the Caregiver has not engaged in any other work, the Consultant must have a meeting with the Caregiver, and the Caregiver must complete a self-declaration form. The form must be agreed, signed and dated by the Caregiver.
Consultants may seek a character reference to confirm the Caregiver’s self-declaration and provide context. However, character references must not be relied upon.
References must be obtained from professional domain email addresses. If this is not possible due to a company closing down, a nanny position where parents do not have professional email addresses, or another unavoidable situation, Tinies will accept a non-professional domain on the basis that we can verify the closure, or verify the parent through an online search.
For example, a parent who is a lawyer using a non-professional email domain may be visible via an online search, meaning we are able to verify the referee’s name and profession.
3.Vetting
3.1 Rehabilitation of Offenders Act Declaration
During the registration process, all Candidates are required to complete our Rehabilitation of Offenders Act Declaration and, as required for regulated sectors, disclose all spent and unspent convictions, subject to the filtering rules.
For Candidates seeking work in early years and childcare settings, nanny roles, support roles in schools and wraparound provision, we will not place a Candidate who has unspent convictions.
3.2 Rehabilitation of Offenders Policy
As an organisation assessing Candidates’ suitability for positions that are included in the Rehabilitation of Offenders Act 1974 (Exceptions) Order, and using criminal record checks processed through the Disclosure and Barring Service (DBS), Tinies complies fully with the DBS Code of Practice and undertakes to treat all applicants for positions fairly.
Tinies undertakes not to unfairly discriminate against any subject of a criminal record check based on a conviction or other information revealed.
Tinies can only ask an individual to provide details of convictions and cautions that Tinies is legally entitled to know about. Where a DBS certificate at an enhanced level can legally be requested, where the position is one that is included in the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 as amended, and where appropriate under the Police Act Regulations as amended, Tinies can only ask an individual about convictions and cautions that are not protected.
Protected convictions are certain old or minor offences that are not disclosed on a Standard or Enhanced DBS certificate after a specific period. This process is known as filtering. The aim is to help individuals move on from past mistakes that are considered less serious and no longer relevant to most employment or volunteer roles.
Key points about protected convictions include:
Minor offences: These typically include less serious crimes, such as minor theft or public disorder offences.
Time period: The conviction must be spent, meaning a certain amount of time has passed since the conviction without any further offences.
Exclusions: Serious offences, such as those involving violence or safeguarding concerns, will always be disclosed.
Tinies is committed to the fair treatment of its staff, potential staff and users of its services, regardless of race, gender, religion, sexual orientation, responsibilities for dependants, age, physical or mental disability, or offending background.
Tinies has a written policy on the recruitment of ex-offenders, which is made available to all DBS applicants at the start of the recruitment process.
Tinies actively promotes equality of opportunity for all with the right mix of talent, skills and potential, and welcomes applications from a wide range of Candidates, including those with criminal records.
Tinies selects all Candidates for interview based on their skills, qualifications and experience.
Tinies ensures that all staff involved in the recruitment process have been suitably trained to identify and assess the relevance and circumstances of offences.
Tinies also ensures that all staff have received appropriate guidance and training on the relevant legislation relating to the employment of ex-offenders, such as the Rehabilitation of Offenders Act 1974.
At interview, or in a separate discussion, Tinies ensures that an open and measured discussion takes place about any offences or other matters that may be relevant to the position. Failure to reveal information that is directly relevant to the assignments sought could lead to withdrawal of an offer as a Tinies Caregiver.
Tinies makes every subject of a criminal record check submitted to DBS aware of the existence of the Code of Practice and makes a copy available on request.
Tinies undertakes to discuss any matter revealed on a DBS certificate with the Candidate seeking the position before ceasing the onboarding process.
3.2.1 Open and honest discussions with Candidates
If any conviction or relevant information is disclosed, Tinies will ensure that a fair, open and confidential discussion takes place with the Candidate before any decision is made. Candidates will be given an opportunity to explain the circumstances, provide context and share information about rehabilitation.
Failure to disclose legally required information may affect the progression of an application.
3.2.2 Supporting rehabilitation and safeguarding
Tinies recognises its dual responsibility to:
protect children and vulnerable groups
support people with past convictions who can safely and suitably work in childcare
Where offences do not affect the Candidate’s suitability or pose no safeguarding risk, Tinies will continue the recruitment process in line with our values-based approach.
3.2.3 Referral duties
Where information suggests that a Candidate or staff member may pose a risk of harm, Tinies will follow the National Guidance for Child Protection in England and, where required, fulfil the organisational duty to refer concerns to the Disclosure and Barring Service, in line with statutory obligations.
3.2.4 Confidentiality and data handling
All disclosure information is handled in line with UK GDPR.
Information is:
used only for the purpose for which it was requested
shared strictly on a need-to-know basis
retained only for the minimum period necessary to evidence the recruitment decision
securely deleted in line with Tinies’ data retention schedule and the requirements for handling disclosure information
3.3 Disclosure and Barring Service and Update Service checks
Tinies requires all Candidates to have an enhanced Disclosure and Barring Service (DBS) check, which includes a check on the Children’s Barred List.
We view and take a digital copy of the original paper DBS certificate, which is stored securely. Consultants are then permitted to complete a status check on the DBS Update Service where applicable. During registration, we obtain the Caregiver’s consent to store a copy of the DBS certificate and to undertake additional status checks.
Under Regulation 22 of the Conduct Regulations 2003, where Tinies introduces or supplies a work-seeker for a role that involves working with children, Tinies is required to obtain copies of any relevant qualifications or authorisations of the work-seeker and offer to provide copies of those documents to a Client. As a DBS is an authorisation required by law to work in roles that involve working with children, Tinies is required by law to offer a copy to Clients.
Under Regulation 29 of the Conduct Regulations 2003, Tinies must keep work-seeker records for at least one year from the date of their creation and at least one year after the date on which Tinies last provided work-finding services to the work-seeker. This includes PVG records. Tinies may keep records for a longer period if there is a legitimate business interest reason for doing so, such as safeguarding issues or other similar extenuating circumstances being raised.
If the Update Service check states that there is new information, we require the Candidate to apply for a new DBS certificate before proceeding with their registration.
If a Candidate wishes to register with Tinies and they are not already on the Update Service, Tinies requires them to apply for a new DBS. Tinies strongly encourages the Candidate to subscribe to the Update Service. If the Candidate does not subscribe to the Update Service, Tinies requires a new DBS check to be undertaken annually.
More frequent checks may be required in certain circumstances, such as if required by a Client or if we receive information about a Candidate that requires us to carry out additional checks.
Tinies will undertake repeat status checks on the Update Service at least once every three months, or more often if required by our Clients. We obtain the Caregiver’s consent to undertake additional status checks during registration.
If the DBS check shows details of a conviction or caution, in line with The School Staffing (England) Regulations 2009, we must email a copy of the DBS to the school where this applies.
Following the decision of the Department for Education to remove access to the stand-alone Barred List checking system for employment businesses from 1 April 2021, we cannot conduct this standalone check, and we will not place any Candidates in a role without a full enhanced DBS check being completed. This check includes a Barred List check where required.
When reviewing a Candidate’s DBS certificate, Consultants check that the certificate is for the Child Workforce only and that status checks on the Update Service are only for the Child Workforce. Unless the role being applied for involves regulated activity with both children and adults, in accordance with the definition of regulated activity contained in the Safeguarding Vulnerable Groups Act 2006, we will not accept a previously issued DBS that covers both adult and child workforces.
3.4 Overseas Police Checks
All Candidates who have lived and worked in an overseas country for a period of at least six months at any point within the last five years need an overseas police check. Where possible, Tinies Consultants should apply for the check directly. Any other documentation provided by a Candidate will not be accepted.
Where a Candidate has lived and worked in a number of overseas countries in the last five years, Tinies Consultants discuss the Candidate’s work history with them and then conduct police checks accordingly, based on their professional judgement and in consultation with their Line Manager.
If the Candidate is unable to provide a police check from the relevant country, for example if the relevant country does not provide police checks, Tinies may accept a statement of good conduct from the Candidate’s previous employer within the relevant country. Tinies requires the statement to include confirmation that, to the best of their knowledge, the Candidate has no criminal convictions and that they know of no reason why the Candidate should not work with children.
If Tinies is unable to obtain a police check or a statement of good conduct, the onboarding process must cease.
3.5 Letter of professional standing for Candidates who have lived or worked overseas
For Candidates who have lived or worked overseas in the last five years, Tinies requires a letter of professional standing from the relevant regulatory authority to confirm suitability, using the Regulated Professions Database for EU, EEA and Swiss bodies and independently identifying regulators for everywhere else in the world.
Where a letter cannot be obtained and all reasonably practicable steps have been taken to obtain it, Tinies requests that the Candidate provides an alternative document that confirms their suitability for the role. This may be a letter of good standing from the headteacher in the school they worked in, the manager of a childcare unit, or additional professional references.
Tinies also verifies international qualifications through UK ENIC, with Candidates obtaining an Early Years Statement for early years-focused qualifications at no cost, or a Statement of Comparability where appropriate at a cost to the Caregiver.
Candidates are informed of all steps taken to meet suitability requirements under Regulation 22 of the Conduct Regulations.
Tinies cannot proceed with onboarding if no acceptable documentation is available.
3.6 Online and social media checks
In accordance with the Department for Education’s statutory guidance, KCSIE 2025 paragraph 226, Tinies conducts an online search of Candidates as part of our due diligence checks.
Furthermore, we consider any specific checks that form part of the Client’s own policy or procedures regarding online checks.
We let Candidates know that this check will take place, but we do not ask for consent because consent is not considered lawfully valid in situations such as recruitment, where there is a natural imbalance of power. Instead, we carry out the check because we are legally required to do so as part of safer recruitment and because it is in our legitimate interest to make sure Candidates are suitable for the roles we place them in.
3.7 Qualifications and professional registration
Candidates’ qualifications must be checked on the Early Years Qualification List (EYQL) to ensure they are full and relevant and have been approved by the Department for Education. The EYQL online service can be used to check if an early years qualification achieved in the UK is approved and confirms whether someone who holds this qualification can count in staff-to-child ratios at level 2, 3 or 6 in an early years setting in England.
To confirm if the qualification is full and relevant, the qualifications checker will ask where the qualification was awarded, the date the qualification was started and awarded, the level of the qualification, and the awarding organisation.
Approved qualifications are published on the EYQL, except, as outlined in paragraphs 1.11 and 1.16 of the Early Years Qualification Requirements and Standards document, those that are not individually listed on the EYQL but count as approved qualifications if they meet certain criteria.
3.7.1 Safeguarding Training
All Caregivers must have safeguarding training.
Caregivers are expected to have up-to-date knowledge and engage with refresher training on a regular basis. Certificates must be shared with Consultants.
Franchise Owners and Consultants may consider whether any Caregivers need additional training to help maintain basic skills and keep up to date with any regulatory changes.
3.7.2 Paediatric First Aid
For Candidates who have completed a Paediatric First Aid (PFA) course, Consultants ask for a copy of the certificate and evidence regarding the type of course, either full 12-hour or emergency 6-hour. The PFA certificate must be from an officially recognised provider, as outlined by the government.
Nannies should have completed a 12-hour full PFA course but must complete a 6-hour Emergency PFA course. Where this is not the case, Consultants must inform the Client and take each assignment on a case-by-case basis.
Training must be renewed every three years.
Certificates must be shared with Consultants and saved to the Caregiver’s account.
3.8 Disclosure Service Duty to Refer
Tinies, as an employment business, is a personnel supplier and has a legal requirement under the Safeguarding Vulnerable Groups Act 2006 to refer information to the DBS about individuals who have either harmed, or placed at risk of harm, a child or vulnerable adult.
Where Tinies supplies or introduces a Candidate to a Client, and the Client subsequently removes the Candidate from carrying out regulated activity because the Client believes that the person has engaged in relevant conduct or that the harm test is satisfied, Tinies must provide information to the DBS about this matter.
Additionally, if Tinies decides to withdraw our services from the Candidate because we believe that the Candidate engaged in relevant conduct or that the harm test is satisfied, we must provide information to the DBS about this.
Relevant conduct is defined as:
conduct that endangers a child or vulnerable adult or is likely to endanger a child or vulnerable adult
conduct that, if repeated against a child or vulnerable adult, would endanger or would be likely to endanger them
conduct involving sexual material relating to children, including possession of such material
conduct involving sexually explicit images depicting violence against human beings
conduct of a sexual nature involving a child or vulnerable adult
Tinies has a duty to refer information to the DBS if the harm test is satisfied, meaning if Tinies believes that the person may:
harm a child or vulnerable adult
cause a child or vulnerable adult to be harmed
put a child or vulnerable adult at risk of harm
attempt to harm a child or vulnerable adult
incite another person to harm a child or vulnerable adult
To ensure compliance with the DBS referral rules, we have processes in place to ensure that all staff are aware of the legal duty to make a DBS referral where necessary and know the process for doing so.
3.9 Fitness to work in early childhood education and childcare
Tinies asks all Candidates to tell us about any health conditions or disabilities that may affect their ability to carry out essential parts of the role. When something is declared, a Consultant will discuss it with the Candidate to understand what support or reasonable adjustments may be needed, or whether advice from a medical professional is required.
Any agreed adjustments will be shared with Clients so they can support the Candidate during assignments. If medical confirmation is needed, we will request, with the Candidate’s consent, written assurance from their doctor that they are fit to work. If this cannot be obtained, we cannot complete registration.
Candidates must also let us know if they take any medication or substances that could affect their ability to care for children. Where this applies, they should seek medical advice and may only work if a medical professional confirms that the medication will not impair their ability to look after children safely.
If Tinies cannot review this confirmation, we are unable to proceed with registration.
3.10 Fitness to work as a nanny
To ensure compliance with Regulation 21 of the Conduct Regulations 2003, health and safety places a duty on Tinies to inform Candidates of any known information from the Client regarding health and safety risks.
Therefore, Tinies asks all Candidates to advise us of any health or disability issues that they believe are relevant to the role and that make it difficult for them to carry out functions that are essential to the role. This includes asking Candidates about their driving record and fitness to drive, as driving is an intrinsic function of the role.
When a health condition is declared, a Consultant will discuss it with the Candidate to understand what support or reasonable adjustments may be needed, or whether advice from a medical professional is required.
Any agreed adjustments will be shared with Clients so they can support the Candidate during assignments. If medical confirmation is needed, we will request, with the Candidate’s consent, written assurance from their doctor that they are fit to work. If this cannot be obtained, we cannot complete registration.
Candidates must also let us know if they take any medication or substances that could affect their ability to care for children. Where this applies, they should seek medical advice and may only work if a medical professional confirms that the medication will not impair their ability to look after children safely.
If Tinies cannot review this confirmation, we are unable to proceed with registration.
Furthermore, Tinies owes a duty of care to our Clients for the safety and wellbeing of their children, and Caregivers must not be under the influence of alcohol or any other substance that may affect their ability to care for children.
Tinies asks all Candidates to advise us of any medication or any other substances that may affect their ability to carry out functions that are essential to the role.
3.11 Lone Working
In accordance with the Health and Safety at Work Act 1974, employers are required to ensure the health and safety of all individuals at work, including those working under a contract of service. The Management of Health and Safety at Work Regulations 1999 mandate employers to conduct risk assessments and implement appropriate safety measures for lone workers.
Tinies has produced separate guidance to support any Caregivers with assignments that involve lone working. This is shared with Candidates as part of the onboarding process.
4. Storing of Data
Tinies will retain all copies of Caregivers’ documentation while they are engaged with Tinies and for two years thereafter. Documentation is stored within a secure platform. After two years, all digital copies are deleted.
Data Protection: All digital documents sent directly to any member of staff at Tinies are deleted once they have been uploaded to the secure platform.
5. Other checks
5.1 Continued suitability in early education and childcare
At Tinies, we prioritise safer recruitment practices to ensure the highest standards of safety and quality in childcare and education. Our robust policies are designed to thoroughly vet all Candidates, ensuring they meet stringent criteria and comply with all legislative requirements.
The ongoing suitability of Caregivers is an essential part of our role, and Tinies is committed to ensuring that our workforce is highly skilled, professional and trustworthy. This is why we continue to administer suitability checks, as well as seeking feedback from Clients.
Caregivers read and sign the Suitability Declaration every year.
Caregivers must maintain a valid DBS on the Update Service, with re-checks completed where required by service contracts or where information indicates a need.
Where concerns arise, Tinies will follow local child protection procedures under the National Guidance and consider the duty to refer.
Feedback is obtained from Clients where possible after every assignment. If this is not possible, feedback will be obtained every three months, ensuring there is one example of feedback. This is added to the Caregiver’s file.
6. Unsuitable Candidates
During the onboarding process, if a Consultant is unsure as to the suitability of a Candidate to work with children, they must inform their Line Manager and discuss their concerns.
If the Franchise Owner agrees that the Candidate is unsuitable to work with children, they must be placed on the Central Register of Unsuitable Candidates. This decision must be made by a Franchise Owner and not a Consultant.
This decision must be communicated to the Candidate verbally and in writing, with clear reasons as to why that decision has been taken.
Furthermore, Franchise Owners must consider whether the threshold has been met for a referral to be made to the DBS. If so, this must be made within three months, in addition to any notifications and local child protection processes.
It is recommended that Franchise Owners keep records of Candidates who decide to cease the onboarding process. Reasons should be documented as part of continuous improvement processes.
