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 Commitment to fairness and equality
3.2.2 What information Tinies may legally consider
3.2.3 Use of Disclosure Scotland and PVG Scheme information
3.2.4 Open and honest discussions with Candidates
3.2.5 Supporting rehabilitation and safeguarding
3.2.6 Referral duties
3.2.7 Confidentiality and data handling
3.3 Disclosure Scotland, PVG Scheme
3.3.1 Legal Position, since 1 April 2025
3.3.2 Our process
3.3.3 Re-checks
3.3.4 Retaining checks
3.3.5 Exceptional circumstances
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 Child Protection
3.7.2 Paediatric First Aid
3.8 Disclosure Scotland 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
6.1 Borderline or Complex Cases, Escalation Route
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 standards of child protection at each stage of the recruitment process.
Our processes are compliant with relevant legislation, including the Conduct Regulations 2003. Tinies’ Scottish childcare agency operations are regulated and inspected by the Care Inspectorate. We must evidence compliance with the SSSC Codes of Practice 2024, the Health and Social Care Standards, and the National Guidance for Child Protection in Scotland 2021, updated 2023, throughout recruitment and ongoing deployment.
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.
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.
Tinies recognises its responsibilities under the Children and Young People (Scotland) Act 2014, including its contribution to the GIRFEC, Getting It Right For Every Child, approach. Our safer recruitment processes support these duties by ensuring that only individuals who can promote children’s wellbeing, safe, healthy, achieving, nurtured, active, respected, responsible and included, are selected for work in childcare and education settings.
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
This approach supports fairness, aligns with GIRFEC principles, and upholds SSSC expectations around dignity and respect.
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.
In line with the Care Inspectorate’s Stage 4 essential background checks, we verify identity rigorously and retain only the minimum necessary data in accordance with UK GDPR and Disclosure Scotland’s Code of Practice expectations.
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.
Our referencing approach aligns with Care Inspectorate Stage 4, References, and the SSSC Code for Employers, Standard 1: make sure people you recruit are suitable. Where we supply workers into regulated ELC services, we expect references to address suitability to work with children and any known child protection concerns.
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.
If there are concerns about the Caregiver’s ongoing suitability, the Caregiver must undergo ID and PVG checks before being redeployed.
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
Tinies is committed to ensuring fair, safe and lawful recruitment practices in Scotland. When assessing a Candidate’s suitability for roles involving work with children or protected adults, Tinies complies with the Disclosure (Scotland) Act 2020, the Management of Offenders (Scotland) Act 2019, the PVG Scheme, the SSSC Codes of Practice, and the expectations set out in the Care Inspectorate’s Safer Recruitment Through Better Recruitment 2023 guidance.
3.2.1 Commitment to fairness and equality
Tinies undertakes not to unfairly discriminate against any Candidate on the basis of a conviction or other information disclosed through a Disclosure Scotland check or the PVG Scheme. We recognise that many people with previous convictions can make a valuable contribution to the early learning and childcare sector and should not be excluded unfairly.
Our approach reflects the SSSC Codes of Practice, which require employers to ensure recruitment processes are fair, transparent and values-based, and that decisions are proportionate to the level of risk associated with the role.
3.2.2 What information Tinies may legally consider
Tinies will only ask Candidates to disclose information that we are legally entitled to know, and only when it is relevant to the role and permitted under Scottish law.
This includes:
unspent convictions under the Management of Offenders (Scotland) Act 2019
any relevant information returned by Disclosure Scotland as part of a Level 1 or Level 2 check
information disclosed through the PVG Scheme, including consideration of whether an individual is under consideration for listing
Tinies will not ask Candidates to disclose convictions that are protected, the Scottish equivalent of filtered in England and Wales, meaning convictions that are no longer legally disclosable. We rely on Disclosure Scotland’s determination of what information is disclosable.
3.2.3 Use of Disclosure Scotland and PVG Scheme information
Candidates applying for regulated roles with children must be members of the PVG Scheme, and Tinies will review the PVG disclosure to determine suitability.
Any disclosed information will be considered in relation to:
the nature and seriousness of the offence
how long ago it occurred
its relevance to the duties of the role
the circumstances of the offence and any changes since
whether there is a pattern of concerning behaviour
any professional or safeguarding risks arising
Where appropriate, Tinies will consult the Care Inspectorate safer recruitment guidance and National Child Protection Guidance when weighing safeguarding concerns.
3.2.4 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.
3.2.5 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.
3.2.6 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 Scotland and, where required, fulfil the organisational duty to refer concerns to Disclosure Scotland and the SSSC, in line with statutory obligations.
3.2.7 Confidentiality and data handling
All disclosure information is handled in line with the Disclosure Scotland Code of Practice and 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 Scotland, PVG Scheme
3.3.1 Legal Position, since 1 April 2025
The PVG Scheme is a legal requirement in Scotland for people working in regulated roles with children or protected adults. Tinies will only deploy workers into regulated roles when we have obtained the appropriate PVG Scheme disclosure and confirmed Scheme membership.
3.3.2 Our process
During registration, we obtain the Candidate’s consent to undertake a PVG check.
We confirm whether the role is a regulated role using current PVG regulated roles guidance.
For regulated roles with children, we obtain the appropriate PVG Scheme disclosure before deployment, except where the Care Inspectorate has explicitly agreed an exceptional contingency. This is rare.
We record the applicant’s legal name, PVG reference, date of issue, workforce, decision and reviewer initials. We also record the date on which the PVG was checked and the initials of the Consultant who confirmed the check. This information is recorded on the secure platform. No physical copies are held at any Tinies branch.
3.3.3 Re-checks
Tinies conducts PVG status checks in the following circumstances:
every three years for all Caregivers deployed in regulated roles, in line with sector best practice
immediately where any safeguarding, conduct or fitness concern is raised
following a break in assignments of twelve months or more, before redeployment
when requested by a Client service contract that requires more frequent checks
These checks ensure Tinies has up-to-date information from Disclosure Scotland and can evidence ongoing suitability.
3.3.4 Retaining 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 PVG check 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.
3.3.5 Exceptional circumstances
Providers are expected to receive satisfactory background checks before deployment. Any deviation requires Care Inspectorate advice or approval and documented risk controls.
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
Tinies may undertake proportionate online due diligence as part of safer recruitment, in line with Care Inspectorate guidance on digitally assisted recruitment and the SSSC Codes of Practice, including professional conduct, values and rights. Any findings are risk-assessed, discussed with the Candidate, and documented.
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
For roles in early learning and childcare in Scotland, Tinies verifies that workers hold, or are working towards, SSSC-recognised qualifications for the relevant SSSC Register part, and that they are registered with the SSSC within the required timescales.
3.7.1 Child Protection
All Caregivers must have child protection 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 Scotland Duty to Refer
Where Tinies removes, or would have removed had they not left, an individual from a regulated role due to harmful behaviour or risk of harm to a child or protected adult, we have a legal duty to make a referral to Disclosure Scotland within three months. This duty applies to personnel suppliers and employment agencies, as well as direct employers.
Harmful behaviour includes, but is not limited to:
harming or placing at risk of harm
inappropriate sexual conduct
inappropriate conduct involving pornography
giving inappropriate medical treatment
We will also notify relevant regulators, such as SSSC or GTCS where applicable, and follow local child protection procedures under the National Guidance for Child Protection in Scotland.
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 PVG Scheme membership, with re-checks completed where required by service contracts or where information indicates a need.
Tinies confirms that SSSC registration remains current and supports workers to meet the SSSC Codes, including learning and development and conduct.
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.
The Unsuitable Candidate Form must be completed and shared with the Operational Lead.
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 Disclosure Scotland. If so, this must be made within three months, in addition to any SSSC or GTCS 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.
6.1 Borderline or Complex Cases, Escalation Route
Where a Consultant or Franchise Owner identifies information that does not clearly indicate suitability or unsuitability, a structured escalation process must be followed:
- Consult the Operational Lead for a documented risk assessment.
- If uncertainty remains, seek advice from the Care Inspectorate’s safer recruitment guidance support line, where appropriate.
- For matters relating to conduct, professional fitness or registration, consult the SSSC Employer Advice Line for guidance.
- All decisions and advice taken must be recorded under the Caregiver’s file notes.
No placement will proceed until the escalation process is completed and a decision is agreed by the Franchise Owner.
