THE DIOCESE'S RECOMMENDATION
The Diocese recommends that:
- Where a parish has any worker or volunteer undertaking Regulated Activity with children, that PCC qualifies as a children’s charity, and all PCC members should have an Enhanced DBS check for the child workforce;
- Where a parish has any worker or volunteer undertaking Regulated Activity with adults, the PCC qualifies as an adults charity, and all PCC members should have an Enhanced DBS check for the adult workforce;
- Where both apply, PCC members should have an Enhanced DBS check covering both workforces.
- For most PCC members this will be an Enhanced DBS check without barred-list information, unless the PCC member is undertaking other roles which bring them into the definition of Regulated Activity, in which case they should have a barred-list check.
WHAT IS REGULATED ACTIVITY:
Regulated Activity with Children: Paid or voluntary work involving specified responsibilities or care for children that gives a person a position of trust, such that someone barred from working with children must not carry it out.
A person is generally engaged in Regulated Activity with children if they:
- Teach, train, instruct, care for, supervise, or provide advice/guidance to children (under 18) once a week or more, four or more times a month, or overnight.
- Provide healthcare or personal care to a child, regardless of frequency.
- Work in certain specified establishments (such as schools, children's homes and childcare settings) in roles that give them regular opportunities for contact with children and meet the statutory criteria.
- Are undertaking work that a person barred from working with children is legally prohibited from doing.
Regulated Activity with Adults:Paid or voluntary work involving specified care, support, healthcare, social work, advocacy or related assistance to adults, such that someone barred from working with adults must not carry it out. Unlike children's regulated activity, a single occasion can be sufficient
A person is engaged in Regulated Activity with adults if they carry out any of the following for an adult aged 18 or over:
- Provide healthcare.
- Provide personal care, such as assistance with washing, dressing, eating, drinking or toileting.
- Provide social work.
- Assist with cash, bills or shopping because of the adult's age, illness or disability.
- Assist in the conduct of a person's affairs, for example under a power of attorney or certain advocacy roles.
- Convey (transport) an adult because of their age, illness or disability to receive healthcare, personal care or social work. This doesn’t include transportation to and from church.
PARISH EXAMPLES
Example 1: Weekly Sunday School or Youth Group.
A parish operates a weekly Sunday school or youth group led by volunteers, at least one of whom meets the frequency criteria set out above (e.g. four or more days in a 30 day period). These volunteers are in Regulated Activity, meaning that the PCC is a children’s charity. The Diocese recommends that all PCC members hold an Enhanced DBS check for the child workforce.
Example 2: Creche
A parish runs a creche, which meets at the back of church during the morning service. A church volunteer helps with the activities, but the parents are always present. This volunteer is not in Regulated Activity. The parish does not run any other children’s activities. The PCC is not a children’s charity: the PCC members do not require a DBS check.
Example 3: Previously exempt children's workers
Following removal of the supervision exemption, a parish should review roles previously considered outside Regulated Activity solely because they were supervised. If any volunteer or worker is now in Regulated Activity, the PCC is a children’s charity and PCC members are eligible for an Enhanced check for roles with children.
Example 4: Pastoral Care, including with ‘vulnerable adults’.
Where a pastoral care team hold an Enhanced Check of the Adult workforce without the barred list check, team members are not in Regulated Activity with adults. In this situation, PCC members are not required to hold an Enhanced check for roles with adults.
Example 5: Regulated Activity with Adults.
Where personal care is provided to adults, those providing that care are in Regulated Activity with adults. PCC members should then be checked at Enhanced Level for the adult workforce.
FREQUENTLY ASKED QUESTIONS
Is this a legal requirement?
No. Government guidance establishes eligibility for DBS checks but does not set a requirement. This guidance sets out the Diocese's recommendation as a matter of good safeguarding practice.
Does every PCC need DBS checks for all PCC members?
No. This recommendation applies where the PCC has workers or volunteers undertaking legally defined Regulated Activity.
Does having children in church automatically make us a children's charity?
No. The key question is whether the parish has workers or volunteers undertaking Regulated Activity with children.
My PCC currently hold ‘Child and Adult Workforce Checks’. Do I need to make any changes?
No. The recommendations of this guidance already are met if your PCC members have the ‘Child and Adult Workforce Check’.
Is there separate guidance for Church Wardens?
No. The same guidance applies to Church Wardens as PCC members
Is there a deadline to make these changes?
No. As this is recommended best practice rather than a legal requirement, PCCs are encouraged to implement these changes, but no firm timescale is set.