Schools are having to tighten up their record keeping after an Ofsted survey found confusion surrounding procedures for vetting staff.

Following the publication of Ofsted’s report, the government introduced new measures to improve record keeping and revised guidance was issued over the summer for consultation.

Procedures for vetting school employees and volunteers came under close scrutiny at the beginning of this year after a controversy over sex offenders being cleared to work in education. As part of her response to the crisis, the then education secretary, Ruth Kelly, commissioned Ofsted to investigate how effectively schools and colleges were carrying out the existing checks during recruitment.

After surveying 58 schools, Ofsted came to the conclusion that, although schools and local authorities said staff were suitably checked, neither had  comprehensive evidence that this was so. Voluntary aided schools, where the governors are the direct employers of their staff, were also found not to have comprehensive evidence of their vetting checks.

Before the Ofsted report was published, the DfES had written to headteachers, explaining that amendments to the School Staffing Regulations would soon make it a legal requirement that schools maintain proper records and advising them to ensure that their record keeping was quickly improved. The letter also reminded schools that it had been mandatory for all newly appointed school employees to have Criminal Records Bureau checks since May 12 2006.

Another letter sent out at the beginning of July incorporated many of Ofsted’s recommendations as it set out details of the process schools should be working through to bring their record keeping up to scratch. In the first phase of the exercise, which was expected to have been completed by the end of September, schools were asked to record all information they possessed on staff as required under current guidelines. A second phase would then be introduced to advise schools on how to deal with the gaps identified where evidence could not be found for people who should have had List 99 or CRB checks.

Ofsted also drew attention to widespread confusion around the vetting of governors themselves. After an initial requirement for governors to have a standard CRB disclosure was dropped as the bureau struggled to cope with the volume of applications, governors were asked to sign a declaration of suitability and undergo a List 99 check. Although this situation will not change for many governors, those whose position is judged to include ‘regular work in the presence of children’ or who are in sole charge of children will have to have an enhanced disclosure.

Ofsted’s key findings on safeguarding children

  • Schools say that their staff are suitably checked, but do not have comprehensive evidence that this is so, whether relating to identity, qualifications or criminal records.
  • Local authorities say that they check those staff they employ (in maintained schools), but they do not have comprehensive evidence that this is so, whether relating to identity, qualifications or criminal records.
  • Voluntary aided church schools, whose governors employ staff directly, do not have comprehensive evidence that they check staff’s identity, qualifications or criminal records.
  • Schools are not sure which staff, or others who have contact with children, to check; nor are they sure what to do when checks are ‘pending’.
  • Half of the schools and colleges in the survey are not aware of, and therefore not using, the range of advice and guidance available to them.
  • The survey found misconceptions about the employment practices of supply agencies.

Information schools must hold


name, address and date of birth, along with record showing information was verified through appropriate documents and date when check was made


evidence of qualifications which are a requirement of the job, dated when check was made (overseas staff should also have been checked for evidence of permission to work)

List 99

evidence that a List 99 check has been carried out

CRB checks

evidence and date of Criminal Records Bureau check for all staff recruited since March 2002 (except those with approved continuity of service)

People for whom the school should have a record

  • all staff who are employed to work at the school and have regular contact with children and any employees who have been appointed since 12 May 2006, whatever level of contact they have with children
  • all staff employed as supply staff to the school, whether employed directly by the school or local authority or through an agency, who have regular contact with children
  • all others who work at the school who have regular contact with children – this covers volunteers, including governors who also work as volunteers within the school, and people brought into the school to provide additional teaching or other experience for pupils but who are not staff members, eg a specialist sports coach or artist