Keeping Children Safe in Education (KCSIE) 2025: A Practical Guide to Safer Recruitment (Part Three Summary)

If you're responsible for safer recruitment in a school or college, the KCSIE 2025 guidance sets a clear expectation:

Safeguarding isn't just a process. It's a system of checks, judgement, and accountability.

On paper, part three of KCSIE provides a structured framework.

In practice, applying that framework consistently - across roles, jurisdictions, and edge cases - is where most of the challenge lies.

This article breaks down:

The full list of checks referenced in KCSIE
The roles those checks apply to
And where schools and colleges are required to interpret the guidance

The Checks

Below is a consolidated list of the checks referenced in Part three: Safer recruitment.

Category	Check
IDENTITY	✓ Identity verification (including name history)
ELIGIBILITY	✓ Right to work in the UK
HEALTH	✓ Mental and physical fitness
CRIMINAL	✓ Enhanced DBS ✓ Enhanced DBS + children's barred list ✓ Standalone children's barred list (where applicable) ✓ DBS Update Service status (if subscribed and used)
EMPLOYMENT	✓ References (must be or must include): From an authorised person Verified as genuine From a legitimate source Covering most recent employment Last role working with children (where applicable) Reason for leaving Any concerns resolved before appointment ✓ Employment history review (including gaps)
SUSTAINABILITY	✓ Self-declaration of criminal record
DUE DILIGENCE	✓ Online search of shortlisted candidates
QUALIFICATIONS	✓ Professional qualifications verification
TEACHING	✓ QTS verification ✓ Induction / probation verification ✓ Prohibition from teaching ✓ Interim prohibition order ✓ GTCE legacy sanctions
MANAGEMENT	✓ Section 128 direction
CHILDCARE	✓ Childcare disqualification
OVERSEAS	✓ Overseas criminal record ✓ Professional regulatory authority, e.g. Ministry of Education letter ✓ Alternative checks where formal records are unavailable ✓ Risk assessment where information cannot be obtained

For full procedural detail, see the KCSIE guidance linked at the bottom of this article.

The Roles

KCSIE applies these checks across a wide range of roles.

Role	Key Considerations
Teaching staff	Typically regulated activity
Non-teaching staff	May or may not be regulated activity
Agency & Third-Party Staff (Supply Staff)	Written confirmation from agency that checks have been completed, identity check on arrival
Contractors	May or may not be regulated activity, identity check on arrival
Trainee / student teachers	Full safer recruitment checks (if salaried by school/college). Confirmation checks completed by training provider (if fee-funded).
Visitors	Identity check (for professional visitors), confirmation of DBS checks by employer (where applicable)
Volunteers	Risk-based checks (never unsupervised without checks)
Management (independent schools)	May or may not be regulated activity, section 128 direction
Governors and proprietors	May or may not be regulated activity, identity verification, overseas checks (where applicable), section 128 direction
Alternative provision / work experience	Written confirmation that safeguarding checks have been completed by provider

The Critical Factor: Regulated Activity

The single biggest factor in determining the level of criminal record check required is whether an individual is engaging in regulated activity.

In simple terms:

Regulated activity

Requires an Enhanced DBS check with children's barred list information

Not regulated activity

Requires an Enhanced DBS check (no barred list)

This distinction is fundamental.

Where It Gets Difficult

On paper, this framework is structured and logical.

But in practice, the challenge begins when schools are required to apply judgement.

KCSIE deliberately avoids being overly prescriptive - and instead places responsibility on schools and colleges to determine what is “appropriate” in context.

1. Overseas Checks

KCSIE states:

“Schools and colleges must make any further checks they think appropriate…”

This is where complexity increases quickly.

Questions arise:

Which countries provide criminal record data?
How reliable are those sources?
What should be done where records are unavailable?
What is considered “sufficient” due diligence?

Take Saudi Arabia as an example.

Guidance states - ”The UK is not currently aware of a process for obtaining criminal record certificates from the Saudi Arabian authorities.” In practice, checks can be obtained - if you know how.

The challenge isn't just compliance, it's knowing what's actually possible.

A Common Risk: Candidate-Supplied Overseas Checks

One issue that comes up repeatedly in conversations with schools and colleges is how overseas checks are obtained.

In many cases, candidates are asked to:

Apply for their own criminal record documentation
Receive the document
Submit it to the school

In some jurisdictions, this is unavoidable.

But it introduces a structural risk.

Because the candidate:

Controls how the check is obtained
Receives the document

There is an inherent conflict of interest.

This raises important questions:

How is authenticity verified?
Could documents be altered or selectively presented?
Would this approach stand up to inspection?

The question isn't whether a check has been completed, it's whether the way it was obtained is independent and defensible.

Additional Overseas Assurance

KCSIE also highlights the option of obtaining:

A letter from the professional regulating authority, e.g. Ministry of Education

Confirming:

No sanctions or restrictions
No known reason the individual is unsuitable to teach

Again, this is straightforward in theory - but inconsistent in practice across countries.

2. Online Searches

KCSIE states that schools:

"should consider carrying out an online search…"

This is not a requirement.

But in practice:

In many cases, inspectors expect to see it
There is no defined methodology
There is no clear threshold for concern

So schools are left asking:

What should we search?
How far back?
What is relevant?
How do we record it?

This creates inconsistency - even within the same organisation.

3. The Judgement Gap

KCSIE sets out:

What must be done
What should be considered

But it does not fully define:

What "good" looks like in every scenario
What is proportionate
What is excessive

This creates a judgement gap.

And that gap is where:

Confusion creeps in
Processes diverge
Risk becomes harder to manage

4. Inspectors Interpret the Interpretation

Even where schools and colleges follow KCSIE:

Inspector expectations evolve
Judgement calls are scrutinised
Documentation becomes critical

It's not just about doing the checks, it's about being able to show your work.

What This Looks Like in Practice

Consider a typical scenario:

A candidate:

Has recently worked in a UK school
Previously lived overseas
Needs to start quickly

Questions arise:

Is a new Enhanced DBS required?
Are overseas checks necessary?
Should a risk assessment be considered to speed things up?

There isn't always a single correct answer.

KCSIE expects schools to apply judgement - and justify it.

The Real Challenges Schools Face

From conversations with schools and colleges, the challenges tend to fall into three areas:

1. Interpreting the Guidance

Ambiguity around overseas checks
Lack of definition for online searches
Judgement required for edge cases

2. Knowledge & Experience

Understanding what checks are possible globally
Knowing how to obtain them
Applying consistent standards

3. Administrative Burden

Chasing references across time zones
Researching best practice for specific international checks
Maintaining audit trails

In some cases, schools and colleges even hire additional staff to manage this workload - time that could be spent elsewhere.

Where Structured Support Comes In

This is where many schools and colleges look for support.

Not because they don't understand safeguarding - but because:

The interpretation burden is high
The knowledge required is global
The execution is time-intensive

Working with a partner like Avvanz helps to:

Bring clarity to grey areas
Provide global expertise
Ensure consistency
Reduce administrative burden

So when decisions are challenged:

they are clear
they are documented
and they are defensible

The Single Central Record (SCR)

The SCR is your school or college's audit trail of pre-appointment checks.

It must record:

What checks were carried out or certificates obtained
When
For whom

For schools (colleges and independent schools have slightly different requirements), it must include all staff, including:

Teacher trainees on salaried routes
Agency and third-party supply staff

If it's not recorded, it didn't happen.

Beyond Recruitment

KCSIE makes it clear that recruitment is just the start.

Schools must:

Carry out new checks where roles change
Act on concerns
Refer cases to DBS or TRA where required

Safeguarding is continuous.

Final Thought

KCSIE provides a framework.

But it deliberately leaves space for judgement.

And in that space:

Standards can drift
Risk can increase
Confidence can drop

The difference isn't just doing the checks.

It's knowing which checks matter, when, and why - and having the evidence to stand behind every decision.

Full Guidance

For full details, refer to the official KCSIE 2025 guidance: Link