05 · Vetting Checklist
Owner: Compliance Lead. Trigger: Offer made (file 04). Deadline: all green within 28 days of offer, otherwise the offer lapses.
The 8 vetting items
| # | Item | Evidence we collect | Renewal | Where it lives |
|---|---|---|---|---|
| 1 | Enhanced DBS (or PVG in Scotland / AccessNI in NI) | Original certificate number, issue date | Re-checked every 3 years OR on update service annually | Coach file (encrypted) |
| 2 | Right to work in UK | Share code + check date, OR passport + visa scan | Re-checked on visa expiry | Coach file |
| 3 | Professional reference #1 | Email reply on letterhead / verifiable domain | Once at onboarding | Coach file |
| 4 | Professional reference #2 | Same | Once at onboarding | Coach file |
| 5 | Professional indemnity insurance | Policy schedule, ≥£1m PI + £2m PL | Annual | Coach file |
| 6 | ICO registration (if self-employed and processing personal data) | ICO registration number | Annual | Coach file |
| 7 | Signed Code of Conduct | Countersigned PDF, includes FCA boundary (Sprint 4 / 01) and no-clinical scope | Re-signed at every contract renewal | Coach file |
| 8 | Bank details + IR35 status determination (if relevant) | Verified bank account; SDS where applicable | Annual | Finance system, not coach file |
What we do NOT collect
- Health information (we don't need it; reasonable adjustments handled by line manager equivalent).
- Personal financial history.
- Social media handles or "social media check" — we don't do those.
- Photographs beyond a professional headshot the coach uploads themselves.
Retention
- Vetting documents kept for the duration of the contract + 7 years (insurance / safeguarding audit floor).
- Reference content (the words the referee wrote) kept 24 months from receipt, then summarised to a one-line "received and positive/qualified/negative" and the source content deleted.
- All retention rules enforced via the same machinery as
src/server/evidence-pack-retention.functions.ts.
Audit drill
Once per quarter, Compliance picks 3 coach files at random and times themselves pulling all 8 items. Target: <10 minutes per file. If any item is missing, the coach is paused (file 09) until resolved.
Failure scenarios — how we handle them
| Scenario | Action |
|---|---|
| DBS comes back with disclosed conviction | Risk-assess against role using NACRO guidance. Not auto-decline. Decision documented and signed by Head of Coaching + Compliance Lead. |
| Reference declines to respond after 3 attempts | Coach asked for an alternate referee. Two failed referees = offer lapses. |
| Insurance lapses mid-contract | Coach paused immediately. Cannot deliver until renewed. |
| Code of Conduct breach reported | Triage within 48h. Suspension during investigation per file 09. |
