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Sprint 7 · Module 05 of 10

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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

#ItemEvidence we collectRenewalWhere it lives
1Enhanced DBS (or PVG in Scotland / AccessNI in NI)Original certificate number, issue dateRe-checked every 3 years OR on update service annuallyCoach file (encrypted)
2Right to work in UKShare code + check date, OR passport + visa scanRe-checked on visa expiryCoach file
3Professional reference #1Email reply on letterhead / verifiable domainOnce at onboardingCoach file
4Professional reference #2SameOnce at onboardingCoach file
5Professional indemnity insurancePolicy schedule, ≥£1m PI + £2m PLAnnualCoach file
6ICO registration (if self-employed and processing personal data)ICO registration numberAnnualCoach file
7Signed Code of ConductCountersigned PDF, includes FCA boundary (Sprint 4 / 01) and no-clinical scopeRe-signed at every contract renewalCoach file
8Bank details + IR35 status determination (if relevant)Verified bank account; SDS where applicableAnnualFinance 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

ScenarioAction
DBS comes back with disclosed convictionRisk-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 attemptsCoach asked for an alternate referee. Two failed referees = offer lapses.
Insurance lapses mid-contractCoach paused immediately. Cannot deliver until renewed.
Code of Conduct breach reportedTriage within 48h. Suspension during investigation per file 09.

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