Safer recruitment in care: the evidence checklist for CQC compliance

What CQC Regulation 19 Requires

CQC Regulation 19 (Fit and Proper Persons Employed) requires that registered persons ensure all persons employed in the provision of regulated activity are fit and proper for the work they do.

"Fit and proper" means both competent (training, qualifications) and safe (character, conduct, DBS). Both must be evidenced before a person begins work in a regulated activity role.

Safer recruitment is not a HR process that sits separate from compliance. It is the point at which the compliance chain either holds or breaks. An unsafe hire who later causes harm will be traced back to whether the recruitment process was fit for purpose.

The Pre-Employment Evidence Checklist

Identity verification

• Passport or birth certificate + photo ID
• Confirmation of right to work in the UK (Home Office List A or List B documents)
• Verification that name matches DBS application, NMC/HCPC records, and payroll

Criminal records

• Enhanced DBS check completed, dated within 3 months of employment start
• DBS certificate reviewed by a named person, record made of disclosure or nil disclosure
• For roles with children or adults at risk: barred list check confirmed
• DBS Update Service subscription confirmed (if applicable; reduces need for repeat DBS on move between care settings)

Employment history

• Full employment history from education to present date. Unexplained gaps must be explored
• Minimum 2 professional references obtained, one from most recent employer in care
• References cover character and conduct, not just dates of employment
• All references received and reviewed before start date, not after

Qualification and registration verification

• Relevant qualifications verified (not just copies of certificates; originals checked)
• Professional registration checked and dated:
  • Nurses: NMC register search, PIN verified
  • Allied health professionals: HCPC register
  • Social workers: Social Work England register
• Mandatory training completion dates verified and applicable to the role

Health assessment

• Occupational health assessment completed or health declaration received
• Fitness to undertake the role confirmed
• Reasonable adjustments identified and documented if required

Contract and compliance documents

• Employment contract signed and dated
• Care certificate enrolment completed (for new care workers without prior experience)
• GDPR consent for processing personal data
• Data protection briefing completed and signed

The Most Common Regulatory Failures

1. Starting before DBS is complete

Under-pressure care homes sometimes allow new starters to begin work before the DBS certificate is received, with verbal assurances from the applicant that there is nothing to disclose.

This is not acceptable. If the DBS reveals a barring disclosure and the person has already been working with vulnerable adults, the regulatory and legal exposure is significant.

A risk-assessed period of supervised work may be possible in exceptional circumstances, but this requires a documented risk assessment, not an informal verbal agreement.

2. References received after the start date

References must be received and reviewed before the start date, not requested before the start date. Requesting a reference and starting someone before it arrives is the same exposure as not requesting one.

3. Right to Work checks not recorded properly

Under the Immigration Act, Right to Work checks must follow the Home Office guidance exactly. "We checked their passport" is not sufficient. The check must be documented with a record of which document was seen, when, and by whom.

4. Unexplained employment gaps not explored

A structured safer recruitment process requires that unexplained gaps in employment history are explored at interview, with the outcome recorded. A gap of six months without explanation is not a reason to decline employment. It is a reason to ask the question.

5. DBS obtained but not reviewed

The DBS certificate must be reviewed and a record made. "DBS obtained" is not the same as "DBS reviewed and decision recorded." If the certificate shows a disclosure, there must be a documented risk assessment of whether the disclosure is relevant to the role.

DBS at Government Cost

An Enhanced DBS check costs £49.50 at the government registered body rate. Third-party providers typically charge £65–70 for the same check, adding £15–20 per check, plus admin fees.

For a care home processing 15 DBS checks per year, that is £225–300 in unnecessary overhead. DBS at cost, through a registered body, is a direct saving that scales with your team size.

See the full detail on DBS checks and costs.

Centralising Safer Recruitment Evidence

The challenge with safer recruitment evidence is that it spans multiple people (hiring manager, HR, registered manager) and multiple document types (DBS, references, Right to Work, qualification certificates). In practice, this evidence ends up spread across email chains, shared drives, and paper files.

When CQC asks for a staff file at inspection, you need to produce a complete, dated record for each employee. A disorganised or incomplete file is a finding under Regulation 19, not just an administrative inconvenience.

A workforce verification system structures the safer recruitment process so every evidence item has a defined place, a status, and a completion record, before the person's start date rather than after.

See how safer recruitment evidence works in Statixs