PROVIDED ON BEHALF OF THE DEPARTMENT FOR WORK AND PENSIONS. Medical Services. Security Checks in Atos Healthcare - Pre-employment screening Guide
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1 MEDICAL SERVICES PROVIDED ON BEHALF OF THE DEPARTMENT FOR WORK AND PENSIONS Standards MEDICAL SERVICES PROVIDED ON BEHALF OF THE DEPARTMENT FOR WORK AND PENSIONS Security Checks in Atos Healthcare - Pre-employment screening MED-AHRP-HM01 Version: 07 January 2011
2 Document control Superseded documents Recruitment Procedures (MED-MSRP01) Version history Version Date Comment 1( Final) 07 January 2011 Final Version 1e(draft) 6 December 2010 Comments from CMMS 1d(draft) 11 October 2010 Further comments from CMMS 1c(draft) 28 September 2010 Comments from CMMS team 1b(draft) 19 July 2010 Updated comments from 1 st QR 1a (draft) 28 May 2010 General Review Changes since last version Outstanding issues and omissions Updates to Standards incorporated Issue Author: Owner and approver: Manasi Barve Process Design Team Manager Signature: Date: 07 January 2011 Distribution: LiveLink MED-AHRP-HM01 Page 2 of 23
3 Contents 1. About this document Purpose Applicability Owning Process Owner References 5 2. Introduction 6 3. Baseline Personnel Security Standard (BPSS) 7 4. Personal Details Full Name Age and Place of birth Current Address National Insurance Number (NI) Proof of Qualification/ Registration 9 5. Proof of identity and References Identity References Employment History Nationality and Immigration Status Criminal Record Disclosure from Disclosure Scotland Meaning Type of Disclosure Issuing Disclosure Forms Documentation check for Disclosure Outcome of Disclosure Hiring Overseas Candidate Confirmation of name, date and address National Insurance Number 18 MED-AHRP-HM01 Page 3 of 23
4 9.3 Qualifications/ Licence and Employment History References Permission to work in UK Criminal Record Check 19 Appendix A HM Compliancy Checklist 22 Observation form 23 MED-AHRP-HM01 Page 4 of 23
5 1. About this document 1.1 Purpose The purpose of this guide is to provide guidance on the process and the security clearance checks to the Hiring Manager (HM) in recruitment of the new staff. 1.2 Applicability The guide applies to both and Human Resource staff when undertaking the new staff recruitment for Hiring Manager. 1.3 Owning Process Human Resource 1.4 Owner The DWP Service Delivery Director owns this document The owner is responsible for approval of this document and all related feedback should be addressed to them. 1.5 References The following guides are referred to in this document: New Member of Staff System Access MED-NMS-SA01 Criminal Records Bureau Disclosure - lines for Managers & Interviewers UKG-HR-0022 MED-AHRP-HM01 Page 5 of 23
6 2. Introduction This document is designed to give an outline of the security requirements that all Atos Healthcare (AH) Hiring Managers (HM) are required to conduct at the time of interview, prior to engaging new recruits. This document provides the guidance for the Security Clearance Checks that are required as part of the contractual obligations to the Department for Work and Pensions. AH must have checks in place for all the new candidates who have access to the Department s data or assets. The HM is responsible for ensuring that the new recruits clinical and non-clinical have satisfactory checks in place on commencement of start date. Candidates should not be allowed to commence work until all the clearances are conducted. The Security Team, The recruitment teams (both clinical and non clinical), the Hiring managers and the Human Resource Support Centre (HRSC) team all play a vital role for these checks to be completed. The team Atos Recruitment Centre (ARC) which manage the end to end recruitment process for all GCM1-6 roles consist of: IT Support (BBP) Architecture, Testing, Project and Programme Management, Software Development (LTQ) Administration, Contact Centre, Healthcare - Non-Clinical (BBP) Non-permanent Admin Staff - All service lines Supply Chain Management, BI, Procurement, BC, HR, Finance GCM 7-9 will continue to be supported by the Senior Hire Office. Service Delivery Manager - Clinical Recruitment Department - Responsible for Permanent Clinical Staff Management of Clinical Associate - OH Service Line MED-AHRP-HM01 Page 6 of 23
7 3. Baseline Personnel Security Standard (BPSS) It is a mandatory requirement that all new recruits Non-Clinical & Clinical and overseas candidates recruited, or engaged in the delivery of services to DWP are compliant with the Baseline Personnel Security Standard (BPSS) before they are granted access to DWP s assets (premises, systems, information or data). The HM has to ensure that the relevant forms for this check are completed on the day of the interview. All new permanent, non-permanent, fixed-term clinical and non-clinical staff will require a basic disclosure check completing as part of the full BPSS process. In addition to the BPSS process, for Clinical staff a Full enhanced Criminal Records Bureau (CRB) check, is to be applied for before the candidate begins their employment. The below mentioned documents will be sent to the candidates prior to their interview only for the Clinical candidates and not for the non-clinical candidates. Non-clinical candidates are provided the documents on the day of the interview. They should be obtained by the HM during the interview process, in order to complete a BPSS application mentioned below. They are discussed in detail in the following sections. 1 x Basic Disclosure Form (Disclosure Scotland) 1 x Signed Original Official Secrets Declaration. 1 x Completed Employment History Document 1x BPSS Verification Record Form Basic Criminal Record Disclosure from Disclosure Scotland The link below provides full information on the BPSS material on Live link. ort=name&viewtype=1 MED-AHRP-HM01 Page 7 of 23
8 4. Personal Details 4.1 Full Name The HM has the responsibility of checking the security-related documents when a new candidate joins the organisation. All the relevant papers related to the new candidate s name should be checked and verified. If the person is known by any other name, then such papers must also be checked and verified. The document can be a current UK full driving licence (old) or current UK photo card driving licence or a gender recognition certificate. 4.2 Age and Place of birth A person s age is the poor determinant of ability. AH believes the concept of fairness and equal treatment. All screening and interviewing by the HM must be based on the competence, capability and the skills of the candidate. The HM should ask for a birth or adoption certificate, naturalisation or baptism record. The relevant certificate should be checked to ensure that the dates are consistent with the appearance of the candidate. The certificate will also indicate the age and the place where the person was born. The HM can further conduct the verification of Nationality and the immigration status of the candidate on the basis of the place of birth mentioned on the certificate Current Address The HM should confirm proof of address by asking for any 1 type of documentation which provides the candidate s name and the current address. Suitable documents are: Recent original utility bill or certificate from a utility company confirming the arrangement to pay for the services at a fixed address on prepayment terms Local Authority tax bill (valid for current year) or Bank, building society or credit union statement or passbook or Recent original mortgage statement from a recognised lender or Current local council rent or tenancy agreement. Refer to Appendix A for further details MED-AHRP-HM01 Page 8 of 23
9 4.4 National Insurance Number (NI) The new candidate needs to provide their NI number to the Recruiter responsible who will forward it to the HR. This is to ensure that correct tax and contributions are deducted from the candidate s pay. 4.5 Proof of Qualification/ Registration The HM should check the qualification of the new candidate. In case of a clinical candidate the HM should check the Annual Registration Certificate valid NMC/HPC or GMC pin Card or certificate etc. if the clinical candidate is a nurse, physiotherapist or doctor then the HM should check the proof of qualification Similarly the proof of qualification should be checked in case of Non clinical candidates, whether the candidate actually possess those certificates/degree as per the job requirement. Refer to Appendix A for further details on Qualification/ Registration MED-AHRP-HM01 Page 9 of 23
10 5. Proof of identity and References 5.1 Identity In order to provide proof of identity, the candidate should provide a document which is issued by a trustworthy and reliable source and is difficult to forge., It should be current and should contain the person s name, photograph and signature. HM should verify their identity by asking for at least two documents. The acceptable documents are : Current signed full passport Visa and /or other documentation relating to immigration status and permission to work. (See Nationality and Immigration status), Current UK photo card driving licence For Further acceptable documents, please refer to Appendix A 5.2 References References are required to verify and clarify a candidate s suitability for a role, once an interview has taken place. It is not a selection tool, but it is for candidates who are already successful. They are used to support the decision taken. All the new candidates will be required to have at least one reference from their current manager or their previous manager. All candidates whether Internal or external, Clinical or Non-Clinical, permanent or fixed or contract will have to provide the references. References can be sought from the: work address, work fax number or the work address. If the reference is received by the HM, then upon receipt of the reference the HM should forward the reference to HR If an unsatisfactory or ambiguous reference is received, the HM should inform the recruitment consultant and then it will be handled accordingly. All offers are subject to receipt of satisfactory references. If the candidate is appointed and then reference for the candidate is received as unsatisfactory or ambiguous, the HM needs to review the case of the candidate and check the reason for unsatisfactory reference. After reviewing the case the HM can take the appropriate decision for the candidate, as the candidate is still on probation period for 3 or 6 months as per the probation policy. The outcome of the review will be informed to the HR by the HM, which can be either continuing with the employment or it may include termination of employment. MED-AHRP-HM01 Page 10 of 23
11 Detailed information on the probation policy is provided on this link: /803136/804063/802078/ / /Probation_Policy.pdf?nodeid= &vernum=1 The below link provides the BPSS Identity and Reference material on livelink: ort=name&viewtype=1 MED-AHRP-HM01 Page 11 of 23
12 6. Employment History All new candidates, Clinical and Non clinical should provide details of their work history over the last three years at the time of joining. These details need to be submitted by the HM after completing the form BPSS Employment History, which record their work history before joining the AH. The candidate should provide detailed information of their work history including for any significant periods (over one month) spent not working. The reason for not working should be included in the form. The reason could be any reason like unemployment, further education, travel, sickness etc. The candidate must also include the name and address of the previous employer including the contact details and name of recent manager. The following details of previous employers are required: Dates of employment (from - to) Name and Address of the employer Name and Contact telephone number for the most recent manager. The below link provides the BPSS Employment History material on livelink: ort=name&viewtype=1 MED-AHRP-HM01 Page 12 of 23
13 7. Nationality and Immigration Status AH is required to verify a new candidate s eligibility to reside and work in the UK, this applies to all the candidates, including those born in the UK. Some candidates may need a work permit to start the work in the UK. A work permit is a generic term for a legal authorization which allows a person to take up employment. It is a permission given to the person to work in a country where he/she does not hold citizenship. If the person does not have a valid work permit and if they are caught by the Home Office (Borders and Immigration Agency), then the employing company can be fined. Candidates holding a passport are exempted, The UK The respective Channel Islands Work permit or other approval issued by Work Permits UK and a passport or other travel document endorsed to show that the candidate has current leave to enter or remain in the UK and is permitted to take the work permit employment in question, A letter issued by the Home Office to the holder confirming the same. An Immigration Status Document issued by the Home Office, endorsed with a UK Residence Permit, which indicates that the candidate has been granted indefinite leave to enter or remain in the UK, then such a candidate can take the employment in the UK. A letter is issued by the Home Office to the candidate, which indicates that this person has subsisting leave to enter, or remain in the UK and is entitled to take the employment in the UK. In all the above cases the stamps and the endorsements must be checked by the HM, to confirm that the passport stamps allow the candidate to take up the employment of the nature which is offered by AH. The expiry date on the Work permit must be checked to confirm the documents are still valid. If the candidate who is a British citizen and does not hold a current UK passport, they must produce a full UK birth certificate which specifies the names of the holder s parents and the Nationality so that this can be checked. The below link provides the BPSS Nationality and Immigration material on livelink: ort=name&viewtype=1 MED-AHRP-HM01 Page 13 of 23
14 8. Criminal Record Disclosure from Disclosure Scotland 8.1 Meaning A Disclosure is a document containing impartial and confidential criminal history information held by the police and government departments which can be used by employers to make safer recruitment decisions. The information includes: Details of Criminal records Information about a persons inclusion on children s or adult s lists Other relevant information held by a local police force or Government Body State that there is no information Information included on the document varies from the type of disclosure. Disclosure Scotland is a service designed to enhance public safety by providing potential employers and voluntary sector organizations with the criminal history information on individuals applying for posts. Refer to the website for further details - The HM has to decide the type of Disclosure check for the new candidate. 8.2 Type of Disclosure A. Basic Disclosure Only convictions considered unspent under The Rehabilitation of Offenders Act B. Standard Disclosure - All conviction information, spent and unspent, including cautions. C. Enhanced Disclosure - All conviction information, spent and unspent and any other non conviction information considered to be relevant by the police or other Government bodies. In Scotland these are Issued by Disclosure Scotland and in England and Wales by the Criminal Records Bureau (CRB) Disclosure Scotland issues certificates known as Disclosures which provides the details of an individual s criminal convictions or states that they have none. Enhanced Disclosure, where appropriate, will also contain the information held by police or government bodies. MED-AHRP-HM01 Page 14 of 23
15 The HM needs to ensure if the check is for the Clinical or Non clinical staff, as for Clinical staff the Enhanced CRB Disclosure has to be obtained along with the BPSS process and for Non-clinical staff only the Basic Disclosure has to be obtained from Disclosure Scotland as a part of BPSS process. 8.3 Issuing Disclosure Forms All Clinical and Non-Clinical candidates that are engaged to work for AH, are issued with the Disclosure Scotland form and the BPSS forms. These forms will be issued to a potential new candidate by the relevant Recruitment team, either clinical or nonclinical. The Clinical Recruitment Department issues the relevant disclosure forms and BPSS forms prior to any interview taking place. The candidates will bring the completed forms in full with them to the interview.. For the Non clinical candidates all the forms along with the Disclosure forms are completed by the candidates when they arrive for their interview. In addition to this the clinical candidates are required to sign a Criminal Record Declaration in the initial application form in the very first stages of the recruitment process. The HM has to check whether the clinical or non clinical candidate has a current ( within 6months) criminal record disclosure form. The relevant BPSS & CRB forms need to be completed by both, Clinical and Non Clinical candidate correctly with all the details in the correct section of the form and original signatures must be taken on all appropriate forms. The HM has to check the details in the forms and submit the forms to the Clinical Recruitment Department for the clinical candidates and in case of non-clinical candidates the HM needs to send the form directly to the Security team in order to avoid any further delay in processing the security checks. If the form is incomplete or the form is filled incorrectly then this can delay the start date of the candidate. 8.4 Documentation check for Disclosure The HM should check the relevant documentation submitted by the candidate to ensure that it confirms the candidate s identity and supports the Disclosure Scotland and CRB forms in obtaining the correct personal information. The HM needs to check the original passport or driving licence and write on the two photocopies `Certified a true copy of the original and then print their name and date and sign the statement. The HM also has to also check the address on the address-related evidence against the address on the CV or the application form or the competed Disclosure form. All applications for BPSS must include details of any unspent criminal convictions as disclosed in terms of the basic criminal record check carried out by Disclosure Scotland. MED-AHRP-HM01 Page 15 of 23
16 The Clinical and the Non clinical candidate has to submit the BPSS form to the HM and providing all the information which is required and its documentation. The information to be provided is: Information from a utility bill (gas, electricity or telephone) at the home address The number of any previous disclosure The address details covering at least the past five years The Criminal Record Check for the Clinical candidates is applied separately by completing the form. All cost for the Disclosure checks for the Clinical and the Non clinical candidates are covered by the AH and not by the candidate. The Clinical recruitment team conducts the criminal check and the BPSS forms handed over by the HM. The list of documents A utility bill (gas, electricity or telephone) or another document issued by a government department. or the local authority which confirms current address, and Either passport, driving license or birth certificate which shows the date of birth A Basic Disclosure can only be obtained via the organisation, Disclosure Scotland, but cover the UK and Wales. This check is vital for the BPSS process. When requiring a Basic check and an enhanced disclosure for a Scottish candidate two copies of the Disclosure Scotland form must be completed by ticking the relevant different box for each at the top of the form. Following the interview session all BPSS, Disclosure Forms and other required compliancy forms ( refer Appendix A) of the clinical candidates is sent by the HM to the Recruitment Department and for the non-clinical candidates the forms are directly sent to the security team as soon as possible. 8.5 Outcome of Disclosure On receipt of the Disclosure outcome for the clinical Candidate, the original certificate (not a copy) must be sent to the Clinical Recruitment Department and the non-clinical candidate must send the original certificate (not a copy) to the Security Directorate addressed to, Personnel Clearance Co-ordinator, Atos Origin, Greenwood House, Greenwood Drive, Manor Park, Runcorn, Cheshire, WA7 1UG. In case of Clinical candidates, the Full enhanced CRB copy is received by both, the candidate and the Security Directorate. In some cases, a certificate will be returned with the criminal convictions which have MED-AHRP-HM01 Page 16 of 23
17 not been previously discussed. In this case the HM should refer the candidate s case to the Head of HR and the Chief Medical Officer. This panel will decide whether or not the candidate will receive an offer of employment. All BPSS forms for unsuccessful Clinical candidates are destroyed once the role is filled by the HR. In case of Non-clinical candidates only the selected candidates fill in the BPSS forms. The new clinical and non clinical candidate will be unable to start until the Atos Security Directorate have approved the BPSS check. There is an exception to this process that has been agreed with the DWP team to permit the Clinical candidates to start with their employment, before the outcome of a BPSS check has been completed following the implementation of Security and Accreditation provided their BPSS forms are in process (with no issues highlighted during the completion) and the Clinical candidates are not left unsupervised during the training period. After completion of the Clinical candidates training, if still the BPSS check outcome is unknown, then the candidates will be unable to work in the Centre(MSC) or the Medical Examination Centre(MEC) until the full BPSS clearance has been obtained. The below link provides the BPSS Criminal Record material on livelink ort=name&viewtype=1 MED-AHRP-HM01 Page 17 of 23
18 9. Hiring Overseas Candidate Any candidate is an asset to AH. Whenever a new overseas candidate is hired to work in the UK, AH should ensure that they are entitled to work in the UK, with honesty, integrity and values and will need to follow BPSS process to comply with the DWP requirements. The HM needs to verify the documents as per the HMG to Contractors. HM is referred to as Contractor. There may be certain documents that the candidates can provide even if they live outside of the UK. The documents which the overseas candidate needs to submit and the Contractor to review are: 9.1 Confirmation of name, date and address The candidate s full name and signature, date of birth and full permanent address should be corroborated using as many of the following documents as is considered necessary on case-by-case basis. Only original documents should be used for identification purposes copies are not accepted. Where a signature has not previously been provided (because of e-application), the individual should be asked to provide it at a later date eg-at the time of interview, for checking the relevant documentation. Candidates should provide the photo ID along with the additional documents for adequate identification. The address verification for the overseas candidate can be done via correspondence or if there is a physical presence of Atos recruitment personnel in the candidates country before the candidate becomes the UK resident. Guidance on ID documentation checks is available from the Centre for the Protection of the National Infrastructure (CPNI) 2007: pdf 9.2 National Insurance Number National Insurance number or unique personal identifying number where appropriate must be provided by the new candidate. But it should not be considered as a sole means of identification or as wholly reliable indicator of entitlement to work in the UK by the Contractor as it can be acquired fraudulently. 9.3 Qualifications/ Licence and Employment History The Contractor needs to check the qualifications as mentioned in the CV and as required by the position for which the candidate has applied. Full details of previous employers( name, address and dates), for a minimum of past MED-AHRP-HM01 Page 18 of 23
19 3 years - The employment history can be verified with checking with the previous or the former employers. The previous of former employers should provide the relevant information about the candidate and minimise the effort involved to prompt a quick response. The candidates prior written permission should be taken to approach the previous and/or current employers. In case of self-employment the candidate should be asked to co-operate in providing the evidence(e.g. from bankers, solicitors etc.) as appropriate, confirming that the candidate s business was properly conducted and was terminated satisfactorily. In order to speed up the procedure the, Contractor can or telephone the previous and/or current employer and the telephone conversation should be recorded. 9.4 References The Contractor may seek suitable references if they wish, they are not required as a part of the Standard. The candidate should be honest enough and not conceal the gaps to verify recent( minimum of past 3 years)employment history. References are though not necessarily required. However, where confirmation of employment history is not available or cannot be confirmed a personal reference should be obtained. Where a candidate has been overseas for 6 months or more or for any reason the employer reference is not available, personal reference can be obtained from a referee of some standing in the candidate s community ( e.g. a JP, medical practitioner, officer, etc.) This is not necessary if the period of coverage is less than 6 months or if the candidate is in full time education, then the reference from the relevant academic institution can be obtained. 9.5 Permission to work in UK The contractor must take care while employing the candidate from overseas by preventing the illegal working and its penalised. It is an offence for any person to employ a person who is aged 16 or over who is subject to immigration control as per the Immigration, Asylum and Nationality Act Current signed full passport, travel document or other documentation related to immigration status and permission to work letter must be checked. The complete guidance on preventing illegal working is available on the Border and Immigration Agency website. 9.6 Criminal Record Check For candidates based outside the UK, access the Authority s assets, the Contractor shall ensure the appropriate and robust procedures are followed. A copy of these procedures should be provided to the Authority for their Approval. Specially that the information on criminal convictions available from Disclosure Scotland is largely confimed to UK residents and offences committed in the United Kingdom. The Security Industry Authority website does include guidance on obtaining a criminal record check in a number of countries. The Disclosure Scotland site also includes limited information on overseas criminal record checks. MED-AHRP-HM01 Page 19 of 23
20 Overseas criminal record checker( this link will take to the Security Industry Authority website) Disclosure Scotland website There is no requirement of these checks to be applied retrospectively where assurances have already been obtained or in place to allow access to the government assets. The implementation of the BPSS( including application of the unspent` criminal record check on all the candidates is a core mandatory requirement as per the Security Policy Framework(SPF). Where the BPSS cannot be approved by the Security Controller as the unspent convictions were declared, then the contractor will wish to consider the below points: A. The number of offences and their seriousness A number of offences and convictions resulting in prison sentences will be of greater concern than single convictions and those that have resulted in fines and discharge orders. Those offences that result in community penalties are generally more serious than those that result in fines and discharge orders, but less serious in those that result in imprisonment. B. The relevance of the offence The relevant offences in relation to the Authority s assets are property offences, notable theft and fraud, but also criminal damage. Other offences, such as drink-driving, assault and public order offences may in some instances be serious, but are not necessarily relevant to the post. C. The length of time since the offence occurred While there will always be exceptions to this rule, Home office statistics show that if someone goes more than two years from conviction or release from prison without re-offending, their chances of being cautioned or convicted again is considerably reduced. D. The nature and background of the offence Offence labels tend to sound worse than the behaviours they describe and the circumstances behind individual offences vary from the mitigating to the sorely aggravating. It is important to speak to the candidates about their offences in order to make assessment about whether they represent a risk or not. E. The candidate s attitude to the offence and evidence of change Many offenders will regret what they have done and feel a sense of remorse. Many will have been young at the time of their offences and will have matured and settled down and are likely to get into trouble again. This is especially true of young women but is also true of young men, although generally they take longer to settle down. Some candidates are likely to be unsuitable because of the nature and seriousness of their offences. The best way to determine whether a candidate is a risk is by discussing their offences and their attitudes to those offences with them. Decisions should not be made without giving candidates the opportunity to discuss their MED-AHRP-HM01 Page 20 of 23
21 offences. The below links provide the further guidance for Contractors and also the BPSS related forms: MED-AHRP-HM01 Page 21 of 23
22 Appendix A HM Compliancy Checklist BPSS Revised Compliancy Checklist. MED-AHRP-HM01 Page 22 of 23
23 Observation form Please photocopy this page and use it for any comments and observations on this document, its contents, or layout, or your experience of using it. If you are aware of other standards to which this document should refer, or a better standard, you are requested to indicate this on the form. Your comments will be taken into account at the next scheduled review. Name of sender: Date: Location and telephone number: Please return this form to Atos Healthcare, Process Design Team. to R Process Design MED-AHRP-HM01 Page 23 of 23
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