Board and Staff Vetting Policy
1 Introduction
The objectives of the Internet Watch Foundation (IWF) are to:
-
Foster trust and confidence in the internet
-
Assist service providers to combat the abuse of their systems for the dissemination of criminal content
-
Assist law enforcement in the fight against criminal content on the internet
The types of content covered by IWF activities are:
-
Child sexual abuse images hosted anywhere in the world
-
Non-photographic child sexual abuse images hosted in the UK
-
Criminally obscene adult content hosted in the UK
The precise terms of
the IWF’s remit and objectives are determined by its Board according to
the procedures in the constitution and are recorded in a separate
document.
The IWF works in
partnership with the police, Government and internet industry. We have
close working ties with a number of national police units and with most
Constabularies. We have regular meetings with Ministers and officials
from the Department for Business, Innovation and Skills, and the Home
Office with specific responsibility for internet affairs and we are a
members of a number of national working groups dealing with and advising
on internet safety.
A
Memorandum of Understanding between Crown Prosecution Service (CPS) and
the Association of Chief Police Officers (ACPO) concerning Section 46
Sexual Offences Act 2003 determines that the IWF is a “relevant”
authority which enables it to carry out its work.
Board
expressed their determination to ensure that the IWF is a robust and
professional organisation aspiring to best practice and at their meeting
on 11th February 2003 agreed:
“That
the Board endorse a formal approach by the IWF to the Home Office to
seek provision for IWF’s inclusion as an organisation for staff and
Board members to have Enhanced Disclosures from the Criminal Records
Bureau”
In
2004 an amendment to the Criminal Records Bureau (CRB) Regulations
under part 5 of the Police Act 1997, acknowledged the IWF’s position
with regard to Disclosures for Hotline staff:
“15.
With the advent of different ways of delivering services, and of
different technologies, it is proposed that Enhanced Disclosures should
be available in respect of people whose duties involve:
-
monitoring illegal material (including paedophile images on the internet) on any form of electronic communication system for the purpose of preventing such abuse.”
Since the amendment the CRB have been carrying out Enhanced Disclosures for IWF Hotline staff and their direct line management.
2 Policy Statement
Following advice
in June 2006 with regard to the regulations determining eligibility and
in accordance with the assessments and Board resolution of February
2003, all IWF staff and Board appointments will be subject to a CRB
Enhanced Disclosure.
An organisation
which makes use of CRB Disclosures as part of its appointments process
must adhere to the CRB Code of Practice and have a policy statement on
appointing ex-offenders.
The IWF policy on
vetting procedures and the appointment of staff and Board members with
criminal convictions is attached at annex A below.
Annex A
Internet Watch Foundation (IWF)
Policy on the use of criminal record checks and the recruitment of staff and Board members with criminal convictions
1 Scope and Purpose
1.1 This document outlines the IWF’s
policy on the use of criminal record checks, the storage and use of
information which has been disclosed by the Criminal Records Bureau
(CRB) and the recruitment of staff and Board members with criminal
convictions. It should be read in conjunction with the IWF’s policy on
staff recruitment and selection in the Employee’s Handbook and the IWF
Constitution and Board Members Handbook.
1.2 This policy applies to all staff and Board members and will be given to applicants at the outset of the selection process.
2 Introduction
2.1 The IWF will not discriminate
unfairly against applicants with a criminal record. Having a criminal
record will not necessarily bar an applicant from working for the IWF or
from Board membership; the nature of a disclosed conviction, its
relevance to the post in question and the length of time since the
offence occurred, will be considered. Any conviction of a sexual
offence, however, is likely to be incompatible with working for the IWF
or for being a Board member. The Rehabilitation of Offenders Act 1974
provides that ex-offenders are not required to disclose to prospective
employers, convictions defined as spent under the Act. Given the nature
of the work undertaken by the IWF, applicants for employment and Board
positions must disclose any conviction, caution or inappropriate
behaviour that could bring their personal and professional suitability
for the appointment into question.
2.2 Where a conviction or caution has
been disclosed in an individual’s application for a post at the IWF, a
discussion will take place at the end of the interview regarding the
offence and its relevance to the position. Failure to reveal information
relating to any conviction of a sexual offence could lead to withdrawal
of an offer of employment or Board appointment.
2.3 The IWF uses the Criminal Records
Bureau (CRB) Disclosure Service to obtain information which enables the
assessment of an applicants suitability for employment or Board
membership. The IWF complies fully with the CRB code of practice and
does not discriminate unfairly against any subject of a CRB disclosure
on the basis of conviction or other information revealed.
2.4 The IWF complies with the CRB code
regarding the secure storage, handling, use, retention and disposal of
CRB disclosures, disclosure information and with its obligations under
the Data Protection Act.
2.5 In addition to the formal vetting
procedures, all candidates for appointment to roles within the IWF must
provide a minimum of two referees. The IWF treats all information gained
from referees, both previous employers and personal, as private and
confidential. All responses from referees are stored in the candidates
file for the retention period.
2.6 The IWF’s appointments procedures
will follow the relevant principles set out within the recommendations
of the Bichard report relating to recruitment and selection.
3 Appointments requiring a CRB disclosure
3.1 An appointee will be requested to
submit to a CRB disclosure request when they are seeking appointment as
either a member of staff or a Board member. The further particulars of
a post or Board appointment will contain an indication that a CRB
disclosure will be requested in the event of the individual being
offered the position. All subjects of a CRB disclosure request will be
made aware of the CRB Code of Practice. Any information revealed in a
disclosure that is likely to lead to the withdrawal of a job offer or
Board appointment will be discussed with the applicant before the offer
is withdrawn.
Storage and Access
3.2 CRB disclosure information will not be stored on an employee’s personnel file but will be stored separately in lockable storage with access limited to those who are entitled to see it as part of their duties. A record will be maintained of all those to whom disclosure information has been revealed as it is a criminal offence to pass this information to anyone who is not entitled to receive it.
3.2 CRB disclosure information will not be stored on an employee’s personnel file but will be stored separately in lockable storage with access limited to those who are entitled to see it as part of their duties. A record will be maintained of all those to whom disclosure information has been revealed as it is a criminal offence to pass this information to anyone who is not entitled to receive it.
Usage
3.3 CRB disclosure information will
only be used for the specific purpose for which it was requested and for
which the applicant’s full consent will have been obtained.
Retention
3.4 Once a recruitment (or other relevant) decision has been made, CRB disclosure information will not be stored for longer than is necessary. This is generally for a period of up to six months to allow for consideration and resolution of any disputes or complaints. If, in exceptional circumstances, it is considered necessary to keep such information for longer than six months, consideration will be given to the Data Protection rights of the individual.
3.4 Once a recruitment (or other relevant) decision has been made, CRB disclosure information will not be stored for longer than is necessary. This is generally for a period of up to six months to allow for consideration and resolution of any disputes or complaints. If, in exceptional circumstances, it is considered necessary to keep such information for longer than six months, consideration will be given to the Data Protection rights of the individual.
Disposal
3.5 Once the retention period has elapsed, the IWF will ensure that any CRB disclosure information is destroyed and while awaiting destruction, the information will be kept securely. A record of the date of issue of a disclosure, the name of the subject, the type of disclosure, the position for which the disclosure was requested, the unique reference number of the disclosure and the details of the recruitment decision taken, will however be securely stored for monitoring purposes.
3.5 Once the retention period has elapsed, the IWF will ensure that any CRB disclosure information is destroyed and while awaiting destruction, the information will be kept securely. A record of the date of issue of a disclosure, the name of the subject, the type of disclosure, the position for which the disclosure was requested, the unique reference number of the disclosure and the details of the recruitment decision taken, will however be securely stored for monitoring purposes.
Please note: The IWF uses the term child sexual abuse content to accurately reflect the gravity of the images we deal with. Please note that child pornography, child porn and kiddie porn are not acceptable terms. The use of such language acts to legitimise images which are not pornography, rather, they are permanent records of children being sexually exploited and as such should be referred to as child sexual abuse images. If you see such content online please report it to the IWF.
