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Fri, 29th August, 2008
 
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Board and staff vetting policy

 
Internet Watch Foundation (IWF)
 
Policy on vetting staff and Board appointments
 
1 Introduction
The objectives of the Internet Watch Foundation (IWF) are to:
 
  • foster trust and confidence in the internet among current and future Internet users;
  • assist service providers to combat the abuse of their systems for the dissemination of criminal content; and
  • 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 and UK hosted incitement to racial hatred and obscene adult material.  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.
 
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 former DTI, now known as the Department for Business, Enterprise & Regulatory Reform, 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 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 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.
 
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 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 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 IWF will not discriminate unfairly against applicants with a criminal record. Having a criminal record will not necessarily bar an applicant from working for 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 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 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 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. 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 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.  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  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.
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.
Disposal
3.5 Once the retention period has elapsed, 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.
 
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Page Modified: Wed, August 8th, 2007

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