Secure Storage, Handling, Use, Retention and Disposal of Disclosures and Disclosure Information
1. General Principles
Medacs Healthcare, as an organisation using the Criminal Records Bureau (CRB) Disclosure and Disclosure Scotland services to help
assess the suitability of applicants for positions of trust, complies fully with their Code of Practice regarding the correct handling,
use, storage, retention and disposal of Disclosures and Disclosure information. It also complies fully with its' obligations under the
Data Protection Act 1998 and other relevant legislation pertaining to the safe handling, use, storage, retention and disposal of
Disclosure information and has a written policy on these matters.
2. Storage and Access
Disclosure information should be kept securely, in lockable, non-portable, storage containers with access strictly controlled and
limited to those who are entitled to see it as part of their duties.
3. Handling
In accordance with section 124 of the Police Act 1997, Disclosure information is only passed to those who are authorised to
receive it in the course of their duties.We maintain a record of all those to whom Disclosures or Disclosure information has been
revealed and it is a criminal offence to pass this information to anyone who is not entitled to receive it.
4. Usage
Disclosure information is only used for the specific purpose for which it was requested and for which the applicant's full consent
has been given.
5. Retention
Once a recruitment (or other relevant) decision has been made, we do not keep Disclosure information for any longer than is necessary.
This is generally for a period of up to six months, to allow for the consideration and resolution of any disputes or complaints. If, in very
exceptional circumstances, it is considered necessary to keep Disclosure information for longer than six months, we will consult either
the CRB or Disclosure Scotland about this and will give full consideration to the data protection and human rights of the individual
before doing so. Throughout this time, the usual conditions regarding the safe storage and strictly controlled access will prevail.
6. Disposal
Once the retention period has elapsed, we will ensure that any Disclosure information is immediately destroyed by secure means,
i.e. by shredding, pulping or burning. While awaiting destruction, Disclosure information will not be kept in any insecure
receptacle (e.g. waste bin or confidential waste sack).We will not keep any photocopy or other image of the Disclosure or any
copy or representation of the contents of a Disclosure. However, notwithstanding the above, we may keep a record of the date
of issue of a Disclosure, the name of the subject, the type of Disclosure requested, the position for which the Disclosure was
requested, the unique reference number of the Disclosure and the details of the recruitment decision taken.
7. Acting as an Umbrella Body
Before acting as an Umbrella Body (one which countersigns applications and receives Disclosure information on behalf of other
employers or recruiting organisations), we will take all reasonable steps to satisfy ourselves that they will handle, use, store, retain
and dispose of Disclosure information in full compliance with the CRB Code and in full accordance with this policy.We will also
ensure that any body or individual, at whose request applications for Disclosure are countersigned, has such a written policy and,
if necessary, will provide a model policy for that body or individual to use or adapt for this purpose.