DBS ID Guidance changes – with effect from 22nd April 2025

As of 22nd April 2025, the Disclosure and Barring Service (DBS) has implemented refreshed manual ID guidance for its DBS check service. This new guidance will be easier to understand and use for applicants and organisations conducting DBS checks.

The old guidance will continue to be useable until 1st November 2025, to take into account technical changes that Registered Bodies may need to make in line with the updated guidelines.

There are a number of changes which aim to streamline application routes (including those for non-UK nationals) and increasing the range of documents for applicants.  The full details of the changes can be viewed via this link. DBS launches new manual ID guidance for DBS checks – GOV.UK

Retention Period

The new DBS Identity Checking Guidelines (April 2025) refer to retaining identity check records for a ‘minimum of two years’. This relates specifically to DBS compliance processes. Schools already exceed this standard.

Although Keeping Children Safe in Education does not specify a fixed retention period, the recommendation is to retain documents used to evidence identity for the duration of a person’s employment, plus six years. This aligns with the data retention schedule here: https://www.gov.uk/guidance/data-protection-in-schools/record-keeping-and-management in the section ‘Create a data retention schedule’.

Evidence of current address for identity

The latest DBS Identity Checking Guidelines (from 22 April 2025) no longer states that at least one document must show the applicant’s current address, which was a specific requirement in the 2021 version. This only applies to Route One of the identity check. However, this doesn’t mean that schools no longer need to obtain or verify address information:

• The DBS application form still requires a full 5-year address history.
• The guidance still expects ID checkers to confirm the applicant’s identity as a whole and that includes being satisfied that their address history is accurate and consistent with other information (e.g. employment history, references).
• In cases where documents don’t confirm the current address, schools will still need to verify it through other appropriate means.