School exchanges are an enriching and enjoyable part of learning a language. But recently there has been some confusion around DBS checks for host families on school exchanges.
In September 2016 the government amended the wording in its Keeping Children Safe in Education guidance in respect to school exchanges.
The changes have led to uncertainty among some school leaders about what they are legally responsible for.
Are DBS checks a requirement for host families?
The government’s guidance states that schools arranging a stay with a host family ‘should request a DBS enhanced check (which will include barred list information) to help determine their suitability for the arrangement’.
But it’s important to note that in a statement to the Association for Language Learning, the Department for Education (DfE) confirmed that this is a suggestion and not a requirement.
There is no requirement for schools to carry out DBS checks for host families on school exchanges – but they are able to if they wish.
If a school makes an arrangement for a child to live with a host family, including if the school engages a company to make the arrangement on their behalf, then the host family is considered to be in regulated activity and is eligible to be DBS checked.
However, because the regulated activity takes place in the host family’s home and not in a ‘specified place’, the regulatory requirement for DBS checks does not apply.
If arrangements are made directly between parents with no involvement from the school, then this would be deemed a private arrangement. This would not count as regulated activity and so the families would not be subject to DBS checks.
What does this mean for schools?
It’s up to schools to decide whether or not to undertake DBS checks for host families on school exchanges. However, safeguarding should always be the priority in any activity involving children. All schools should understood that a host family would be eligible to have this level of check carried out.
The government’s guidance is in place to help protect children, and it’s important to remember that a school’s obligation to its pupils goes beyond regulatory compliance.
Schools should always act reasonably and sensibly and consider pupils’ welfare first and foremost.
In its statement to the Association for Language Learning, the DfE said: “If schools decide not to carry out these checks, they should satisfy themselves that they are not putting a child at risk and be able to justify the decision if challenged.”
What about overseas host families?
Where host families are overseas, it won’t be possible for schools to carry out DBS checks due to DBS checks being UK-based.
In these cases, schools should seek assurance from their overseas partners to determine whether host families are suitable for this role.
In addition, schools could look into the possibility of the overseas school or the relevant provider carrying out criminal record checks on the overseas host families. As mentioned before, DBS checks are UK-based, but there will be a DBS check equivalent specific to each country – so this could be an avenue to explore.
Schools can also take steps to reduce risk while pupils are away from home. For example, they could ensure pupils see a member of staff every day, have access to a mobile phone and know who to contact if they have any concerns.
DBS checks for host families on school exchanges: a summary
DBS checks for host families on school exchanges are not a legal requirement.
However, the government suggests that schools should carry out enhanced DBS checks on host families they have arranged to place exchange pupils with.
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