CRB Proposed Increase in Disclosure fees and Introduction of Fees for POVAFirst

2 February 2006

Response from the Independent Schools Council

The Independent Schools Council represents 500,000 children in 1,275 independent schools.  ISC exists to promote choice, diversity and excellence in education; the development of talent at all levels of ability; and the widening of opportunity for children from all backgrounds to achieve their potential.  Its schools rely on the quality of CRB checks to prevent unsuitable people from gaining access to these young people. 

ISC schools happily undertake CRB checks on all their staff and realise that there is a cost to be born for this service.  Given the current improvements that CRB are undertaking, in particular I-PLX and the new Quality Assurance Framework, a £2 increase in fees may not seem unreasonable.  However, ISC notes that the CRB Enhanced Disclosure check will have risen some 200% in four years from just £12 in April 2002 to £36 in April 2006.  The rise in this charge has not been mirrored in Scotland where Enhanced Disclosure checks still only cost £13.60.  These fee rises must be curbed soon as they are damaging, particularly within small voluntary and not-for-profit organisations such as independent schools.

ISC notes that these fee rises may coincide with the additional cost implications for smaller organisations of the CRB's proposals to introduce a minimum number of applications submitted per annum in order for an organisation to remain a Registered Body (RB).  The CRB's analysis of responses to a consultation on this issue states that many organisations were extremely concerned about the cost implications of having to use the services of an Umbrella Body (UB) if their organisation were deregistered, with 62% against deregistration.  The lowest cost of these services being, not £1 as quoted in the CRB's original Regulatory Impact Assessment for the above consultation, but at least £10-£14.  This, combined with the proposed fee rises, leaves small organisations, often those with the least access to extra money, having to find £46-£50 per Enhanced Disclosure check, an additional 35%-47%. 

In addition to this, the CRB is in the process of withdrawing ‘portability', a service which allows people who move jobs frequently to carry their CRB Disclosure check into a new post, without the need to conduct a new check.  Such people, many of whom do not work in high paid professions will be placed in extreme financial difficulties, if fee rises remain unchecked. 

In proposing fee increases at this time, the CRB should consider the total cost implications to end users of its services in the light of all the proposed changes it is considering at this time.  If other changes are carried out, it is certainly not the case that the only fee increase that CRB users will have to absorb over the coming year is £2 per check.