Pre-Employment Checks Policy

Pre-Employment Checks Policy Policy Reference Number PRS057 Status Ratified Version 4 Implementation Date August 2008 Current/Last Review Dates July 2009, November 2010, September 2013 Next Formal Review August 2018 Sponsor Director of Human Resources Sponsor Signature Author Where available Target audience Director of Human Resources Intranet All Trust staff on any site involved in the process of undertaking pre-employment checks Ratification Record Clinical Governance and Risk Committee August 2013 Procedural Document Sub Group (Clinical Governance and Risk Committee) September 2013 Approval Record Committee Name Chairperson Date HR Steering Group Director of HR Joint Staff Committee Director of HR JCC Director of HR June 2013 Consultation HR Steering Group members Joint Staff Committee members Date Regulators Requirements Standards for Better Health NHSLA Risk Management Standard for Acute Trusts Core standard C10a Standards 1.9 and 1.10 Document Control / History Version No Reason for change 1 New policy in line with regulator requirements 2 New policy format and ensure document is in line with regulator requirements 3 Slight amendments made in November 2010 4 Slight amendments and ensure document is in line with regulator requirements

Contents Section Page Document Summary 3 1 Introduction 4 2 Purpose 4 3 Definitions 4 4 Duties (Roles and Responsibilities) 5 5 A systematic approach to employment checks 6 5.1 Checks to be carried out on appointment 6 5.2 Ongoing checks 7 5.3 Carrying out and recording checks 7 5.3.1 Verification of identity checks 7 5.3.2 Right to work checks 7 5.3.3 Registration and qualification checks 7 5.3.4 Employment history and reference checks 8 5.3.5 Disclosure and Barring Service checks 9 5.3.6 Occupational health checks 9 5.4 Following up those who fail to satisfy employment checks 10 5.5 Temporary staff 10 5.6 Starting work before completion of checks 11 5.7 Recording and protecting data 11 6. Assuring the checking process 11 7. Training and Implementation 11 8. Equality Impact Assessment 12 9. Monitoring Compliance with this Policy 12 10. Associated Policies and Procedures 13 11. References 13 Dartford and Gravesham NHS Trust Page 2 of 14

Document Summary This policy sets out how the Dartford and Gravesham NHS Trust will ensure that NHS Employers Employment Checks Standards are incorporated into Trust practice. In summary the Trust s policy is that: Permanent and fixed term staff may only be appointed through Human Resources. The policy explains the requirements of the following pre-employment checks (as required by the NHS Employers Employment Checks Standard): Verification of identity checks Right to work checks Registration and qualification checks Employment history and reference checks Disclosure and Barring Service checks Occupational health checks These checks apply to permanent or fixed term medical and nonmedical staff, volunteers, students, trainees, contractors, highly mobile staff employed through an agency and flexible workers employed by NHS Professionals (NHSP). In normal circumstances all of the above checks must be completed satisfactorily before the member of staff starts. However, in some limited circumstances staff may be permitted to start work without all checks being completed. This must be approved by the Director of Human Resources (or their nominated deputy) in advance. False declarations of information on application forms may result in disciplinary action up to and including dismissal. Dartford and Gravesham NHS Trust Page 3 of 14

1. Introduction Thorough pre-employment checks are essential to ensure patient safety and patient confidence in staff that provide services to them. They are also essential to ensure the Trust complies with Department of Health, the law, and NHS Care Record Service requirements. 2. Purpose The policy sets out to ensure that there is a system in place to complete appropriate preemployment checks for applicants to the Trust. The purpose of this policy is to explain to all staff involved in recruitment their responsibilities for pre-employment checks. Failure to comply with these standards could potentially put the safety, and even the lives, of patients, staff and public at risk. The aim of this policy is to provide a system of administering pre-employment checks and to incorporate the NHS Employers Employment Checks Standards into Trust practice. The Employment Check Standards include those checks that are required by law, those that are Department of Health policy and those that are required for access to the NHS Care Record Service. This policy applies to permanent staff, staff on fixed-term contracts, temporary staff, volunteers, students, trainees, contractors, highly mobile staff employed through an agency and flexible workers employed by NHSP. When the Trust appoints locums and agency staff it will ensure that these providers comply with these standards. This policy does not apply to staff who retire and rejoin the Trust within one month. 3. Definitions Permanent staff A person who is employed with the intention of there being an ongoing employment relationship for an indefinite period which may be full time or part time. Temporary or honorary staff A person who is employed full time or part time either for a non permanent period or a person who is appointed to work for the organisation through an agency or third party. Flexible worker employed by NHSP A person who undertakes temporary work for the Trust through their employer, NHS Professionals. NHSP are the chosen supplier of nonmedical temporary workers for the Trust. Volunteer A person who volunteers their time for the Trust without remuneration. Pre-employment checks Refers to all checks as defined by the NHS Employers Employment Checks Standards i.e. verification of identity checks, right to work checks, registration and qualification checks, employment history and reference checks, criminal records checks and occupational health checks. Disclosure and Barring Service (DBS) - An external organisation responsible for undertaking criminal record check of applicants. Relevant section of Human Resources where this term is used in the document it refers to the Recruitment Team for permanent, honorary and fixed-term non-medical staff and Medical Staffing for permanent and temporary medical staff where engaged directly by the Dartford and Gravesham NHS Trust Page 4 of 14

Trust. This also applies to Trust medical honorary appointments. The manager responsible for these teams is responsible for ensuring actions are undertaken. 4. Duties (Roles and Responsibilities) 4.1 Duties within the organisation Director of Human Resources The Director of HR has corporate accountability for pre-employment checks and the effective operation of this policy. Human Resources department (HR) The relevant section of HR is responsible for ensuring pre-employment checks are completed for all permanent staff, staff on fixed-term contracts, trainees and honorary appointments. HR staff involved in recruitment must ensure that they understand the full requirements of all Employment Checks Standards. Staff Resourcing Manager The Staff Resourcing Manager is responsible for ensuring pre-employment checks are completed for non-medical employees of the Trust. This includes making sure that managers are suitably trained or briefed, for example to check candidate s documentation at interview. Medical Staffing Manager The Medical Staffing Manager working with the Medical Staffing Officer is responsible for ensuring pre-employment checks are completed for permanent and temporary medical staff employed directly by the Trust. Junior Doctor Rota Manager (JDRM) The JDRMs are responsible for checking that the relevant pre-employment checks for locum doctors have been carried out by the agency. Volunteer Services Manager is responsible for ensuring pre-employment checks are completed for volunteers. Contractor/partner organisations Contractor organisations are required to comply with these standards for staff providing services to the Trust: The PFI Contract Manager will ensure that these requirements are incorporated into the contracts with the main contractor organisations; currently Carillion and Vinci. The PFI Contract Manager will prompt the Staff Resourcing Manager (via a standing item on the performance meetings with the Hospital Company) to undertake an annual audit of the main contractor organisations preemployment check records. NHSP is responsible for ensuring pre-employment checks are completed for flexible workers employed directly by NHSP. This is covered in the contract between NHSP and the Trust. The manager responsible for supplementary contractors will be responsible for ensuring pre-employment checks are completed. (Please see section 6 on training and implementation for further information on the application of this section of the policy). Managers are responsible for Ensuring no member of staff starts work until satisfactory pre-employment checks have been completed. Dartford and Gravesham NHS Trust Page 5 of 14

Ensuring that they fulfil their responsibilities in procedures to support the effective operation of this policy (e.g. inspecting and copying documentation at interview). Checking with the main employer that the DBS, professional registration and occupational health status of people with an honorary contract is up to date and ensuring identity checks are completed on the individual s first day at this Trust. (Please see section 6 on training and implementation for further information on the application of this section of the policy). All Staff are required to co-operate with the requirements of this policy. 4.2 Committees and Groups with Overarching Responsibilities Trust Board The Chief Executive and nominated directors will gain assurance on the implementation of this policy from the Director of Human Resources. HR Steering Group The HR Steering Group is responsible for overseeing this policy and monitors its application. The HR Steering Group reports to the Quality and Safety Committee. 5. A Systematic Approach to Employment Checks The Trust adheres to the six documents that form the NHS Employment Check Standards (2010). 5.1 Checks to be carried out upon appointment The NHS Employment Checks Standards comprise the following as the agreed checks to be carried out upon appointment: Verification of identity checks. Right to work checks. Professional registration and qualification checks. Employment history and reference checks. Disclosure and Barring Service Checks (DBS) Occupational health checks. Links to each of these NHS Employment Check Standards are contained within this document under the different headings for each standard. It is also recognised that legal requirements, Department of Health requirements, and NHS Employers guidance may change, sometimes at short notice than it is reasonably practical to incorporate into policy. HR will incorporate any updates in legal requirements, Department of Health requirements, and NHS Employers guidance into Trust practice as soon as reasonably practical. Written offers of employment may only be made by the HR department on request of a manager with delegated authority to recruit staff. Offers of employment will be conditional upon satisfactory completion of pre-employment checks. The HR department is responsible for retaining the relevant paperwork of all preemployment checks on an individual s personal file. The individual member of Human Resources completing the check must record that the original documentation was sighted Dartford and Gravesham NHS Trust Page 6 of 14

and checked, that the pre employment checks were satisfactory and when the check was completed. The HR department will follow up applicants who have not provided information required to complete pre-employment checks, and for progress chasing documentation that can only be provided by external bodies (e.g. references, DBS checks). 5.2 Ongoing Checks Professional Registration checks will be completed in line with the Professional Registration Checks policy. DBS checks are not routinely repeated for this Trust s employees and this is in line with advice from NHS Employers. However if an employee were to move to another post internally within the Trust and that post satisfied the requirement for a DBS check, then a further DBS check would be completed at that stage. Furthermore the Trust retains the right to request that a further disclosure is sought at any time for an employee in a post that requires a disclosure see item 5.3.5. 5.3 Carrying out and Recording Checks 5.3.1 Verification of identity checks It is the responsibility of the HR department to complete identity checks on the employees first day of service. If the Trust is unable to verify the identity of an applicant to its satisfaction the offer of employment will be withdrawn. Current NHS requirements and advice on these checks are included in the NHS Employers Employment Checks standard on the Verification of Identity Checks. The Trust will adhere to these standards. Link to NHS Employment Check Standards: http://www.nhsemployers.org/aboutus/publications/documents/verification%20of%20identit y%20checks.pdf 5.3.2 Right to work checks No employee may start paid work until the Trust has confirmed that he/she has the right to work in the Trust. Where the right to work is time limited (e.g. work permit) it is the responsibility of the employee to ensure that he/she takes appropriate action to renew the right to work and stay in the country. The HR department will ensure that this is monitored and will remind the employee and his/her manager in reasonable time. If an employee s right to work lapses he/she may be dismissed by the Trust in these circumstances dismissal procedures will comply with the Trust s Disciplinary Policy. The Asylum and Immigration Act sets the law (and the penalties for non compliance) relating to eligibility to work in the UK checks. Current NHS requirements and advice on these checks are included in the NHS Employers Employment Checks standard on the Right to Work Checks. The Trust will adhere to these standards. Link to NHS Employment Check Standards: http://www.nhsemployers.org/aboutus/publications/documents/right%20to%20work%20che cks.pdf 5.3.3 Professional registration and qualification checks Professional registration and qualifications required for the post (as defined in the person specification for the post) will be checked at interview by the recruiting manager. Original Dartford and Gravesham NHS Trust Page 7 of 14

documentation will be required. Professional registration will also be checked by the HR department prior to the employee commencing employment with the Trust, directly with the relevant professional body in accordance with their recommendation. The checks will normally be undertaken by a check of the website. A member of staff who requires professional registration for his/her post may not start work until registration status is confirmed satisfactorily. All employees will be required to complete a declaration on their application form to confirm whether they are currently under investigation, or have ever been investigated by their professional body. Each case will be considered on its merits and investigation by a professional body may not be a bar to employment at the Trust. Current NHS requirements and advice on these checks are included in the NHS Employers Employment Checks standard on the Registration and qualifications checks. The Trust will adhere to these standards. Link to NHS Employment Check Standards: http://www.nhsemployers.org/aboutus/publications/documents/registration%20and%20qual ification%20checks.pdf 5.3.4 Employment history and reference checks The Trust will verify at least three years of employment/training history. Ideally, this should include a period which covers two separate employers (where possible), one of which should be their current or most recent employer. Where an individual has been with one employer for three years or more, one reference will normally be regarded as sufficient. Recruiting managers must ensure that the employment history of all applicants is examined in detail. This includes ensuring that any gaps in employment are satisfactorily explained and where possible verified during the recruitment selection process. All references received must be satisfactory to the Trust. In all cases references should be requested through the applicant s line manager or other relevant department manager. In addition, where possible, the HR department will check employment dates through the organisation s HR department or other relevant recruitment function. If the applicant is already working within the NHS, Electronic Staff Record Internal Authority Transfer process will be used to verify dates of employment. Note the additional requirements for the following staff groups. For healthcare professionals, references should be obtained from their clinical line manager, medical director, or supervising consultant or, where this is not possible, their postgraduate dean, educational supervisor, or other relevant professional lead. For senior medical appointments and non rotational appointments, Medical Staffing obtain references verifying 3 years of employment/training history and have them verified by the Consultants or appointments committee as relevant. Doctors on rotational training programmes are considered as being in continuous employment throughout the period of their training. As the Deanery undertakes central recruitment they are responsible for obtaining satisfactory references and retaining them centrally. Current NHS requirements and advice on these checks are included in the NHS Employers Employment Checks standard on the Employment History and Reference Checks. The Trust will adhere to these standards. Dartford and Gravesham NHS Trust Page 8 of 14

Link to NHS Employment Check Standards: http://www.nhsemployers.org/aboutus/publications/documents/employment%20history.pdf 5.3.5 Disclosure and Barring Service (DBS) checks Whether a DBS check is required will be determined by the nature of the post. The DBS standards define when checks are appropriate and the level of check that is appropriate. Many posts within the Trust will be covered by the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (as amended) because the employment is concerned with the provision of health services of such a kind as to enable an employee to have access to persons in receipt of such services in the course of their normal duties. If the post holder will work in Regulated Activity with children and/or adults as defined by the Safeguarding Vulnerable Groups Act (amended by the Protection of Freedoms Act 2012) then they will require an Enhanced Disclosure checked against the barred lists(s). Such posts include nurses, midwives, doctors, therapists, healthcare assistants, radiographers, and possibly other ward staff. If the post is not deemed to be a position of Regulated Activity then in accordance with the Protection of Freedoms Act 2012 it may still be appropriate to seek an Enhanced disclosure without barred list information. The Staff Resourcing Manager will use both the NHS Employment Check Standards Criminal Record and Barring Checks document and decision tree tool to inform their decision on when and what type of check shall be sought for each post. The Trust will not seek basic disclosure checks which are only available in Scotland. Where a criminal record is declared the Trust will consider it on its merits and in the context of the post applied refer to the Rehabilitation of Offenders Policy for further information. The conviction will be discussed with the employee by the recruiting manager with advice from HR. If an employee (with a permanent or non permanent Trust employment contract), volunteer or honorary member of staff is charged with or convicted of a criminal offence (this includes Police cautions, but not minor motoring offences such as points penalties unless this could affect their ability to work for the Trust) he/she must declare this to the Director of Human Resources immediately. Each case will be considered on its individual merits. The Trust regards failure to declare a criminal charge or conviction as misconduct, which may lead to disciplinary action up to and including dismissal. The Trust retains the right to request that a further disclosure is sought at any time for any employee in a post that requires a disclosure at whatever level from the DBS. The HR department will also check whether the applicant is listed any current Alert Letter list. Link to NHS Employment Check Standards: http://www.nhsemployers.org/sitecollectiondocuments/criminal_record_checks_dl270209.p df 5.3.6 Occupational health checks A satisfactory occupational health check must be obtained before an employee starts work. Occupational Health checks will be completed by the Trust s Occupational Health department. Where medically appropriate this may involve a meeting with an Occupational Health nurse or physician to complete medical checks or make further assessments. Occupational Health may recommend that a workplace adaptation should be considered for an employee as part of our duty under the Equality Act 2010. In this circumstance the matter will be discussed with the employee by the recruiting manager who should seek Dartford and Gravesham NHS Trust Page 9 of 14

further advice from Occupational Health and/or HR before making a decision on whether reasonable adaptations can be made. Link to NHS Employment Check Standards: http://www.nhsemployers.org/aboutus/publications/documents/occupational%20health%20 checks.pdf 5.4 Following up those who fail to satisfy employment checks If pre-employment checks cannot be completed satisfactorily for whatever reasons the Trust will consider withdrawing an offer of employment. The authority to withdraw an offer of employment rests with the recruiting manager, who must take advice from HR before doing so. If an applicant is unable to provide the information required to complete pre-employment checks the Trust will consider what further checks may be appropriate to verify the applicant is suitable to be employed by the Trust. Each case will be considered on its merits but if the Trust is not able to satisfactorily complete pre-employment checks the offer of employment will be withdrawn. Where an applicant does not co-operate with pre-employment checks processes within a reasonable timescale the Trust may withdraw an offer of employment. Each case will be considered on its merits. Where an offer is being withdrawn this will be clearly communicated to the individual. Where the decision is based on a matter of judgment (e.g. whether a reference is satisfactory or not) a right to request a review of this decision within the Trust is normally offered as part of good practice. False declarations The Trust considers a false declaration made by an employee during the application process to be misconduct. Should an applicant be appointed and it becomes apparent that they had made a false declaration during their application and recruitment process then misconduct will normally be addressed through the Trust s disciplinary processes and could result in action up to and including dismissal. Where appropriate the Trust may also refer a false declaration to Local Counter Fraud Service, registration body or other body. Where appropriate a false declaration made by an applicant to whom the Trust does not offer employment may be referred to Local Counter Fraud Service, his/her registration body, or other body. 5.5 Temporary staff Temporary non-medical flexible workers are provided by NHSP. NHSP are committed to providing safe and reliable flexible workers and have a framework for governance and assurance. Scrutiny of this framework is provided by NHSP s Clinical Governance Committee and by the audit and risk committee, both of which are sub committees of the NHSP Board and chaired by one of their Non-Executive Director. The Trust instructs NHS Professionals to use only NHS procurement framework suppliers for temporary non-medical flexible workers engaged through an agency. This provides assurance to the Trust that preemployment checks are completed by the agency. For medical staff taken through an agency the process will be as follows. If the doctor is appointed via the agency during normal office hours then the locum agency will forward all the documentation to the JDRM who will ensure that the appropriate checks are carried out before confirming the doctor with the agency. Out of hours the agency will send an electronic file of evidence to the Site Manager and the Consultant on call (with a copy to the JDRM). Dartford and Gravesham NHS Trust Page 10 of 14

5.6 Starting work before completion of all checks The Trust will not normally allow a member of staff to start work without completing all checks required for the post. This is the primary control to ensure compliance with this policy. In the most exceptional circumstances, the Director of HR (or nominated deputy) may allow an employee to start work before all checks are completed. This discretion will only be used where the assessed risk of an individual starting is low, where patient safety will be improved by allowing them to start, and when it is legal to do so. A manager requesting in writing that an employee starts without all pre-employment checks must ensure comprehensive supervision arrangements are in place. When an employee is allowed to start work under the above circumstances he/she will be employed on a weekly renewable contract until all pre-employment checks are completed satisfactorily. 5.7 Recording and protecting data The Trust will carry out all checks in compliance with the Data Protection Act 1998. Information should only be obtained where it is essential to the recruitment decision and kept in accordance with the Act. The Trust will record pre-employment checks on Electronic Staff Record (ESR). 6. Assuring the checking process At the end of every quarter an audit will be carried out on the pre employment checks undertaken in the last 3 months for those employed by the Trust. This audit will always be carried out by different colleagues in the HR team than those who did the original checks (for example medical staffing may carry out the audit on files for non medical roles and vice versa). A quarterly audit of pre employment checks for temporary medical staff will be carried out by the Trust medical staffing team. The outcomes of these audits will be reported to the Director of HR (and the relevant General Manager). Assurance of pre employment checks for non-medical temporary staff provided by NHSP will be via a detailed assurance report to the NHSP/Trust quarterly strategic meeting. Procurement will build into their processes an audit (at least annually) of checks on contractors providing services to the Trust. 7. Training and Implementation A training needs analysis has been undertaken for this policy. Mandatory training was provided for managers who recruit and select on behalf of the Trust in January 2013. Further to this: Human Resources will brief managers about this policy through coaching and training as appropriate. Managers may need to approach Human Resources to request this training and coaching as and when particular situations arise such as honorary contracts or contractor organisations/individuals providing services to the Trust. Dartford and Gravesham NHS Trust Page 11 of 14

The Staff Resourcing Manager will brief the Recruitment Assistants so they know their responsibilities. The Medical Staffing Manager will work closely with the Medical Staffing Officer to ensure this policy is correctly applied for medical staff employed by the Trust. Both of these managers will annually appraise their staff members regarding eligibility to work in the UK checks. Human Resources will ensure that our NHSP partners have a copy of this policy Medical Staffing will ensure that the Junior Doctor Rota Managers have a copy of this policy and support them to implement it. The HR Steering Group will note the receipt of reports relating to this policy s implementation. This policy has been disseminated to all staff via the Trust intranet and website. It is the responsibility of the directorate or department to:- Enable staff to access this information. Inform staff any new or newly revised policies disseminated by the Trust 8. Equality Impact Assessment The Trust aims to design and implement services, policies and measures that meet the diverse needs of our service, population and workforce, ensuring that none are placed at a disadvantage over others. In order to meet these requirements, a single equality impact assessment is used to assess all its policies/guidelines and practices. This policy was found to be compliant with this philosophy. The Trust has an Equality of Opportunity in Employment Policy which will be followed. The Trust recognises that it must comply with The Equality Act, 2010. This includes being mindful of the protected characteristics under The Act and avoiding discrimination in recruitment processes. Also seeking to make reasonable adjustments to the process where these are needed, for example by a disabled applicant. 9. Monitoring Compliance with this Policy The HR Steering Group will monitor the adherence to the policy. Any deficiencies in performance identified by the monitoring will be addressed by the use of action plans which will be monitored by the Director of HR What will be monitored Substantive nonmedical staff employed by the Trust How/Method Frequency Lead Reporting to Confirmation that all preemployment checks are undertaken by HR in relation to substantive non-medical staff employed by the Trust. Exceptions and action taken to remedy lapses will be reported. Monthly report Resourcing Manager Director of HR, report also presented to HR Steering Group Implementation of any required change. Required changes will be actioned by named person within specific timeframes. Dartford and Gravesham NHS Trust Page 12 of 14

What will be monitored Temporary non medical staff including agency, bank How/Method Frequency Lead Reporting to Confirmation that all preemployment checks are undertaken in relation to temporary non-medical staff employed by NHS Professionals. Confirmation of checks of agency staff. Exceptions and action taken to remedy lapses will be reported. Monthly report Assistant Director of Human Resources Director of HR, report also presented to HR Steering Group Implementation of any required change. Required changes will be actioned by named person within specific timeframes. Medical staff Confirmation that all preemployment checks are undertaken by HR in relation to permanent and temporary medical staff employed by the Trust as well as those with honorary contracts. Monthly report Medical Staffing Manager Director of HR, report also presented to HR Steering Group Required changes will be actioned by named person within specific timeframes. Professional registration checks by contractor organisations Annual report on compliance with preemployment checks for new staff. Annual Contractors through Facilities Monitoring Manager Director of Human Resources, confirmation will be given through review of Core Standards Declaration Required changes will be actioned by named person within specific timeframes. New Trust employees permitted to start work under supervision The relevant department manager is responsible for ensuring staff who are permitted to start under supervision work within these restrictions Monthly Resourcing Manager Director of HR, report also presented to HR Steering Group Required changes will be actioned by named person within specific timeframes. The Trust will undertake periodic audits of personal files to ensure preemployment checks have been correctly recorded Audit of a random selection of personal files to ensure preemployment checks were completed and recorded accurately. Annual Resourcing Manager Director of Human Resources also presented to HR Steering Group Required changes will be actioned by named person within specific timeframes. 10. Associated Policies and Procedures This policy should be read in accordance with the following Trust policies and documents Trust s Recruitment Standard Rehabilitation of Offenders Policy (located within the Trust CRB/DBS Policy) Professional Registration Checks Policy Disciplinary Policy and Procedure Volunteers Policy This policy should also be read in conjunction with NHS Employers Employment Checks Standards. 11. References NHS Employers (2012) Employment Checks Standards. Dartford and Gravesham NHS Trust Page 13 of 14

Equality Impact Assessment Tool for this Policy To be completed and attached to any procedural document when submitted to the appropriate committee for consideration and approval Policy Name: Pre-employment checks policy Name of Assessors: Andy Brown 1. Does the policy/guidance affect one group less or more favourably than another on the basis of: Race Religion or belief Disability learning disabilities, physical disability, sensory impairment and mental health problems Yes/No/Possible No No Possible Comments (Positive/Negative) Consideration may need to be given to reasonable adaptations for new recruits with a disability Gender No Sexual Orientation No Age No 2. Is there any evidence that some groups No are affected differently? 3. If you have identified potential n/a discrimination, are any exceptions valid, legal and/or justifiable? 4. Is the impact of the policy/guidance No likely to be negative? 5. If so can the impact be avoided? n/a 6. What alternatives are there to achieving n/a the policy/guidance without the impact? 7. Can we reduce the impact by taking different action? n/a If you have identified a potential discriminatory impact of this procedural document, please refer it to the PPI Manager, together with any suggestions as to the action required to avoid/reduce this impact. For advice in respect of answering the above questions, please contact the PPI Manager. Please ensure you consider all of the following legislation when producing your policy: Gender Sex Discrimination Act 1975 Equal Pay Act 1970 Equalities Act 2006 Gender Recognition Act 2004 Race Race Relations Act 1976 Race Relations (Amendment) Act 2000 Disability Disability Discrimination Act 1995 and 2005 Age Age Regulations 2006 Sexual orientation Equalities Act 2006 Relevant employment legislation Religion and beliefs Equalities Act 2006 Relevant employment legislation Additional Comments: Dartford and Gravesham NHS Trust Page 14 of 14