AccessNI Code of Conduct

Rutledge Group uses AccessNI disclosure information solely to help assess an individual's suitability for a position of trust, in line with the eligibility set out in Part V of the Police Act 1997 and AccessNI guidance.

A criminal record will not, of itself, debar a person from employment, training or placement with Rutledge. Every applicant is considered on their individual merits, taking into account the relevance of any conviction to the role applied for. This Code of Conduct sits alongside our Policy on the Recruitment of Ex-Offenders.

Rutledge maintains, and makes available on request, a written policy on the secure storage, handling, use, retention and disposal of Disclosure information. The full policy is published as the AccessNI Policy Statement.

All applicants for an AccessNI check through Rutledge are made aware of the AccessNI Code of Practice, are given a copy on request, and are signposted to the published version on the nidirect website.

Rutledge follows AccessNI's published identity verification process for every disclosure application we countersign. Identity documents are inspected by a trained Rutledge nominee, recorded against the application, and never retained beyond what is required to verify identity.

Rutledge only submits applications for the level of disclosure (Basic, Standard or Enhanced, with or without barred-list checks) that the role is legally eligible for under the Rehabilitation of Offenders (Exceptions) Order (Northern Ireland) 1979 (as amended) and the Safeguarding Vulnerable Groups (NI) Order 2007. Where there is any doubt about eligibility we will seek guidance from AccessNI before submitting an application.

Disclosure information is treated as strictly confidential. It is only passed to those Rutledge officers, employees and authorised persons who are entitled 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.

We recognise that under section 124 of the Police Act 1997 it is a criminal offence to pass Disclosure information to anyone who is not entitled to receive it.

Disclosure information is used only for the specific purpose for which it was requested and for which the applicant's full consent has been given. It is not used for any secondary or unrelated purpose.

Disclosure information is kept securely, in lockable storage with access restricted to authorised personnel only. Electronic records, where retained, are held on access-controlled systems compliant with UK GDPR and the Data Protection Act 2018.

Disclosure information is retained for no longer than six months after a recruitment or other relevant decision has been taken, or after any dispute about the accuracy of a Disclosure has been resolved, save in exceptional circumstances that justify a longer period. Once the retention period has elapsed, Disclosure information is destroyed by secure means (shredding, pulping or burning). Pending destruction, it is never kept in an unsecured receptacle.

Rutledge processes Disclosure information in accordance with the Data Protection Act 2018 and UK GDPR. The lawful basis for processing is the legitimate interest of assessing suitability for a position of trust, together with explicit consent from the applicant. Our Data Protection Officer, Catriona Reid, can be contacted at creid@rutledgegroup.co.uk.

Rutledge co-operates with AccessNI to undertake assurance checks (including scheduled visits, video conference and telephone audits) as to the proper use and safekeeping of Disclosure information.

Rutledge will report promptly to AccessNI any suspected malpractice in relation to this Code, any suspected offence concerning the handling or storage of Disclosure information, and any data breach affecting Disclosure information in line with our obligations to the Information Commissioner's Office (ICO).

This Code of Conduct is owned by the Rutledge HR Manager, who has overall responsibility for implementation and monitoring. It is reviewed at least annually, and additionally whenever there are relevant changes in legislation, AccessNI guidance or our working practices.

Reference: the full AccessNI Code of Practice (PDF) is published on nidirect.gov.uk.

Any queries or comments about this Code of Conduct should be addressed to the HR Manager or to the Data Protection Officer, Catriona Reid (creid@rutledgegroup.co.uk).