DBS and Police Checks

An enhanced Disclosure and Barring Service (DBS) check is required on entry to Medical School for all students who been resident in the UK since the age of 13.

Degree programmes that lead to the award of a professional qualification have a duty to the public to ensure that students seeking to enrol and students who are enrolled meet the relevant standards of professional conduct. In the case of medical students, the General Medical Council (GMC) provides guidance to Medical Schools and their students on Professionalism and Fitness to Practice in their publication  Achieving Good Medical Practice:

Students applying for and entering the MBBS programme are required to disclose to the Medical School any spent or unspent convictions, cautions or fixed penalty notices (FPN) including Penalty Notices for Disorder (PND)*. DBS clearance is an NHS requirement for students to take clinical placements. 

An enhanced Disclosure and Barring Service (DBS) check is required on entry to Medical School for all students who been resident in the UK since the age of 13. This DBS check will state any criminal convictions you hold and, if appropriate, whether you are barred from working with children or vulnerable adults. International students are required to submit an equivalent police check from the relevant authorities in their home country as part of the admissions process. Individual students must then disclose any convictions, cautions and FPNs received during the course to the Medical School, and all students are required to make a declaration of their DBS status prior to entering Year 4. 

The “Medical Student Code of Conduct” notified to you with your offer to study medicine at UCL and published on the MBBS current student website includes an undertaking to disclose “any matters relevant to fitness to practice on entry and for the duration of enrolment on the MBBS course”. Non-disclosure of criminal records is a fitness to practice issue under this code. Criminal records must be also then declared to the GMC and their Foundation School during their final year of the programme and subsequently to future employers. Students are advised that while there are no “spent” cautions or convictions with respect to Medicine, there are some FPN’s, “protected” cautions and convictions which do not need to be declared to the GMC. 
 

UCL’s guidance on Disclosure and Barring Service requirements and applications can be found here:

UCL has an obligation to refer students to the Disclosure and Barring Service if it thinks a student:

  • has harmed or poses a risk of harm to a child or vulnerable adult
  • has satisfied the harm test; or
  • has received a caution or conviction for a relevant offence and;
  • the person they’re referring is, has or might in future be working in regulated activity and;
  • the DBS may consider it appropriate for the person to be added to a barred list

Admissions Policy and Procedures

The Medical School does not wish to prevent individuals with criminal records or FPNs being considered for a place at UCL, however the School has a legal obligation to consider its responsibilities to the public, to its students and to the regulatory bodies when considering applications from students who may hold a criminal conviction.

UCL expects students applying for A100 Medicine course at UCL to declare any spent and unspent convictions that would appear on an enhanced criminal record check, in the appropriate space on their UCAS application. Students who have ticked the UCAS declaration will be contacted by the UCL Medical Admissions team and will be asked to provide further information in confidence.  

Any relevant criminal convictions declared will be investigated as per UCL’s Academic Manual Chapter 1 Annex 1.4 and an Assessment Panel will consider the case.

All other declarations which do not fall within the wider UCL criminal conviction policy will be initially reviewed and investigated by the Medical School Divisional Tutor, who is responsible for Fitness to Practice referrals. The decision reached will take into consideration the seriousness, frequency and pattern of offences as well as the implications of any lack of appropriate judgement on a future medical career. The Divisional Tutor may request additional information from the candidate, and where appropriate they may also request permission to contact a third party, such as a probation officer or social worker who can provide further information. Additionally the Divisional Tutor may seek specialist advice if required. 

The outcome of this investigation will be communicated to the applicant and will either be:

  • Continuation of the medical school selection process without prejudice. Should this decision be reached, the candidates will be made aware that should their application be successful, they may be subject to an Initial Fitness to Practice Panel hearing on entry to the medical programme. UCL’s Fitness to Practise Procedure can be found here:
  • A recommendation is made to Student and Registry Services that the application for admission to the MBBS/BSc programme be rejected. Appeals are referred to the Director of Access and Admissions for consideration by the UCL Criminal Conviction Panel.

Please be aware that should an applicant not declare a conviction during the admissions process that comes to light prior to, or following enrolment then an offer of admission may be withdrawn, or a student’s registration may be terminated.

Enrolment Checks

Students who firmly accept our offer of a place to study at UCL Medical School will be provided with detailed information about this online process, by the Admissions Team, once their place has been confirmed as unconditional. The cost of the DBS check will be met by the Medical School apart from a small fee charged by the post office for an ID check. 

On receipt of their certificate, students must present this to the Medical School Records Manager who will make a note of the DBS certificate number in the Medical Student Academic Record (ASR). This process must be completed by 31st October at the latest, prior to your first patient contact. 

Please note that:

  • The Medical School does not receive a copy of the certificate and it is imperative that students retain their certificates carefully for the rest of the course as medical students may be required to show their certificate later in the programme, for example when taking up clinical placements and applying for electives in countries such as Australia and the USA. 
  • Some clinical providers require a recent DBS check and we strongly advise you to subscribe to the DBS online update service which allows you to check your application online and to give permission to future employers or institutions to view your certificate. 
  • Please be aware that if you lose your certificate, or need a new DBS check, you will need to meet the costs yourself. Should you only require your reference number, the Medical School Records Manager can provide this for you.
  • Once students have joined the course, any queries about your DBS disclosure should be directed to the Medical School Records Manager, who are responsible for managing and monitoring DBS records under the direction of the Divisional Tutor as part of the Medical School’s Fitness to Practise procedures.
  • UCL’s guidance about DBS applications and processes may be found at:

Self-declaration prior to entering Year 4

Students will be prompted by the Student Support Team to make a declaration of their DBS status prior to entering Year 4. Students who fail to submit a declaration may not attend any events in NHS spaces or involving patients during the Introduction and Orientation Module and may not take up a clinical placement. Failure to disclose convictions, cautions or FPNs is a Fitness to Practise issue.

Transfer entries and returning to MBBS programme

  • Students transferring into year 4 to join the MBPhD programme are required to undergo an enhanced DBS check prior to acceptance on the MBBS course. Information about how to do this will be included in your offer letter.
  • Students who have been out of attendance from the MBBS programme for 3 years or more are required to have a new DBS check on re-enrolment. These students will need to follow UCL’s process set out here:
  • On receipt of their certificate, students must present this to the Medical School Records Manager who will record the DBS certificate number in the Medical Student Academic Record (ASR).

Fitness to Practise 

•    Cautions /Convictions/Fixed Penalty Notices including Penalty Notices for Disorder (PND)

Students with any of the above offences are referred automatically to the Medical School’s Initial Fitness to Practise Panel to decide whether the student should be referred to the School of Life and Medical Sciences’ Full Fitness to Practise Panel. The Initial Fitness to Practise Panel is serviced by the Head of Medical Student Support and Records and conducted by two Academic Leads drawn from:    

  • Director of UCL Medical School
  • MBBS Academic Leads
  • (or a delegate drawn from members of the Student Support Committee)

Where, after referral to Initial or full FtP proceedings, students are permitted to continue with the course, the UCLMS Initial FtP Panel will decide whether there is a requirement for the student to re-apply for enhanced disclosure on entry to Year 4 or 12 months after permission to continue with the programme is granted.  

Students with offences on their record are advised that they are less likely to secure electives in some countries, in particular, for example, the USA or Australia.

•    Offences against a third party

Any student with an FPN and/or caution and/or conviction for an offence against a third party that may put a patient at risk is automatically referred to the UCLMS Fitness to Practise Panel. 

•    Warning re subsequent offences

If there is a subsequent offence, or if a student’s integrity is questioned again at any stage in the course, an automatic referral will be generated to the SLMS Fitness to Practise Panel.   

•    Failure to declare convictions and/or cautions and/or FPNs

If the School becomes aware that a student has failed to declare convictions and/or cautions and/or FPNs during the course, the student is referred automatically to the full SLMS Fitness to Practise Panel.  

It is important for medical students to be aware that any criminal record (including police cautions) remain on their record and must be disclosed throughout their working life. For health professionals they do not ‘disappear’. Even if they have been deleted from records they should still be declared. Hence in cases where students are not at fault they should not accept a police caution as a ‘quick solution’. It has been suggested that the police themselves may not be aware of the differences in regulations for health care professionals and could give the wrong advice.

Disclosure to Educational Supervisors

The Medical School has an obligation to ensure that clinical placement providers and staff who are supervising MBBS students are aware of concerns relating to fitness to practise issues which might pose a risk to patient safety.  In accordance with UCL’s Fitness to Practise Policy, and within the provisions of the Data Protection Act 2018, placement providers will be notified on a case-by-case basis and students will be informed of any such decision(s):

  1. At the discretion of the Divisional Tutor, potential fitness to practise issues will be disclosed immediately to the Module Lead or GP Tutor or DGH UG Tutor who is responsible for supervising a student’s current attachment.  
  2. The Initial Fitness to Practise Panel will determine, as part of their investigations and recommendations, whether and to whom fitness to practise issues will be disclosed.  
  3. Referrals to UCL’s Fitness to Practise Panel will be disclosed to Module Leads and/or GP Tutors and/or DGH UG Tutors responsible for supervising attachments, who will be informed that Fitness to Practise proceedings have been instigated.

GMC Registration and Transfer of Information to Foundations Schools 

All students in their final year are asked to disclose criminal record information to the GMC as part of their application for provisional registration and are also required to participate in the national Supporting Trainees  Entering Practice (STEP) to Foundation Schools. This is a means both of supporting students as they move from Medical to Foundation School and also ensuring that information that relates to patient safety is available to a nominated person in each Trust (e.g. the clinical tutor). Hence it is appropriate to declare all ongoing significant health issues and repeated examination retakes. Students have ownership of the information they wish to disclose but are obliged to comply with GMC rules and provide information that may affect their ability to treat patients safely. 
    
Students with positive DBS records are required to discuss their GMC and STEP declarations with the Divisional or Deputy Divisional Tutor to ensure that appropriate information is provided. 

GMC guidance for final year medical students can be found at:

* Fixed Penalty Notices, including the Penalty Notices for Disorder (PND) scheme, are a means of dealing with low-level, anti-social and nuisance offending, which does not require a court hearing.  Fixed Penalty Notices for minor motoring offences such as parking and speeding need not be declared.