By Jack Mellor, CEO, Personnel Checks
Work experience could soon become a much more familiar feature of workplaces. Under the Government’s Work Experience Guarantee, schools in England are being asked to work towards ensuring every pupil receives two weeks of meaningful work experience during secondary education. That includes a week’s worth of workplace activities during years 7 to 9 and a further week of work placements in years 10 to 11.
There is an opportunity for employers to inspire young people to explore different careers, build confidence and create connections. But if a business moves from hosting an occasional student to welcoming young people regularly, it needs to know exactly who is responsible for them.
Contact and responsibility are not the same
A pupil spending a week inside a business could meet dozens of employees. That does not mean everyone they encounter suddenly requires a DBS check. What matters is the activity an individual carries out, rather than proximity alone.
For somebody under 16, teaching, training, instructing, caring for or supervising them can amount to regulated activity with children when the relevant conditions are met. For these activities, current DBS guidance includes a frequency threshold of more than three days in a 30-day period, or certain overnight contact. Employers must assess the full eligibility criteria rather than using frequency alone.
Map the placement before deciding on checks
Establish the pupil’s age, where they will be based, what they will do each day and which members of staff will have responsibility for them. Agree the checking arrangements with the school or college organising the placement.
An employee responsible for teaching and supervising a 15-year-old throughout a working week may be undertaking regulated activity. That requires an assessment of the role and applicable safeguarding arrangements; it is not a reason to request the same check for every colleague who briefly meets the pupil.
“Screening decisions need to follow the design of the placement, rather than the other way around.”
Jack Mellor, CEO, Personnel Checks
Age and the September rule change matter
Where a 16- or 17-year-old is in paid or unpaid employment, teaching, training or supervising them in connection with that employment does not by itself constitute regulated activity with children. Similar-looking placements can therefore lead to different eligibility decisions.
On 1 September 2026, the supervision exemption for regulated activity with children was removed. An individual carrying out qualifying activities frequently enough may now be undertaking regulated activity even when supervised. DBS explains that the change does not create a blanket legal requirement for checks. The role, eligibility rules and applicable safeguarding requirements still need to be considered.
Five questions before a placement starts
- How old is the young person? Age can affect the assessment.
- What will they do? Set out actual activities, rather than simply writing “shadowing”.
- Who is responsible? Identify the people who will teach, train, instruct, care for or supervise them.
- How often will that happen? Record the planned pattern of contact.
- Is the proposed check available for this role? Establish eligibility before requesting a Standard or Enhanced disclosure.
Build placements into early talent planning
Recruitment and HR teams can help give placements clear ownership, brief managers and make screening decisions consistent across departments. Work experience can introduce young people to careers they had not considered and help employers build relationships before a first job application.
The starting point is understanding who will be responsible for the young person, what they will do together and whether those circumstances create eligibility for a check. Getting those foundations right gives employers a stronger basis for offering placements safely and confidently.
This contributed article has been edited for length and clarity. Current DBS guidance is linked above.
Image: Jack Mellor, supplied by Personnel Checks.
