Vetting and Screening Policy

Capita plc Policy
Vetting and Screening
CAPITA PLC POLICY

VETTING AND SCREENING
Version: 11.0
Date of Issue: December 2014
Page 1 of 22 COMMERCIAL IN CONFIDENCE © 2014 Capita plc

Date of Issue: Dec 2014
Capita plc Policy
TABLE OF CONTENTS
1 POLICY ........................................................................................................................................... 3
1.1 POLICY STATEMENT ............................................................................................................. 3
1.2 PURPOSE ............................................................................................................................... 3
1.3 SCOPE .................................................................................................................................... 4
1.4 RECRUITING MANAGERS’ RESPONSIBILITIES .................................................................. 4
1.5 BRITISH ISLES CHECKS ............................................................................................................ 6
1.6 EUROPE, THE MIDDLE EAST AND AFRICA (EMEA) CHECKS ............................................ 7
1.7 ASIA PACIFIC (ASIA-PAC)) CHECKS .................................................................................... 9
1.8 OVERVIEW OF MEANING OF CHECKS .............................................................................. 11
1.9 CAPITA EMPLOYEES ........................................................................................................... 15
1.10 TEMPORARY WORKERS .................................................................................................... 15
1.11 CONTRACTORS ................................................................................................................... 16
1.12 SUPERVISION OF WORKERS ............................................................................................. 17
1.13 CONTACTS ........................................................................................................................... 17
2 APPENDICES............................................................................................................................... 19
2.1 GLOSSARY ........................................................................................................................... 19
2.2 ADDITIONAL UK INFORMATION ......................................................................................... 20
2.3 RELATED INFORMATION AND DOCUMENTS ................................................................... 21
2.4 DOCUMENT HISTORY ......................................................................................................... 21

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1 POLICY
1.1 POLICY STATEMENT
1.1.1 Capita’s Policy is to have a robust vetting and screening process for all Workers
entering our Businesses, to maintain the integrity of our operational environment,
to protect the Capita Businesses and our client’s assets, and where required to fulfil
our regulatory responsibilities.
1.1.2 Capita considers that Temporary workers and Contractors should be subject to
the same level of vetting and screening procedures as Capita employees.
1.1.3 Non-compliance with this Policy may result in disciplinary proceedings against the
recruiting manager, which may also include their manager(s).
1.1.4 This Policy is at least equivalent to the UK Government’s Baseline Personnel
Security Standard (BPSS).
1.1.5 A number of words and phrases in this Policy have particular meanings as set out
in the glossary. Defined terms are capitalised and appear in bold when first used in
the Policy. When reading this Policy, recruiting managers should refer to the
glossary.
1.1.6 Further vetting and screening information is also provided in the Managers’ Guide
to Employment Practices (MGEP) > Starting > Recruitment and Selection > Pre
Employment Checks.
1.2 PURPOSE
1.2.1 The purpose of this Policy is to define the minimum Worker vetting and screening
requirements, which are an integral part of the recruitment process to be followed
within the Capita plc group of companies (Capita).
1.2.2 This Policy supersedes all previous policies regarding vetting and screening
requirements.
1.2.3 The rationale for the vetting and screening of Workers is driven by the need:
 to prevent unsuitable people from having access to employment positions that
provide opportunities to harm children or adults considered to be vulnerable;
 to ascertain if an individual has been cautioned or convicted of a fraud related
offence or an offence which would impact directly on their suitability for the role
they are employed to carry out;
 to fulfil client contractual obligations;
 to protect Capita and client data;
 to safeguard the brand and reputation of Capita and its clients; and
 for UK Financial Services Regulated Businesses to satisfy themselves of the
suitability of anyone who acts for them (including assessing an individual’s
honesty and competence). Similar regulatory requirements exist in a number of
other jurisdictions in which Capita operates.

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1.3 SCOPE
1.3.1 This Policy applies to Capita Businesses globally which recruit Workers. Whilst this
Policy includes some UK references which are not directly relevant to other
jurisdictions, the Policy and its principles must be followed by Businesses in all
jurisdictions, subject to similar vetting and screening checks being available and
within the limits of local law.
1.3.2 This Policy applies to all managers involved in the recruitment of Workers.
1.3.3 The recruitment of Workers includes the following types of engagements:
 Workers recruited as employees on Capita contracts
 Workers recruited to work for Capita on a temporary basis
 Workers engaged to work for Capita on a limited company contract
 Workers who join Capita through Business acquisition or transfer
1.3.4 The Third Party Management Information Security Standard specifies the vetting
requirements for Third Party staff.
1.3.5 This policy must be considered where any other individuals have access to Capita
buildings, equipment, systems or data, so a risk based approach can be taken. The
approach must be agreed by an appropriate governance forum and the decision
must be documented.
1.3.6 This policy confirms what checks must be repeated and the frequency of those
checks.
1.4 RECRUITING MANAGERS’ RESPONSIBILITIES

1.4.1 Recruiting managers must read all relevant sections of this Policy and if any
requirements are unclear they must seek guidance from one of the contacts named
in the Policy.
1.4.2 The recruiting manager must ensure all Workers are recruited via the designated
channel so the checks required by the policy are completed.
1.4.3 The recruiting manager has overall responsibility for ensuring the minimum vetting
and screening checks required by this Policy are completed.
1.4.4 In order for vetting and screening decisions to be notified by Security Watchdog
(SW) to UK recruiting managers, managers must confirm the following role/risk
related information via the Request For Offer (RFO) process:
 Will the role have access to financial/payment data?
 Will the role have access to personal and sensitive data?
 Will the role have ‘privileged’ or ‘super user’ IT access?
 Will the role involve driving?
1.4.5 A decision to proceed with or withdraw the offer of employment is made based on
the criteria listed in 1.4.4 and the results of checks such as financial probity and
criminal records. In the event an individual receives a ‘rejected’ decision, they have
the right to appeal against the decision; information is provided here: MGEP >
Starting > Recruitment and Selection > Pre Employment Checks.

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1.4.6 Where a potential vetting and screening issue is identified before an individual has
started work, e.g. a financial probity or criminal record issue is declared by an
individual as part of the recruitment process, the individual must not be allowed to
start work until a vetting and screening decision has been made.
1.4.7 If the recruiting manager allows an individual to start work before completion of all
the required vetting and screening checks, and the vetting and screening decision
is not to proceed with the employment, the manager must promptly terminate the
employment and complete the leaver process on CAPITA Desktop.
1.4.8 Evidence to confirm the checks have been satisfactorily completed must be
obtained, e.g. identity documentation, previous employment details. Documentation
must be verified and details input onto Capita Desktop, via the RFO process.
Copies of documents for Capita employees will be held confidentially and centrally
via HR Administration and will be subject to audit. Businesses must establish
procedures and resources to implement this Policy, including ensuring
confidentiality of financial probity or criminal records information (in accordance with
relevant requirements e.g. the DBS Code of Practice, the UK Data Protection Act
1998 and the EU Data Directive 95/46 EC), monitoring that checks have been
carried out and establishing an appropriate escalation procedure.
1.4.9 In addition to the minimum checks required by this Policy, Business Managing
Directors (MDs) must consider what other checks may need to be carried out within
their operations and throughout their supply chain (both internal and external) in
order to fulfil contractual and non-contractual obligations. Consideration should be
given to the data being handled (such as financial information), any contact with
higher risk individuals (such as children or adults under safeguarding obligations) or
specific processes that require higher levels of vetting and screening for regulatory
and statutory requirements (such as medical Workers or security cleared
personnel). The recruiting manager is responsible for ensuring appropriate
additional checks determined by the Business MD as required for that Business
operation or described in this Policy are completed.
1.4.10 Workers who join Capita through Business acquisition or transfer must have their
previously conducted vetting and screening checks assessed to ensure any legally
or contractually1 required checks for their role have been completed, and to identify
the required frequency for repeat checks so procedures can be put in place by the
Business. As part of the due diligence and integration process the Business must
also compare the vetting arrangements which were in place for acquired and
transferring staff with the requirements of this policy and address gaps or document
risk acceptance and confirm the additional controls put in place if appropriate. If the
acquisition or transfer involves a jurisdiction not covered in this Policy, there must
be consultation with Group HR, SW and Group Risk & Compliance so this Policy
can be updated.
1
Contract of employment or client contract

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1.5 BRITISH ISLES CHECKS

1.5.1 The table below sets out the minimum vetting and screening checks which are required by this Policy. Guidance notes which describe
the checks are provided later in the Policy, together with further information relating to Capita employees, Temporary workers and
Contractors. Recruiting managers must ensure they read all relevant sections of this Policy. All applicants are required to provide
relevant information and to give consent for Capita to proceed with the checks. Further information is provided in the Managers’ Guide to
Employment Practices (MGEP), accessed via the ‘My team’ section of Capita Desktop: Starting > Recruitment and Selection > Pre
Employment Checks.
CHECK TYPE
Financial probity (must
Criminal records (must
Adverse media (where

must be completed for
criminal convictions &
Signed confidentiality
be repeated annually
authorisation to carry
Contractor’s contract
reg outside of British
Eligibility To Work in
be repeated every 3
Membership (where
Employment history
Sanctions (must be
legally required for

repeated annually;
Declaration of no
Limited company
Insurance cover
relevant to role)
Right To Work/
years for reg)
Qualification/
References/
out checks
agreement
Address
role) ***
Identity
N.I. no.
for reg)
WORKER BUSINESS
Isles)
TYPE TYPE
UK
Capita Non-Reg H H H H S H S S S H
employee
Reg H H H H S H S S S S S S
Temporary Non-Reg C C C C C C  C**  C** C C C

worker
Reg C C C C C C C C C C C C
Contractor Non-Reg C C C S C C  S*  S*  S* S C C S C C
Reg C C C S C C S S S S C C S C C
 ‘H’ indicates check completed by HR Admin  ‘S’ indicates check completed by SW  ‘C’ indicates check completed by CIR or designated CIR supplier
* Planned roll-out by March 2015
** Planned roll-out by June 2015

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*** Non-Financial Services Regulated Businesses may require check to meet contractual requirement or in consideration of data being used (e.g.
financial information), any contact with higher risk individuals (e.g. children or adults under safeguarding obligations) or specific processes that
require higher levels of vetting for regulatory and statutory requirements (e.g. medical Workers)
The recruiting manager has overall responsibility for ensuring all the required checks are completed, including for any direct engagements or for
those engagements not fulfilled via the designated channel.
1.6 EUROPE, THE MIDDLE EAST AND AFRICA (EMEA) CHECKS

1.6.1 The table in this section sets out the vetting and screening checks which are commonly undertaken during recruitment, although this
varies across jurisdictions. A indicates the check is allowable under local law and is available via a known checking mechanism.
Shading indicates the check is required by this Policy. Guidance regarding any known restrictions and cultural considerations is
available from SW. The Centre for the Protection of National Infrastructure also provides advice on obtaining criminal record checks
overseas. The recruiting manager has responsibility for ensuring all the required checks are completed. If recruitment involves a
jurisdiction not covered in this Policy, there must be consultation with Group HR, SW and Group Risk & Compliance so this Policy can
be updated.
CHECK TYPE
Qualification/
References/
Highest Membership Financial Criminal Adverse
EMEA COUNTRY Identity Address Employment Directorship
education where relevant probity records media
history
to role
Current
Bulgaria
address only
Denmark
Equatorial Guinea

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CHECK TYPE
Qualification/
References/
history
to role
Current
France
address only
Germany
Gibraltar
Hungary
Ireland (Republic of)
Kenya
Luxembourg
Netherlands
Nigeria
Poland
Not
membership
Current
South Africa
address only

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CHECK TYPE
Qualification/
References/
history
to role
Switzerland
UAE
1.7 ASIA PACIFIC (ASIA-PAC)) CHECKS

1.7.1 The table in this section sets out the vetting and screening checks which are commonly undertaken during recruitment, although this
varies across jurisdictions. A indicates the check is allowable under local law and is available via a known checking mechanism.
Shading indicates the check is required by this Policy. Guidance regarding any known restrictions and cultural considerations is
available from SW. The Centre for the Protection of National Infrastructure also provides advice on obtaining criminal record checks
overseas. The recruiting manager has responsibility for ensuring all the required checks are completed. If recruitment involves a
jurisdiction not covered in this Policy, there must be consultation with Group HR, SW and Group Risk & Compliance so this Policy can
be updated.
CHECK TYPE
Qualification/
References/
ASIA-PAC COUNTRY Highest Membership
Identity Employment Financial probity Criminal records Directorship Adverse media
education where relevant
history
to role
Australia
Canada

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CHECK TYPE
Qualification/
References/
ASIA-PAC COUNTRY Highest Membership
Identity Employment Financial probity Criminal records Directorship Adverse media
education where relevant
history
to role
Hong Kong
Capita employees,
Reference
Contractors & Temporary
Workers (‘non-SLA’) checks are
India dependent on
role band
Temporary Workers (‘SLA’)
Singapore
USA

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1.8 OVERVIEW OF MEANING OF CHECKS

CHECK TYPE DESCRIPTION OF CHECK
An overview of the check required by this Policy is provided
below. Further details are provided in the Managers’ Guide to
Employment Practices (MGEP), accessed via the ‘My team’
section of Capita Desktop: Starting > Recruitment and Selection
> Pre Employment Checks.
Identity Proof of identity must be provided. In the UK the following are
acceptable:
 Valid passport (any nationality)

 UK driving licence - paper or photocard if accompanied by
paper counterpart
 Original UK full birth certificate
 Valid photo identity card (EU countries only)
 UK firearms licence
 HM forces ID Card (UK)
 Adoption Certificate (UK)
Right To Work/Eligibility Right To Work (RTW) or Eligibility To Work (ETW) in the UK and
To Work in UK any visa expiry date must be checked. Managers must refer to
the ‘Prevention of Illegal Work’ section of the Managers’ Guide to
Employment Practices (MGEP) which specifies the required
documentation. Should Managers want to employ migrants, they
must follow the procedures outlined in the Managers’ Guide.
Should this be for Temporary workers or Contractors, they should
seek advice from CIR.
Visa information is flagged at RFO level within Capita Desktop.
Recruiting managers are required to send Visa information
alongside ID documentation when the new Worker starts
employment with Capita to HR Administration. Capita Desktop
does not have the functionality to monitor visa expiry dates,
therefore it is the responsibility of the recruiting manager to
monitor expiry dates at a local level and action accordingly.
Security Watchdog can offer professional immigration advice.
Address Proof of address must be provided. In the UK the following are
acceptable:
 Bank/credit card/building society/mail order catalogue
statement
 Utility bill – electricity/gas/water/telephone
 Addressed payslip
 A document from UK central/local government/government
agency/local authority giving entitlement
[Disclosure Scotland and the Disclosure and Barring Service
generally require evidence of address for a criminal records
check which has been issued within the last 3 months, but in
some cases 12 months is an acceptable timeframe; further
details are available from Security Watchdog]
N.I. no. Proof of permanent National Insurance number must be
provided. In the UK the following are acceptable: P45, P60,

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national insurance card, or a letter from a Government agency.

Declaration of no criminal This is fulfilled either by the candidate’s completion of an
convictions and application form or via completion of a declaration of consent to
authorisation to carry out vetting and screening checks form.
checks
Signed confidentiality This is achieved as follows:
agreement  Capita employee: via a signed Capita contract of employment
 Temporary worker: via a confidentiality agreement
 Contractor: via a business to business agreement
Financial probity In the UK these Financial Services Regulated
checks can be These checks are repeated annually.
completed within 24 Non-Financial Services Regulated
hours.
A financial probity These checks are not routinely repeated,
check is a check of but a Business might decide it is
publicly available appropriate to repeat them based on the
financial information nature of the role.
for an individual using
their current address
e.g. County Court
Judgments, and is
done via a consumer
database.
Sanctions Financial Services Regulated
Individuals are checked against HMT’s consolidated financial
sanctions list.
These checks are repeated annually.
Criminal records This check can Financial Services Regulated
usually be completed Disclosure and Barring Service (DBS): A
within 2 weeks by the standard disclosure is obtained for UK
UK Disclosure and Approved Persons and their line
Barring Services. managers (i.e. those to whom an
Disclosure Scotland Approved Person directly reports). This
has a turnaround time check is repeated every three years.
of 14 calendar days DBS is an executive non-departmental
(if the e-bulk system public body of the UK Home Office.
is used). Equivalent bodies are used outside of
The policy on the the UK.
recruitment of ex- Disclosure Scotland (DS): A basic
offenders should be disclosure is obtained for all roles except
made available to all UK Approved Persons. This check is
applicants on request. repeated every three years. DS is an
Unless the nature of Executive Agency of the Scottish
the position allows us Government operating on behalf of
to ask questions Scottish Ministers.
about the applicant’s Equivalent bodies are used outside of
entire criminal record, the UK.
we only seek These checks are repeated every 3
information regarding years.
“unspent” convictions
as defined in the

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Rehabilitation of
Offenders Act 1974.
Disclosure Scotland Non-Financial Services Regulated
has a turnaround time Disclosure Scotland (DS): A basic
of 14 calendar days. disclosure is obtained for all roles. The
check is not routinely repeated, but a
Business might decide it is appropriate
to repeat it based on the nature of the
role. DS is an Executive Agency of the
Scottish Government operating on behalf
of Scottish Ministers.
Equivalent bodies are used outside of
the UK.
These checks are not routinely repeated,
but a Business might decide it is
appropriate to repeat them based on the
nature of the role.
Qualification/Membership Where legally required for the role, a qualification or membership
(where legally required of a professional body must be verified. This is achieved directly
for the role) with the issuing authority or by the provision of relevant
documentation e.g. certificates or statements.
References/Employment References must be provided; the recruiting manager (via the
history RFO process) should indicate the type of reference to be sought
- employment, educational/academic or personal. Personal
references must be signed (where not provided electronically)
and provided by an unrelated person living at a different address
to the candidate. References must be provided, regardless of the
individual’s status or any existing relationship with Capita etc.
Where relevant, employment history must be confirmed.
Capita employee non- Capita employee Financial
Financial Services Services Regulated
Regulated UK Approved Persons require 5
3 years employment history, years employment referencing,
supported by at least 2 with a minimum of 3 separate
references (one from the references provided (with one
last employer). An from the last employer) An
explanation of gaps of more explanation of gaps of more than
than 3 months is required, 3 months is required, with
with evidence provided such evidence provided such as a
as a passport showing passport showing travel.
travel. Any gaps may be All other Capita employees require
covered with a personal 3 years employment referencing,
reference. with a minimum of 3 separate
references provided (with one
from the last employer) An
explanation of gaps of more than
3 months is required, with
evidence provided such as a
passport showing travel.
Temporary worker non- Temporary worker Financial
Financial Services Services Regulated
Regulated 3 years employment referencing,

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2 years employment history, with the exception of UK Approved

supported by at least 3 Persons who require 5 years, with
references (with one from a minimum of 3 separate
the last employer). An references provided (with one
explanation of gaps of more from the last employer). An
than 3 months is required, explanation of gaps of more than
with evidence provided such 3 months is required, with
as a passport showing evidence provided such as a
travel. There should also be passport showing travel. If the
a check for previous Temporary worker has been in the
engagement within any same assignment for 3 years or
Capita Businesses within more, 1 employment reference
the previous 12 weeks to and 1 personal reference is
ensure compliance with required.
‘Agency Worker
Regulations’ and relevant
qualifying periods.
Contractor non-Financial Contractor Financial Services
Services Regulated Regulated
Minimum of 2 separate 3 years employment referencing,
references covering the last with the exception of UK Approved
2 years. Any gaps may be Persons who require 5 years, with
covered with a personal a minimum of 3 separate
reference or an explanation references provided (with one
of gaps. from the last employer). An
explanation of gaps is required.
For Contractors who have been in
the same assignment for 3 years
or more, 1 employment reference
and 1 personal reference will be
required.
Insurance cover
Contractors: It should be noted that Capita’s corporate insurance
programmes do not cover Contractors and therefore Contractors
must have their own appropriate cover. The Capita Internal
Resourcing managed service ensures all Contractors
administered by them have the minimum cover as follows:
 proof of Employers’ Liability insurance cover – minimum up to
£5 million (consideration should be given to obtaining higher
levels of cover for higher risk activities)
 proof of Professional Indemnity insurance cover – minimum
up to £1 million (consideration should be given to obtaining
higher levels of cover for higher risk activities)
 proof of Public Liability insurance cover – minimum up to £1
million (consideration should be given to obtaining higher
levels of cover for higher risk activities)
 proof of appropriate travel insurance including medical cover,
if the Contractor is to travel overseas on Capita Business –
minimum up to £2 million (consideration should be given to
obtaining higher levels of cover for visits to high risk
countries)
Adverse media (where Where relevant to the role and as authorised by the Business

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relevant to role) MD a check will be completed. In high risk/profile contracts, an

external service should be used, not just an internet search
Contractor’s contract A Capita standard or compliant contract is required for all
Contractors. Where CIR is used, a compliant contract will be put
in place
Limited company Limited company checks (name, registered address, registered
number, and VAT number) are required.
Highest education In some circumstances it might be appropriate to verify an
individual’s education. This is achieved by the provision of
relevant documentation, e.g. certificates, a letter from the
relevant establishment confirming attendance.
Directorship A statement of declaration or independent check of current and
past directorships, which might reveal any potential conflicts of
interest as a result of relationships with other companies.
1.9 CAPITA EMPLOYEES

1.9.1 The following checks must be completed before the individual starts work:
 Identity [This must be reconfirmed by the recruiting manager on the first day of
employment]
 Right To Work/Eligibility To Work in UK [This must be reconfirmed by the
recruiting manager on the first day of employment]
 Signed declaration of no criminal convictions and authorisation to carry out
checks
 Signed confidentiality agreement
 Financial probity
1.9.2 A criminal records check must be completed as soon as possible but always within
one month of the employee starting work. This check is triggered by the RFO
process; once the RFO has been approved, SW contacts the individual to start the
required check.
1.9.3 All remaining checks required by this Policy must be completed for employees prior
to completion of their probation period.
1.10 TEMPORARY WORKERS

 Identity
recruiting manager on the first day of work]
checks
 Financial probity (with effect from January 2015 for non-Financial Services
Regulated Businesses)

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one month of the individual starting work (with effect from January 2015 for non-
Financial Services Regulated Businesses).
1.10.3 Given the time required to complete a criminal records check, this check can be
waived for Temporary workers engaged for periods of 10 days or less, but this is
the only exception to the checks required by this Policy.
1.10.4 All remaining checks required by this Policy must be completed for temporary
workers in a timely manner.
1.10.5 If there is a gap in engagement where the Temporary worker works on an
assignment outside of Capita for a period of 4 weeks or more, the checks required
by this Policy must be repeated as part of the re-engagement process.
1.11 CONTRACTORS
1.11.1 A Capita contract will not be issued until the checks required by this Policy have
been completed. Failure to complete the checks required by this Policy may result
in Capita being liable for significant fines imposed by HMRC.
 Identity [This must be reconfirmed by the recruiting manager on the first day of
work]
recruiting manager on the first day of work]
checks
 Financial probity
one month of the individual starting work.
1.11.4 All remaining checks required by this Policy must be completed for contractors in a
timely manner.
1.11.5 If there is a gap in engagement where the Contractor works on an assignment
outside of Capita for a period of 4 weeks or more, the checks required by this Policy
must be repeated as part of the re-engagement process.
1.11.6 Sole traders should not be used within Capita Businesses i.e. individuals should
not be contracted directly by Capita and must not be paid via direct local invoicing
through bought ledger. To do this puts Capita at risk for the payment of the
individual’s tax and other statutory liabilities.
1.11.7 However, in some industry sectors, for example GPs providing medico-legal and
screening services, it is normal for Contractors to engage as Sole traders. In these
instances, where it is not normal practice for Contractors to use limited companies,
clearance must be obtained from Group tax that the Sole traders can be paid
without deduction of PAYE / NIC. Group tax will assist the Business with the use of
HMRC’s employment stats indicator tool (ESI) and where this is inconclusive, will
obtain clarification of the status from either HMRC or independent tax advisors.

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Such clearances are however limited to the particular contracts/circumstances of

the engagements at that time. Any changes to such conditions would mean that the
clearance would not hold good and therefore before making any such changes tax
clearance must again be obtained prior to commencement of the service via Group
Tax. Where the ESI tool determines that the Sole trader should be treated as an
employee for tax purposes, payments must be subject to PAYE / NIC at source, it is
not appropriate to merely seek an indemnity from the Contractor in relation to
payment of tax.
1.11.8 Further details of how to use the ESI tool can be found on CAPITA Connections.
Contact Stuart Farrow-Smith, Group Tax (stuart.farrow-smith@capita.co.uk) for
further advice and guidance.
1.11.9 Capita Businesses must not contract with any overseas / non-UK limited companies
where the work is to be carried out by the individual in the UK as the PAYE / NIC
risk can potentially pass back to Capita in these circumstances. There is also a
reputational risk for Capita plc with HMRC.
1.11.10 Individuals who are engaged by Capita under a consultancy agreement fall outside
the scope of this Policy. In this case Capita engages with a company (e.g. KPMG,
IBM, Ernst and Young) for the provision of services, rather than with an individual /
Sole trader. In this case appropriate due diligence should be completed.
Assurances / indemnities on the integrity of the company’s Workers, level of vetting
completed and liability with respect to any fraudulent/criminal activity attributed to
those Workers will be dealt with through the service contract and should be
confirmed with the service provider. Note that “consultants” who are essentially
Sole traders, fall under the definition of “Contractors” above for vetting purposes.
1.11.11 Contractors who join Capita plc through Business acquisition or transfer must be
novated to Capita plc compliant contracts via CIR.
1.11.12 All Contractors or third parties working on Capita’s clients’ data must use Capita
equipment. No third party may use their own e.g. personal or third party company
laptop to work on or transport Capita owned data. For further guidance refer to the
Third Party Management Information Security Standard.
1.12 SUPERVISION OF WORKERS

1.12.1 In addition to the completion of vetting and screening checks, all Workers must be
subject to an appropriate level of supervision during the period they are engaged
within the Business, with designated line reporting within the operational
management structure. This is particularly important for Workers working in
sensitive areas of the Business, e.g. those areas which handle/have contact with
confidential or market sensitive data or cash/securities or other high value assets.
In making this judgement, consideration must be given to the potential for an
individual to undertake fraudulent activity within the work environment e.g. theft of
confidential information, and the type and level of access to sensitive data, having
regard to the level of supervision and other control measures that are in place.
1.13 CONTACTS
1.13.1 The main contacts for this Policy are:

Capita plc Policy
 Wendy Owen, Group Risk & Compliance: wendy.owen@capita.co.uk

 Jacqui Akdeniz, Group HR: jacqui.akdeniz@capita.co.uk
 Ewan Tweedie, Security Watchdog: ewan.tweedie@capita.co.uk
 Aimi Kearney, Security Watchdog: aimi.kearney@capita.co.uk
 Sue Morton, Capita Internal Resourcing: sue.morton@capita.co.uk
1.13.2 For further information and questions, please contact:

 The Managers’ Guide to Employment Practices (MGEP) > Starting >
Recruitment and Selection > Pre Employment Checks: for guidance on
recruitment related vetting and screening
 HR Administration: for employment references and information
 Group HR: for guidance not available in the Managers’ Guide
 Fraud Risk Co-ordinator or Divisional Risk & Compliance team: for advice on
measuring levels of fraud risk and supervision required
 Divisional Information Security Director (DID): for appeals against recruitment
decisions
 Group Risk & Compliance: for updates to this Policy

Capita plc Policy
2 APPENDICES
2.1 GLOSSARY
2.1.1 A number of words and phrases in this Policy have particular meanings as set out
below.
BPSS Baseline Personnel Security Standard: the UK Government’s
standard which outlines the pre-employment checks that all civil
servants and members of the armed forces must undergo before they
are granted access to government assets
British Isles England, Scotland, Wales, Northern Ireland, Isle of Man, Jersey &
Guernsey
Business A firm, company or location within Capita

Capita Capita plc and its subsidiaries
Capita employee Capita’s definition is in accordance with the statutory definition of an

employee under the UK Employment Rights Act 1996: "an individual
who has entered into or works under a contract of employment which
is employed on a continuous basis”. For the purposes of vetting and
screening, this also includes individuals on Capita’s payroll engaged
on a fixed term or zero hours contract of employment.
CIR Capita Internal Resourcing
Contractor
Capita defines a contractor as “an individual who is engaged as a
limited company contractor or who is providing services via an
umbrella company and whose services are supplied to Capita to carry
out requirements of work for Capita”.
A contractor is not an employee and should not be treated as such
(e.g. for annual leave entitlement, receiving sick pay, being included
on internal organisational charts).
FCA Financial Conduct Authority: Capita’s primary UK financial services
regulator, responsible for systems and controls requirements in
relation to personnel recruitment, training and competence
HMT Her Majesty’s Treasury

Policy This Vetting and Screening Policy
PRA Prudential Regulation Authority: along with the FCA, the UK financial
services regulator responsible for systems and controls requirements
in relation to personnel recruitment
Regulated (Reg) A Financial Services Business within Capita which is regulated by the
FCA, the PRA, or an equivalent oversees financial services regulator.
For the purpose of this policy, Regulated Businesses includes all
Businesses within the Asset Services, Insurance and Benefits
Services divisions, and the Businesses within Customer Management
which are FCA authorised. Within the Regulated Businesses, no
distinction should be made between Regulated and non-Regulated
cost centres. All Workers are to be treated as Regulated individuals,
as are Workers who move into a Regulated division, and as such are

Capita plc Policy
required to have completed the vetting and screening checks defined

in this policy.
RFO
Request For Offer: the RFO process within Capita Desktop requires
the recruiting manager to provide contact details for the potential
Worker and to specify information such as the type of reference
required (employment, academic or personal). Once the RFO has
been approved, SW contacts the potential Worker to start the required
vetting and screening checks.
Sole trader
A ‘self-employed’ person running their own business as an individual,
either working alone or employing and responsible for other people.
SW Security Watchdog
Temporary worker
Capita defines a temporary worker as “an individual who is working
under a contract for services or a contract of employment and who is
supplied to Capita or a client through a third party to carry out
requirements of work for Capita or the client under the supervision,
direction and control of Capita or the client”.
Sometimes referred to as an ‘agency’ worker.
All paid temporary workers on assignments in Capita UK must be
sourced through the CIR Master Vendor Agreement.
Temporary workers include individuals placed with Capita for work
experience and interns who are likely to have unsupervised access to
Capita and/or client systems and data.
Third party A non-Capita company which provides products or services e.g. a
cleaning company.
Worker Capita employees, Temporary workers and Contractors; full-time,
part-time and fixed-term workers; paid workers and unpaid volunteers
2.2 ADDITIONAL UK INFORMATION

2.2.1 MANAGERS’ GUIDE TO EMPLOYMENT PRACTICES (MGEP)
Processes and procedures for the application of this Policy are detailed in the Managers’
Guide to Employment Practices (MGEP), accessed via the ‘My team’ section of Capita
Desktop: Starting > Recruitment and Selection > Pre Employment Checks. This Policy must
be read in conjunction with the Managers’ Guide. A list of related documents is provided later
in this Policy.
2.2.2 RECRUITMENT CHANNELS

Capita Internal Resourcing (CIR) is Capita’s specialist recruitment business which provides a
managed service for the recruitment activities of all UK Capita companies. CIR must be
involved in the recruitment of paid Temporary workers and Contractors in the UK.
CIR (or a designated CIR supplier) ensures vetting and screening checks are carried out in
accordance with the requirements of this Policy and that all necessary insurances are in
place. CIR manages the contract negotiation process to ensure full contractual protection to
Capita at market rates.

Capita plc Policy
CIR is a fully compliant channel for Temporary worker recruitment, as well as for Contractor
engagement and management. CIR carries out regular audits to ensure compliance with this
Policy. Contractor assignments are subject to independent internal audit and reporting to
ensure compliance with this Policy, with a particular focus on those resources recruited other
than through CIR.
Any exceptions identified by CIR are notified to the recruiting manager.
2.2.3 SECURITY WATCHDOG (SW)

Security Watchdog (SW) is Capita’s specialist pre-employment vetting and screening
business. SW ensures vetting and screening checks are carried out in accordance with the
requirements of this Policy.
2.3 RELATED INFORMATION AND DOCUMENTS

Note: this is not intended to be an exhaustive list.
CAPITA Connections
Risk & Compliance information

 Group Policies e.g. Safeguarding policy
Information Security information

 Policies and Standards e.g. Security awareness standard
The Managers’ Guide to Employment Practice (MGEP)
Recruitment and selection > Pre Employment Checks

e.g. Employment References, Criminal Records Checks, Financial Probity Checks,
Approved Persons, Ongoing Checks
2.4 DOCUMENT HISTORY

Issue Date Purpose Author
1.0 14/03/07 Final Draft Gaynor Rich
1.0 14/03/07 Final Draft Gaynor Rich
2.0 18/07/07 Issued Rebekah Heaven
3.0 13/09/07 Issued Rebekah Heaven
3.1 06/06/08 For review Graham Smith
3.2 24/07/08 Contractor information and pricing added Heather Kitto
3.3 14/05/09 Integrated policy temps and contractors Gaynor Rich
4.0 19/10/09 Amended Contractors, Temps policy and added Gaynor Rich
Perm requirements
5.0 05/11/09 Revised Master Vendor Agreements Kellie Byrne
6.0 02/11 Annual Review and Contractors project Gaynor Rich
feedback
6.1 01/01/12 Corporate Name Change Gaynor Rich
7.0 24/01/12 Annual Review Gaynor Rich
8.1 01/07/12 Replace TSW-PECT with TSW TSW-PECT Gaynor Rich
8.2 12/09/12 Wording refines Gaynor Rich

Capita plc Policy
9.0 08/02/13 Annual review Gaynor Rich

10 30/08/13 Introduction of financial probity and criminal Wendy Owen
records checks to non-Financial Services
Regulated Workers. Addition of international
information to address increasing multi-
jurisdictional presence. Various rewording and
formatting changes.
11 22.12.14 Additions: 1.1.6, 1.3.4, 1.3.5, 1.3.6, 1.4.6, 1.4.7, Wendy Owen
1.10.4, 1.11.4; minor wording & date changes
Distribution (i.e. those who receive the Policy when updated)
Name Organisation Role

CAPITA Connections Capita Corporate Intranet
Reviewers (i.e. those who review the Policy when updated)

Name Business/Function Role
Wendy Owen Group Risk & Compliance Compliance Manager
Jacqui Akdeniz Group HR Group HR Director Operations
Ewan Tweedie Security Watchdog The Advisory Bureau, Director Group
Risk and Quality Assurance
Aimi Kearney Security Watchdog Chief Operating Officer
Sue Morton Capita Internal Resourcing Projects Director, Internal Resourcing
Approval (i.e. those who have authority to approve the Policy)
Name Role
Vic Gysin Joint Chief Operating Officer
Dawn Marriott-Sims Joint Chief Operating Officer
Chris Terry Director Group Risk & Compliance


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Capita plc Policy

Vetting and Screening

CAPITA PLC POLICY

Page 1 of 22 COMMERCIAL IN CONFIDENCE © 2014 Capita plc

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1.4 RECRUITING MANAGERS’ RESPONSIBILITIES

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1.5 BRITISH ISLES CHECKS

Financial probity (must

Criminal records (must

Adverse media (where

legally required for

years for reg)

Temporary Non-Reg C C C C C C  C**  C** C C C

* Planned roll-out by March 2015

** Planned roll-out by June 2015

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1.6 EUROPE, THE MIDDLE EAST AND AFRICA (EMEA) CHECKS

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Ireland (Republic of)

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1.7 ASIA PACIFIC (ASIA-PAC)) CHECKS

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1.8 OVERVIEW OF MEANING OF CHECKS

 Valid passport (any nationality)

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national insurance card, or a letter from a Government agency.

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2 years employment history, with the exception of UK Approved

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relevant to role) MD a check will be completed. In high risk/profile contracts, an

1.9 CAPITA EMPLOYEES

1.10 TEMPORARY WORKERS

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Such clearances are however limited to the particular contracts/circumstances of

1.12 SUPERVISION OF WORKERS

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 Wendy Owen, Group Risk & Compliance: wendy.owen@capita.co.uk

1.13.2 For further information and questions, please contact:

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Business A firm, company or location within Capita

Capita employee Capita’s definition is in accordance with the statutory definition of an

HMT Her Majesty’s Treasury

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required to have completed the vetting and screening checks defined

2.2 ADDITIONAL UK INFORMATION

2.2.2 RECRUITMENT CHANNELS

Page 20 of 22 COMMERCIAL IN CONFIDENCE © 2014 Capita plc

2.2.3 SECURITY WATCHDOG (SW)

2.3 RELATED INFORMATION AND DOCUMENTS

Risk & Compliance information

Information Security information

The Managers’ Guide to Employment Practice (MGEP)

Recruitment and selection > Pre Employment Checks

2.4 DOCUMENT HISTORY

Page 21 of 22 COMMERCIAL IN CONFIDENCE © 2014 Capita plc

9.0 08/02/13 Annual review Gaynor Rich

Distribution (i.e. those who receive the Policy when updated)

Name Organisation Role

Temporary Non-Reg C C C C C C  C  C C C C