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DBS barring guide · DBS oral representations

Written and oral DBS barring representations

Written representations create the structured evidential case. Oral representations may be considered in some circumstances, but they should add focused explanation rather than substitute for missing evidence.

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What this means

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Written representations create the structured evidential case. Oral representations may be considered in some circumstances, but they should add focused explanation rather than substitute for missing evidence.

Immediate priorities

Organise the position before responding.

01

Build a complete written response first

02

Identify the issue that genuinely requires oral explanation

03

Prepare to answer risk and relevance questions directly

Detailed guidance

The procedure, evidence and possible route from here.

01

Written representations create the evidential structure

A written response should identify the DBS route, list or lists, provisional findings and evidence relied upon. Use headings for material factual corrections, context, regulated activity, current risk, changed circumstances and supporting evidence. Attach an indexed bundle rather than embedding every document in a long narrative. The writing should enable a decision-maker unfamiliar with the wider employment dispute to understand what is accepted, what is disputed and why each exhibit matters.

Written representations are also a durable record of what DBS was asked to consider. Accuracy matters because the file may later be relevant to review or appeal. Avoid absolute assertions that supporting evidence cannot bear. Where recollection is uncertain, say so and distinguish it from a positive denial. Where a finding by a court or competent body cannot be altered by DBS, address its context and current relevance instead of presenting the submission as an appeal against that decision.

  • Organise the response around the DBS decision questions
  • Index exhibits by provisional finding and risk issue
  • Use precise language for memory, admission and dispute

02

Oral representations serve a defined purpose

DBS publishes an oral-representations process for people who are invited to make representations and for whom an oral format may assist. Oral submissions can explain complex history, communication needs or matters difficult to convey in writing. They should complement a documented case rather than replace available evidence. The request should explain why oral participation is appropriate and what issue it will help the decision-maker understand. A dated, source-linked case file helps preserve that distinction as the matter develops.

Preparation should remain truthful and unscripted. Build a topic outline, review the written record and identify difficult questions about harm, responsibility, boundaries and future risk. The speaker should not memorise a performance or introduce surprising allegations that cannot be checked. If a representative or supporter is involved, clarify their role with DBS. Any accessibility or communication need should be raised early so the process can be arranged fairly. Its practical significance must still be assessed against the individual evidence and procedural stage.

  • Explain why oral participation will assist the decision
  • Use a topic plan rather than a rehearsed speech
  • Raise accessibility and support needs promptly

03

Keep oral and written accounts consistent

Consistency does not require identical wording, but material changes need an explanation. Compare the oral account with employer statements, police interviews, court documents and the written representation. If a correction is necessary, identify it before the session and explain its basis. An unexplained shift can affect credibility, while a candid correction supported by records may help DBS understand how an earlier mistake arose. Keeping that question separate makes the resulting submission clearer and more reliable.

After the oral process, keep an accurate note of issues discussed, any further information requested and the date for providing it. If DBS obtains new material it proposes to use, respond through the stated process. The final submission should leave a coherent record across formats. Neither persuasive speaking nor polished drafting guarantees an outcome; both must remain anchored to reliable evidence and the statutory safeguarding question. The record should show how this point applies, rather than asking the decision-maker to assume it.

  • Audit consistency across all prior accounts
  • Explain any material correction with supporting evidence
  • Record follow-up requests and responses after the oral session

Key questions

Keep the analysis tied to this stage.

Question 01

Whether oral representations assist fair decision-making

Question 02

Consistency between documents and oral account

Question 03

How present risk is evidenced rather than asserted

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Advice is provided only by the regulated firm that accepts a matter.

Common questions

Clarifying the route without assuming the outcome.

Can I choose oral representations instead of providing evidence?

Oral representations can assist in appropriate cases, but they do not remove the value of reliable documentary evidence. DBS decides the arrangements under its process.

Should an oral response be memorised?

No. Careful preparation is useful, but a scripted performance can obscure the person's genuine account and make it harder to answer questions accurately.

Connected guidance

Continue through the topic map.

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Official sources

Check the material for this question.

Sources checked 19 September 2026. Rules change, so compare the current notice and linked official material and tell the operator if a citation or summary needs correction.

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