When an ACS assessor, a client auditor or an insurer tests your BS 7858 compliance, they do one thing: pull a screening file and check what is inside it. This checklist is everything a complete file contains, in the order an auditor looks for it, plus the gaps that cause most failures. New to the standard? Read BS 7858:2019 explained in plain English first.
The complete file, item by item
- Signed screening consent, naming the checks and the data processing involved.
- Completed application or screening questionnaire, signed and dated by the applicant.
- Named screening decision-maker recorded for the file.
- Identity documents: certified copies, checked against the person, with the checker's name and date.
- Right to work evidence: the statutory check, done before day one, copy retained.
- Address history covering the required period, with documentary support.
- Continuous employment and education history with no unexplained gaps.
- Written verification from each employer in the period (dates, role, reason for leaving), or documented evidence of genuine attempts and an alternative check.
- Gap evidence: every break accounted for and supported (benefits letters, travel stamps, self-employment records, a statutory declaration where nothing else exists).
- Character referee responses, independent of family, recorded with contact details and dates.
- Financial probity result (CCJs, insolvency), with the applicant's explanation recorded for any adverse finding.
- Criminal record declaration consistent with the role, and a basic disclosure where used.
- Screening decision: pass, fail or incomplete, signed and dated by the named decision-maker, with reasons.
- Conditional employment record where used: preliminary checks evidence, start date, supervision arrangements, and completion inside the 12 week limit.
- Training evidence for the screener and the subject where required, ideally certificates that can be verified online.
- Retention note: what will be kept, for how long, under which lawful basis.
The five gaps that fail audits
- Unexplained history gaps. Three missing weeks is a finding. Chase every gap to evidence or a signed declaration.
- Conditional employment with no clock. Someone started "temporarily" a year ago and screening never finished. Diary the 12 week limit the day they start.
- Referee attempts not documented. Trying twice and giving up is defensible only if the attempts are in the file.
- Subcontractor blind spots. If subcontracted staff work your contracts, your file duty follows them. Hold confirmation of their screening or do it yourself.
- Files kept forever. Over-retention is a UK GDPR breach sitting inside your compliance evidence. Set retention and honour it.
Make the evidence self-serve
Half of audit pain is retrieval. Put training on a live training matrix so assigned, completed and refresher-due dates are one screen, and use certificates with public verification links so nobody has to trust a photocopy. Your screening files stay in the cabinet; everything around them becomes a link.