Does this member of dental staff need a DBS check, and at which level? Five questions

A practice manager with a new starter, or a staff file to bring up to date, has to decide whether that person needs a Disclosure and Barring Service check and what kind. The Care Quality Commission does not decide who is eligible, but it inspects the decision. This questionnaire asks what the person will do, whether anything about the job has changed, what contact they have with patients and what certificate they already hold. It gives one outcome with the rule behind it, taken from the CQC's dental mythbuster 19, its registration guidance and the DBS pages on GOV.UK as we read them on 2 October 2026. It applies to England. Nothing you choose leaves the page.

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DBS checks for dental staff: which rule applies

Answer each question. Some questions appear only when an earlier answer makes them relevant. Nothing you choose leaves this page.

1. What will this person do at the practice?ChooseClinical work: dentist, hygienist, therapist or dental nurseNon-clinical work: reception, management, admin or cleaningApplying to the CQC as provider, partner or registered manager
2. Is this a new recruit or a change of job, or someone carrying on in the same job?ChooseNew recruit, or a change in place or terms of workAlready employed, same job, nothing has changed
3. What contact will the person have with patients?ChooseAccess to records only, no contact with patientsMeets patients at the desk or on the phone, nothing moreWill chaperone, or supervise a child while a parent is treated
4. Is the person a dentist on the NHS Performers List?ChooseYesNo, or a hygienist, therapist or dental nurse
5. Does the person hold an enhanced certificate that is registered with the DBS Update Service?ChooseYes, at the level and for the workforce this job needsNo, or it does not match this job

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The outcome is the rule as our guides and the sources named set it out, applied to the answers you gave. It is not advice on your own case. Regulated work: a GDC-registered professional or the practice manager reviews every patient-facing draft before it is sent; nothing here is clinical advice and the AI assistant writes nothing clinical.

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The questions, and why each is asked

1. What will this person do at the practice? The CQC's dental mythbuster 19 says all clinical staff require a DBS check and that there is no general requirement for non-clinical staff. Someone applying to the CQC to be a registered person follows a separate rule.

2. Is this a new recruit or a change of job, or someone carrying on in the same job? The CQC says there is no requirement to repeat checks for staff who remain employed if there is no change in either their place or terms of work. A new starter or a changed role is assessed afresh. This question appears only when an earlier answer makes it relevant.

3. What contact will the person have with patients? The CQC says the need for a check rests on the level of contact staff have with patients, and gives three examples: access to records alone, chaperone duties, and supervising a baby or child during a parent's appointment. This question appears only when an earlier answer makes it relevant.

4. Is the person a dentist on the NHS Performers List? The CQC says dentists contracted by the NHS should have completed DBS checks as part of their Performers List checks, and that in some cases a practice may use those checks instead of obtaining another. This question appears only when an earlier answer makes it relevant.

5. Does the person hold an enhanced certificate that is registered with the DBS Update Service? With the person's consent, an employer entitled to the same level of check for the same workforce can run a free online status check on a certificate in the Update Service, after seeing the original certificate. This question appears only when an earlier answer makes it relevant.

Every outcome, and the rule behind it

CQC applicant: an enhanced check with barred lists, no more than 12 months old

Reached when: "What will this person do at the practice?" answered "Applying to the CQC as provider, partner or registered manager".

Anyone applying to the CQC as an individual provider, registered partner or registered manager must hold an enhanced DBS check with the appropriate barred list information before applying, and the CQC rejects applications where the check is over 12 months old. A registrant of the GDC or the HCPC posts the original paper certificate. Anyone else needs a check countersigned by the CQC, which it says can take up to 60 working days. The CQC does not accept a certificate from the Update Service.

• Check the issue date on the certificate: it must be no more than 12 months old when the application goes in.
• GDC or HCPC registrant: post the original paper certificate to the CQC with your registration number.
• Not a registrant: apply for the CQC countersigned check first and allow up to 60 working days.

Source: Care Quality Commission, DBS checks for CQC registration (page last updated 19 December 2025), read 2 October 2026. The working is in How much does a DBS check cost for a dental practice or clinic in 2026? £49.50 enhanced, £21.50 basic and £16 a year for the Update Service.

Same job, nothing changed: no repeat check is required

Reached when: "Is this a new recruit or a change of job, or someone carrying on in the same job?" answered "Already employed, same job, nothing has changed".

The CQC says there is no requirement to repeat checks for staff who remain employed if there is no change in either their place or terms of work. It is up to the employer to decide whether a new check is needed, and the practice should hold evidence that it has considered when, with a risk assessment behind the decision. The DBS says a check has no official expiry date. A three-yearly re-check is therefore the practice's own policy and not a rule.

• Write down when the practice re-checks staff and why, and keep the risk assessment with the policy.
• If you do re-check, price it: £49.50 for a new enhanced check against £16 a year for the Update Service.

Source: Care Quality Commission, Dental mythbuster 19: Staff recruitment (page last updated 2 October 2023); GOV.UK, DBS checks: guidance for employers (last updated 11 September 2026); read 2 October 2026. The working is in How much does a DBS check cost for a dental practice or clinic in 2026? £49.50 enhanced, £21.50 basic and £16 a year for the Update Service.

Records access alone: no DBS check is needed

Reached when: "What contact will the person have with patients?" answered "Access to records only, no contact with patients".

The CQC's dental mythbuster 19 says non-clinical staff do not need a DBS check if they have access to medical records alone and no contact with patients. The certificate is one item among the recruitment checks in Schedule 3 of the 2014 regulations, so the rest of the staff file is still required: proof of identity with a recent photograph, a full employment history with any gaps explained, and evidence of relevant qualifications.

• Note in the staff file that the role has records access only and no patient contact, with the date.
• Complete the other recruitment checks the staff file needs.
• Run this again if the person starts to meet patients, chaperone or supervise children.

Source: Care Quality Commission, Dental mythbuster 19: Staff recruitment (page last updated 2 October 2023), read 2 October 2026. The working is in CQC dental inspection in 2026.

Front desk only: no general requirement, so decide and record why

Reached when: "What contact will the person have with patients?" answered "Meets patients at the desk or on the phone, nothing more".

The CQC says there is no general requirement for non-clinical staff to have a DBS check: it depends on their duties and responsibilities, and a practice may not be breaching the regulations if some non-clinical staff have none. If the practice decides against a check it needs a clear rationale and a risk assessment. A basic check, which the DBS says can be used for any position, costs £21.50 and is the level open to a role that is not eligible for a higher one.

• Assess the role's duties and write the decision and the risk assessment into the staff file.
• If the practice wants a check for this role, ask the person to apply for a basic check at £21.50.
• Do not ask for an enhanced check unless the role is eligible: knowingly asking for too high a level is unlawful.

Source: Care Quality Commission, Dental mythbuster 19: Staff recruitment; GOV.UK, DBS checks: guidance for employers (last updated 11 September 2026); read 2 October 2026. The working is in How much does a DBS check cost for a dental practice or clinic in 2026? £49.50 enhanced, £21.50 basic and £16 a year for the Update Service.

Chaperone or child supervision: confirm eligibility, then apply

Reached when: "What contact will the person have with patients?" answered "Will chaperone, or supervise a child while a parent is treated".

The CQC says staff who carry out chaperone duties may need a DBS check because of the nature of the duties and the level of contact with patients, and that staff who supervise a baby or child while the parent or carer has an appointment will need one. The CQC does not decide eligibility or the level. It points practices to the NHS Employers eligibility tool or to the DBS. An enhanced check costs £49.50, with or without the barred lists.

• Use the NHS Employers DBS eligibility tool, or ask the DBS, to confirm the level for these duties.
• Apply through an umbrella body: the DBS fee for an enhanced check is £49.50.
• Keep the person off chaperone and child supervision duties until the certificate has been seen.

Source: Care Quality Commission, Dental mythbuster 19: Staff recruitment; GOV.UK, DBS checks: guidance for employers (last updated 11 September 2026); read 2 October 2026. The working is in How much does a DBS check cost for a dental practice or clinic in 2026? £49.50 enhanced, £21.50 basic and £16 a year for the Update Service.

Performers List dentist: the existing check may be used, with assurance

Reached when: "Is the person a dentist on the NHS Performers List?" answered "Yes".

The CQC says dentists contracted by the NHS should have completed DBS checks as part of their Performers List checks, and that in some cases a practice may use these instead of obtaining an extra check when the dentist starts. The practice must then show suitable assurance from NHS England that an appropriate check has been completed, and the CQC also expects a risk assessment that identifies and reduces any risks.

• Ask NHS England for written assurance that an appropriate check was completed for this dentist.
• Write a short risk assessment and file it with the assurance in the dentist's staff record.
• If the assurance cannot be obtained, apply for a new enhanced check at £49.50.

Source: Care Quality Commission, Dental mythbuster 19: Staff recruitment (page last updated 2 October 2023), read 2 October 2026. The working is in CQC dental inspection in 2026.

Certificate in the Update Service: run a free status check

Reached when: "Does the person hold an enhanced certificate that is registered with the DBS Update Service?" answered "Yes, at the level and for the workforce this job needs".

All clinical staff require a DBS check, and a person whose certificate is in the DBS Update Service can carry it from job to job within the same workforce where the same type and level of check is required. The employer needs the person's consent, must be legally entitled to that level of check, and should see the original certificate first. The status check is free and online. The person pays £16 a year for the subscription, and the DBS will not tell an employer when a status changes.

• See the original certificate and confirm the person's identity before the status check.
• Get the person's consent, run the status check on GOV.UK, and print and file the result.
• Put repeat status checks in the diary: the DBS sets no prescribed frequency.

Source: GOV.UK, DBS Update Service and DBS Update Service: employer guide, read 2 October 2026; Care Quality Commission, Dental mythbuster 19. The working is in How much does a DBS check cost for a dental practice or clinic in 2026? £49.50 enhanced, £21.50 basic and £16 a year for the Update Service.

New clinical recruit: apply for an enhanced check before they start

Reached when: any other set of answers.

The CQC's dental mythbuster 19 says all clinical staff require a DBS check, and lists dentists, dental hygienists, dental hygiene therapists and dental nurses. An enhanced check costs £49.50 whether or not the barred lists are included; the barred lists are available only for regulated activity, so confirm that part with the NHS Employers eligibility tool or the DBS. The CQC would not usually expect to see a member of staff working while the result is awaited, and expects a risk assessment if one does.

• Apply through an umbrella body, which the DBS says to use when you need fewer than 100 checks a year.
• Hold the start date until the certificate is seen, or write a risk assessment and supervise.
• Ask the person to join the Update Service within 30 days of the certificate's issue date, at £16 a year.

Source: Care Quality Commission, Dental mythbuster 19: Staff recruitment; GOV.UK, DBS checks: guidance for employers (last updated 11 September 2026) and DBS Update Service; read 2 October 2026. The working is in How much does a DBS check cost for a dental practice or clinic in 2026? £49.50 enhanced, £21.50 basic and £16 a year for the Update Service.

How to use the result

Run it once for each person, not once for the practice: a dental nurse and a receptionist who start on the same day can reach different outcomes. Write the outcome and the date into the person's staff file, with the risk assessment where the outcome asks for one, because that record is what an inspector reads. Run it again when someone's duties change, for example when a receptionist starts to chaperone. The fees quoted are the DBS's own; an umbrella body adds its charge on top.

The outcome applies the rule to the answers given; it cannot see the facts behind them. Where an answer is a judgement, or the facts are unusual, the outcome may not fit. A GDC-registered professional or the practice manager reviews anything a tool drafts before it reaches a patient, and this page is general information, not clinical or legal advice.

Overlyft sets up AI assistants for dental, physio and aesthetics clinics: they prepare drafts for a person to approve. None of these outcomes depends on them.