DBS Verification Failures: Lessons from the Bracknell Taxi Licensing Case

A background-check requirement only provides protection if the required evidence is actually reviewed.

That principle was highlighted by an investigation into taxi licensing at Bracknell Forest Council following the conviction of former mayoral consort Diwan Khan.

In June 2026, the council published the findings of an internal audit into the circumstances surrounding Khan's taxi licence. The investigation found there was no evidence that his DBS certificate had been seen before the licence was issued.

The case provides a practical lesson for employers, licensing authorities and other organisations using criminal-record checks.

The issue is not simply whether a DBS check was requested. Organisations also need a process for confirming that the appropriate result has been reviewed, relates to the correct person and has been considered according to the requirements of the role.

What Happened in the Bracknell Case?

Bracknell Forest Council commissioned an internal investigation following concerns surrounding the taxi licensing of Diwan Khan.

Khan was convicted of rape at Winchester Crown Court in February 2026. The council subsequently reviewed the licensing process and the actions taken before and after his arrest.

The investigation found that there was no evidence that Khan's DBS certificate had been seen before his taxi-driver licence was issued. The council's governance and audit committee subsequently considered recommendations arising from the review.

It is important not to overstate what this finding proves.

The lesson is not that a DBS check can predict future criminal behaviour or that every adverse disclosure automatically prevents someone from holding a particular role.

The more defensible lesson is that an organisation cannot properly assess relevant criminal-record information if the required certificate or result is never actually reviewed.

Requesting a DBS Check Is Only the First Step

For Standard and Enhanced DBS checks, the certificate is normally issued to the applicant.

Government guidance states that the applicant must then show the certificate to the employer or organisation that requested the check so it can be reviewed.

That creates several separate stages:

• Determine which level of DBS check the role is legally eligible for
• Complete the appropriate application and identity process
• Receive the resulting certificate
• Ensure the appropriate organisation actually reviews it
• Confirm that it relates to the correct applicant
• Assess relevant information according to the role
• Record that the required process has been completed

A process can therefore fail even if an application was originally initiated.

Employers Must Request the Correct Level of DBS Check

DBS checks are not arranged according to a simple hierarchy where organisations can choose the highest level available.

Basic checks can be used much more widely, while Standard, Enhanced and Enhanced with Barred List checks are restricted to roles that meet specific legal eligibility requirements.

DBS guidance states that employers are legally responsible for ensuring a role is eligible before requesting a Standard or Enhanced check. Requesting a level of check for which a role is not eligible can itself breach the law.

This means employers should not describe Standard DBS checks as appropriate merely because a position involves financial responsibility or a high level of trust.

Eligibility depends on the role and the relevant legislation.

For a detailed explanation of the different levels, see our guide to What Is a DBS Check?

What Should Employers Check on a DBS Certificate?

Where the process requires an original DBS certificate to be presented, organisations should not treat a photocopy or photograph as equivalent.

Current DBS employer guidance states that organisations should see the original certificate and describes security features that can help identify whether a certificate may have been altered or counterfeited.

These include features relating to the certificate paper, printing, watermark and other security elements.

The purpose is to establish that the certificate presented appears genuine and corresponds with the application and individual concerned.

This should not be described as checking every certificate against a universal public government registry.

There is no general public DBS database that an employer can simply search to authenticate any certificate.

What About the DBS Update Service?

The DBS Update Service is different from checking the authenticity of an original certificate.

Where an individual has subscribed and the relevant conditions are met, an employer may be able to conduct an online status check to establish whether new information has been added since the certificate was issued.

The employer still needs to establish that:

• The certificate belongs to the individual
• The certificate is genuine
• The level and type are appropriate for the role
• The organisation is legally entitled to request that level of information

The Update Service should therefore not be presented as a universal substitute for reviewing the underlying certificate and understanding the eligibility requirements.

A DBS Disclosure Does Not Automatically Determine the Decision

Criminal-record information needs to be considered in context.

A disclosure does not automatically mean that somebody is unsuitable for employment, licensing or another appointment.

The organisation may need to consider factors such as:

• The nature of the offence
• Its relevance to the role
• When it occurred
• The individual's responsibilities
• Applicable legal or regulatory requirements
• Any safeguarding considerations
• Other relevant evidence

Equally, the absence of information on a DBS certificate does not guarantee that an individual presents no future risk.

DBS screening is one source of information within a wider decision-making process.

Verification Failures Are Governance Failures

The Bracknell case illustrates a broader point about recruitment and licensing controls.

A policy may state that a DBS check is required, but that does not establish that the control operated correctly in practice.

Organisations need to know:

• Whether the check was completed
• Whether the result was actually reviewed
• Who reviewed it
• When the review took place
• Whether discrepancies were identified
• How the final decision was recorded

Without that information, management may believe a safeguarding control is operating when the underlying evidence is incomplete.

High-Volume Screening Increases the Need for Visibility

The same issue can arise in organisations recruiting large numbers of people.

Where checks are managed through multiple emails, spreadsheets or teams, it can become difficult to distinguish between:

• A requested check
• A check awaiting a result
• A certificate awaiting review
• A completed check
• A case requiring escalation

A centralised screening workflow can make these differences more visible.

Conflict International's vetting portal can support candidate onboarding, case tracking and visibility of outstanding screening requirements.

Technology does not decide whether somebody should be appointed.

Its value is in helping organisations maintain a clearer record of which checks have and have not been completed.

What Should Employers Learn from the Bracknell Case?

The central lesson is simple.

A screening requirement has limited value if nobody can demonstrate that the evidence was reviewed.

Organisations using DBS checks should therefore:

• Confirm that the role is eligible for the level requested
• Follow the appropriate identity and application process
• Ensure the required certificate or result is actually reviewed
• Confirm that the information relates to the correct individual
• Record completion of the check
• Escalate incomplete or questionable cases
• Make recruitment decisions according to the role and the information available

The objective is not to make DBS screening more intrusive.

It is to make the existing process more reliable.

DBS Checks from Conflict International

Conflict International provides DBS Checks for employers requiring Basic, Standard and Enhanced screening where the relevant role is eligible.

We can support the application and screening workflow, coordinate candidate information and help organisations maintain visibility of outstanding and completed checks.

The employer remains responsible for determining the correct level of DBS screening for the role and for making the final recruitment decision.

For a full explanation of eligibility and the information provided at each level, see our What Is a DBS Check? guide.

Reviewing Your DBS Process

The Bracknell licensing case demonstrates the difference between requiring a check and being able to show that the result was actually reviewed.

For organisations managing safeguarding, regulated appointments or higher-volume recruitment, clear records and defined responsibility for completing screening can be as important as the check itself.

Complete the enquiry form below to discuss your DBS Checks requirements or how Conflict International's vetting portal can support a structured screening workflow.