Pool lifeguards and DBS eligibility

Last updated: 23 Mar 2021 Topics: Safe recruitment

Facility managers have a duty of care to users and staff to take reasonable steps to ensure that all staff are suitable for their role. An effective safer recruitment process should be undertaken, including criminal records checks for eligible roles.

This briefing paper has for been developed to assist pool operators, managers and staff within leisure facilities to establish a consistent approach to decisions about the eligibility of pool lifeguards for Disclosure and Barring Service (DBS) checks.  

Author: NSPCC Child Protection in Sport Unit (CPSU)
Published: 2021


  • Introduction
  • The roles of lifeguards in relation to children and young people
  • Eligibility criteria for DBS checks
  • Pool lifeguards eligibility criteria for regulated activity
  • Pool lifeguard eligibility if regulated activity criteria are not met 
  • Lifeguards and DBS eligibility 

Lifeguards and DBS eligibility

It's the employer’s responsibility to decide whether, in light of information and guidance provided, their employees (paid or volunteers) are undertaking regulated activity with children, or are otherwise in roles eligible for a DBS check without the barred list check.

As detailed in the briefing, the core pool lifeguarding role, when undertaken in facilities that are regularly or frequently used by children, clearly meets the legislative DBS eligibility criteria.

This is on the basis that the core role involves ‘supervising’ children in the water and that this is carried out on more than 3 occasions in a 30-day period and irrespective of whether or not there are other adults present with primary responsibility for the child.

Download the briefing