Pool lifeguards and DBS eligibility

Last updated: 08 Nov 2017 Topics: Safe recruitment

This briefing (PDF) has been developed to assist pool operators, managers and staff 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: 2017


  • 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 


Facility managers have a duty of care to users and staff, which extends to taking reasonable steps to ensure that all staff are suitable for their role. One part of an effective safer recruitment process is to undertake criminal records checks (DBS in England and Wales) for all eligible posts and roles.

Within leisure facilities there are likely to be individuals in roles that qualify for a range of levels of DBS checks (from basic to enhanced level and children’s barred list check).

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