Following the recent controversy with Liberal Democrat conference accreditation, I have been doing some research into the Criminal Record Bureau’s (CRB) own procedures into dealing with Trans folk. The procedure has been recognised as problematic by the CRB themselves as a recently published equalities impact assessment, dated October 2010, hilighted the issues with the current system. (PDF Link)

From the CRB’s own research in 2010, (PDF Link) there is evidence people are being put off – 91% of people overall would be “willing to to be CRB checked” for either voluntary or paid work, versus 65% for trans folk. It’s noted that the findings are from a “small sample size”, but Intersex folk had a similar response and it is also broadly in line with the general rate of applications revealed in previous FoI requests. Other marginalised groups have similar findings – the Lesbian/Gay (But not Bisexual, oddly) community, Hindus and to a lesser extent those identifying as Asian also reported they were less likely to be willing to be CRB checked.

On the topic of the overall procedures the civil service Trans group, a:gender, responded to the internal EqIA consultation with the two primary concerns with the process:

• That previous name details should be removed from completed Disclosures, as currently the name of the applicant at the time of each conviction is recorded.
• That a form of words is added to the front of the new CRB Disclosure Application Form to highlight to customers that there is no requirement for them to enter names from a previous gender on the application

The plan by the Home Office as a result was…

• To explore options for not revealing previous identities on CRB Disclosures
• To explore options for amending the CRB application form to include reference to inform applicants of the alternative process

On the first issue, not revealing previous identities, there has been some progress but it is questionable in it’s utility and probably not much use at all given it’s unadvertised. I contacted the CRB for the detail and was told that you can contact the data protection office at your local police force (Once you have a Gender Recognition Certificate) and ask them to update the Police National Computer with your new details, so any CRB printout would show the new details.

If you do not yet have a GRC, I’m told you can contact the CRB who can “look into” producing a manual certificate.

It’s something at least, and they deserve credit for recognising the problem.

They seem not to have made an progress in the year since the EqIA was produced on the second point. The latest CRB application form guidance (PDF Link) is dated February 2011 and makes no mention of the Transgender application process. It seems you need to know it exists to use it, or happen to visit the right part of the CRB web site – not good, given that less than half of Trans people said they knew something about the CRB when asked.

Overall, it’s progress. But this new system, particularly given it appears to be completely unpublicised, does not (yet) fill me with confidence.