Adding another document to a tenant application is not automatically better referencing. A DBS certificate contains particularly sensitive information, and a landlord or agent needs to understand the rules before asking for or retaining it.
The Information Commissioner’s Office explains that processing criminal-offence data requires a lawful basis and additional authorisation under the rules applying to that information. For organisations without official authority, a relevant condition under the Data Protection Act 2018 is needed. A general desire to reduce risk does not, by itself, answer those questions.
GOV.UK’s applicant guidance says a basic DBS check contains unspent convictions and conditional cautions. That describes the certificate’s scope; it does not establish that a landlord should request one from every prospective tenant.
Start with the purpose
Write down the specific problem you think the check would solve. Then ask whether the information is necessary for that purpose and whether a less intrusive approach would be suitable. Do this before changing an application form or asking an agent to collect certificates.
Seek qualified advice on the proposed process, including the lawful basis, applicable condition, fairness and what applicants must be told. Do not assume that calling submission “voluntary” settles the issue, especially if applicants believe refusing will harm their chances of securing a home.
Limit access and retention
If a properly assessed process is justified, decide who genuinely needs access and how the information will be protected. Avoid forwarding certificates around an informal group or leaving copies in a general property folder. Set a retention approach tied to the purpose rather than keeping sensitive records indefinitely just in case.
Ask a referencing provider to explain exactly what its service covers. A package name such as “comprehensive” is not a description of each check, and an extra certificate is not a guarantee of future tenancy conduct.
Avoid blanket conclusions
An application should not be reduced to an unexplained label. Build a consistent, lawful decision process with an opportunity to clarify errors or relevant context. This article does not assess any individual’s suitability for housing or endorse automatic rejection rules.
For smaller landlords, the sensible next step is often to review the information already being collected and get advice before adding more. Good referencing includes knowing what not to collect.
Sources: ICO, criminal-offence data guidance; GOV.UK, Basic DBS check: guidance for applicants. Checked November 2026. General information, not legal advice.