The vetting and barring scheme - introduced by the government in the wake of the Soham murders - will cost the NHS millions, put managers under intense pressure to report staff to the Independent Safeguarding Authority to cover their own backs, and could all too easily lead to innocent staff being barred from working with vulnerable adults and children.

As HSJ reports this week, the widely criticised scheme will force managers to make moral judgments about staff behaviour and lifestyles. Draft guidance from the ISA circulated this month and being considered by the Department of Health identifies a wide range of personal characteristics which should prompt managers to consider whether to trigger an alert.

These include “belief that one is entitled to or deserves sex”, “belief that one is entitled to exploit others financially” (presumably encompassing anyone who has worked in banking), “presence of impulsive, chaotic, unstable lifestyle”, and “inability to meet personal needs responsibly within the context of interpersonal relationships”. I struggle to understand how a manager is supposed to judge the last one, or indeed any of them.

You are also at risk if you exhibit “poor emotional arousal management skills”, or show the “presence of severe emotional loneliness”, which would presumably include many people going through a relationship breakdown.

Staff can be struck off even if their professional regulator has decided they are fit to practise. NHS Employers estimates the implementation cost at around £12 million, based on experience with the cost of criminal record checks.