Vetting Standard

Version. 1.0

Effective from. Monday 31 August 2026

Review. Annually.

Published at. bonsai.law/circle/vetting

1. Purpose

The Bonsai Circle is a network of professionals who agree to be introduced to each other, meet each other one to one, and share commercially and personally sensitive information under a strict confidentiality regime. This standard sets out, in full and on the record, what we do to satisfy ourselves as to who a person is and whether they are suitable to be a member.

This standard is applied without exception. It is applied on application and refreshed on renewal. It is published so that members and applicants can see exactly what has been done, and what has been done in respect of them.

2. What we check on application

2.1 Identity and address

Identity and current residential address are verified via Thirdfort, our identity verification provider. After you submit your application and authorise the £300 payment hold, we send a secure link to the mobile number you have given us. You complete the check on your phone.

Thirdfort performs remote photographic identification (passport, UK driving licence, or national identity card), address verification against a current dated document (utility bill, bank statement, council tax bill, or HMRC correspondence, dated within three months), liveness and biometric matching. Thirdfort operates to a KYC standard suitable for regulated professionals and holds current certification against the UK Digital Verification Services trust framework.

The Circle receives Thirdfort's completed report. We do not receive, store or handle uploaded copies of your identity or address documents; those remain within Thirdfort's platform and are handled under Thirdfort's data processing terms. This eliminates the risk of document tampering or unauthorised retention.

Cost is absorbed into the membership fee.

2.2 Basic DBS certificate via Responsible Organisation

Basic disclosure certificates are obtained by us, on your behalf, from a DBS Responsible Organisation registered with the Disclosure and Barring Service under the gov.uk Responsible Organisations scheme.

You consent to us obtaining the certificate on your behalf by ticking the DBS consent on the application form. The Responsible Organisation contacts you directly to complete the applicant portion of the DBS process, verifies your identity, submits the check to DBS, and returns the certificate directly to us. You never handle a paper certificate that we then process.

The Circle does not accept applicant-supplied certificates or copies. This is a deliberate design choice: it eliminates the risk of a forged, altered or substituted paper certificate. Every certificate we hold has verifiable provenance from the DBS via our Responsible Organisation.

The certificate discloses unspent convictions and conditional cautions only. Spent convictions do not appear and are not held against you.

Cost is absorbed into the membership fee.

2.3 Declaration of unspent convictions

You declare any unspent convictions and cautions in writing on the application form. The Rehabilitation of Offenders Act 1974 applies. Spent convictions do not need to be declared and are not held against you.

2.4 Previous professional names

You declare any previous professional name(s) used in the last ten years, together with the years used. This lets us run adverse-media and Companies House checks against names that would not otherwise appear.

2.5 Companies House

We run a Companies House search on your declared current and previous directorships via the free Companies House API. We look for disqualifications, unresolved compulsory strike-offs, and patterns of insolvent companies.

2.6 Adverse media

We run an adverse-media search against your name, previous names, and declared occupation via [Trust Verify or equivalent], current cost around £0.60 to £1 per applicant. We look for reporting of professional misconduct, serious civil litigation, regulatory action, and matters that would materially affect trust and safety in a small confidential membership.

2.7 Regulator check

Where your occupation is regulated by a professional body with a public register, we search the register for your current standing and any past findings. Regulators we routinely check include the Solicitors Regulation Authority, the Bar Standards Board, ICAEW, ACCA, CIOT, RICS, the Financial Conduct Authority, the General Medical Council, the General Dental Council, the Nursing and Midwifery Council, and equivalent bodies for your occupation.

2.8 References

Two written professional references from named referees. Referees must not be members of your household and must not be your current line manager unless we agree in advance. We take references up in writing and follow up by telephone where the referee has agreed to a call.

Referees are asked to comment on your reliability, judgement, and fitness for a peer network operating under strict confidentiality. Answers are held in your application file.

2.9 Sponsor interview

A structured interview, on a script, minuted. Conducted by a founder or a member the founders have appointed as a sponsor for that intake. The interview covers your professional background, your reasons for wanting to join, your understanding of the two-door meeting format, and your understanding of the confidentiality regime.

2.10 Signed acceptance and consent record

You sign the Terms of Membership, and acknowledge in writing that you have read the Vetting Standard, the Safeguarding Policy, the Confidentiality Regime, the Code of Conduct, the Forum Rules and the Privacy Notice.

Each acknowledgement is recorded against your application as a discrete consent event, and captures:

• the policy acknowledged;
• the policy version number;
• a content hash of the exact policy text at the time you ticked, so that any later amendment to that policy leaves a verifiable record of what you had in fact agreed to;
• the timestamp of the tick;
• the IP address and user-agent from which the tick was recorded.

On request, we produce a consent report showing exactly what you agreed to and when. This is available as of right under Article 15 UK GDPR. To request one, email bonsai.circle@bonsai.law with the subject line "Data Protection".

3. What we do with what we find

3.1 Decision

Approve, request more information, refuse. Decisions are taken by the founders jointly. Where founders disagree, refusal stands.

3.2 What causes refusal

Non-exhaustive:

• Failure or refusal to complete any part of the vetting.
• An unspent conviction for an offence involving dishonesty, violence, sexual conduct, or abuse of a position of trust.
• A regulatory finding of professional misconduct that has not, in our view, been adequately addressed.
• Adverse media that materially affects our confidence in the confidentiality regime.
• References that raise material concerns about reliability, judgement, or safety.
• A pattern of insolvent companies or an unspent disqualification.
• Any material inconsistency between what you have told us and what our checks find.

3.3 What does not, on its own, cause refusal

Non-exhaustive:

• A spent conviction.
• A single insolvency event, especially with plausible commercial context.
• A poorly-founded complaint that was not upheld.
• A personal-life matter that has no bearing on Circle activity.

3.4 Communication of decisions

We tell you the decision in writing. On refusal, we do not, as a rule, give reasons, because doing so would compromise our checks and our references. If you consider a refusal to have been made on discriminatory grounds contrary to the Equality Act 2010, you may write to us and we will consider that specific point.

3.5 Refunds

Fees are refunded in full subject to a £30 admin fee to cover the checks listed above on refusal within 14 days.

4. What we do on renewal, annually

• Fresh basic DBS, obtained by us on your behalf.
• Refreshed adverse-media search.
• Companies House re-check on declared directorships.
• Regulator re-check.
• Your written confirmation that nothing has changed on the original declarations, or specification of what has.
• Any changes trigger the same substantive analysis as an application.

Renewal is not a rubber stamp. Where fresh information would have caused refusal on application, it may cause refusal of renewal.

4A. Discretionary rejection grounds

Membership of the Circle is by invitation of the founders. The founders retain complete discretion over admission decisions. In addition to the standard vetting checks in section 4, the founders may decline an application on any of the following grounds without further justification.

4A.1 Adverse media findings

Where a Companies House, adverse media, DBS, sanctions or open-source check surfaces a matter that the founders consider material to the applicant's suitability for the Circle. Materiality is a matter of founder judgement, applied consistently. Founders may take into account the nature of the matter, its recency, the applicant's own account of it, and its bearing on the trust required for closed-room professional discussion under the Confidentiality Regime. The founders may but are not required to raise an adverse finding with the applicant before deciding.

4A.2 Values conflict

Where the founders form the view that an applicant's expressed values, positions or professional conduct are materially incompatible with the values on which the Circle is built.

The Circle is a small, professionally-moderated network built on mutual respect, the equal worth of members regardless of protected characteristic, civil discourse, and honest professional dealing. Applicants whose expressed views or conduct, from any source including their own website, published writing, social media, public speaking, professional record or the sponsor interview, deny the equal worth of any group, endorse cruelty to persons or animals, or would be materially disruptive to the Circle's culture, may be declined on those grounds.

This is a values assessment, not an identity assessment. No applicant is declined on the basis of a protected characteristic under the Equality Act 2010. The founders decline on the basis of expressed views and conduct.

4A.3 Consistency

The founders keep a short internal note against each decline decision under 4A recording the ground relied on and the material considered. The note sits with the vetting record and is retained for the period in the Retention Schedule. The purpose of the note is to allow the founders to apply 4A consistently across applicants over time; it is not a public reason record.

4A.4 Decision, reason and review

A decision to decline under 4A is communicated to the applicant in writing with a short reason of the founders' choosing. The applicant may request internal review by the other founder within 14 days of the decision. The review decision is final. The Circle does not maintain an external appeals process for admission decisions.

5. Continuous monitoring during a membership year

We rely on you to tell us within 30 days of:

• a change of employer or professional role;
• a regulatory investigation or finding against you;
• a caution, charge or conviction;
• an insolvency event affecting you or a company you direct;
• any bankruptcy, disqualification or restrictions order.

We may run refreshed adverse-media checks at any point during your membership year at our own cost. We do not do speculative surveillance beyond that.

6. Data handled under this standard

All vetting information sits under the Bonsai Law Ltd ICO registration and is processed in accordance with the Privacy Notice and the Appropriate Policy Document for criminal offence data. Retention periods are set out in the Data Retention Schedule.

7. Costs

Approximate per-member cost of the vetting stack, absorbed into the membership fee, not itemised:

All amounts are absorbed. No itemised cost is passed to the applicant beyond the annual membership fee, and the applicant pays no third-party invoice at any point in the process.

8. Governance

This standard is owned by Vanessa Challess. It is reviewed at least annually and immediately on any material regulatory change (for example, changes to the DBS scheme, to the Rehabilitation of Offenders Act, or to Schedule 1 DPA 2018).

9. Openness

We publish this standard in full. Applicants and members are entitled to know exactly what we do. Every member has been through the same door.