Forensic questionnaires that dig into applicants' private lives may not always be pleasant, but for an organisation of immense public interest like the FA it's an eminently sensible step. The FA must protect its integrity and its reputation in order to regulate the game effectively. Certainly the elevated pressure and public scrutiny that come with the role of England manager underline the need for stringent checks, not least to avoid the disruption of losing another manager in such a short space of time. Widespread background checks might also have helped to uncover the recent allegations of sexual abuse much sooner.
This move is not about ensuring that all FA employees are paragons of virtue who share Gareth Southgate's school prefect vibe, but about understanding the risks each new member of the team carries so you can mitigate them. That might mean additional training or support, cleaning up an online profile or testing a candidate further on certain issues — such as previous displays of poor judgement.
It is also sensible for an independent third party to carry out the checks. That provides a degree of distance from any internal pressures within the FA and should come with expert knowledge on a complex area of law – including human rights, data protection and employment law.
This is important because the FA will have to balance achieving its aims — ensuring the safety of players and staff and protecting its reputation — with the applicant's right to privacy. The FA is no doubt seeking candidates' consent for these enhanced checks, but it is unlikely to get consent from every family member and friend. Using external consultants doesn't mean that the FA can abdicate responsibility either. It will need to ensure that information gleaned is used fairly and lawfully, since any employer who gains information about an applicant's personal life could face allegations of discrimination if there are suspicions that details of the applicant's sexual orientation, for example, influenced the hiring process. Checks on family and friends could potentially found claims for associative discrimination. Navigating the legal and reputational risks is far from easy.
And the FA would do well to keep in mind that enhanced background checks, although welcome, are not a panacea. As the FA have identified, the allegations that cost Allardyce his job and threw the organisation into crisis mode did not stem from his past conduct. On their own, deeper investigations of prospective employees won't protect an organisation from future reputational damage or subsequent transgressions.
Focusing solely on damage limitation won't be sufficient either. Real and genuine change on the part of the FA — to understand its employees and stakeholders, to build an environment which promotes openness and collaboration, does not apportion blame — will do far more to protect and enhance its reputation than engaging external consultants.
That is a much bigger, longer-term challenge. But background checks are a necessary first step to creating a scandal-free organisation.