Vetting candidates for club membership

A club is nothing without its members; and it is understandable why clubs are preoccupied with recruitment. Given deaths and resignations, clubs need to recruit members just to stand still – that remains true whether a club has a quick turnaround in electing applicants after just a few weeks, or maintains a decades-long waiting list. But there are few more important functions than the vetting stage. What follows is written primarily from an English perspective, but the underlying issues are faced by clubs worldwide. It draws not only on my work around clubs, but on my professional background as a practising investigative journalist, including training from open-source intelligence specialists Bellingcat.

Why does vetting matter so much?

There are several reasons why vetting is so important. Firstly, clubs can very quickly run into serious trouble if they have not adequately vetted applicants. It is all too easy to exclude an applicant in the first place; but once somebody has been elected, it is in practice nigh-on impossible to expel someone who chooses to put up a fight, given the exorbitant cost of resorting to litigation. Even if a club’s decisions and processes are fully vindicated at the end of a lengthy set of appeals, the Club can still find itself poorer by a six- or seven-figure sum in legal fees that it will never recover. Accordingly, it is not only good practice for a club to make an informed decision on membership candidates – it is also significantly cheaper in the long run. This is why proper vetting is an area where clubs should not economise, in either time or money.

Secondly, clubs have reputations to preserve. Each club is composed of members, staff and premises, and each of those three components (as well as the Club overall) has to have its reputation protected.

Thirdly, clubs have an obligation to protect their members and staff as individuals – they are unlikely to knowingly elect an axe-murderer or a convicted fraudster, and so they could be seen as negligent if they had not conducted some basic background checks prior to a member’s election. The Club therefore is vulnerable to a measure of liability towards its members and staff; and its due diligence needs to be considered in that light. Clubs that believe, “But it’s unthinkable for there to be a problem with anyone proposed at our club” are often the most susceptible to this problem.

And fourthly, there is a much less dramatic factor at play in any club: conviviality. The yardstick for most clubs, from the most secretive St. James’s establishment to the most informal working men’s club, is simply “Would we find this person agreeable company to have around, for a chat over a drink?” That is a purely subjective concept, and a candidate who might be considered the life and soul of the party in one club may still be persona non grata in another. It can come down to something as simple as personality clashes. And candidates can be refused entry simply for being thought boring, or overly obsessive in always talking about the same subject. The legal textbook Ashton & Reid on Clubs and Associations emphasises that while there can be no question of illegal discrimination in recruitment, the concept of legal discrimination is central to any club that is not open to the general public, and it has this to say:

“the members of a club admit to membership those whom they find congenial by reason of mutual interests, sporting ability, adherence to political persuasion or whatever. There is nothing to prevent the members of a club excluding applicants for membership for reasons which to an outside observer may seem completely unreasonable, provided such exclusion has not been prohibited by Parliament.”

Who vets?

Different clubs have different structures to deal with vetting. Sometimes it is done by an entire committee of members, sometimes a handful of members are elected or nominated specifically to play a scrutineering role, sometimes it is delegated to club staff who have been trained in this area, and sometimes it is outsourced to professionals. (Full disclosure: I have in the past undertaken the first, second and fourth of these roles myself.)

The precise structure is not so important as a clear mandate being given for this sort of enquiry to those undertaking it; a keen adherence to the most relevant parts of applicable law (in the UK, this would be the laws around data protection, data processing, data storage, privacy, defamation, and equality); and clear processes and policies being in place.

What does vetting look for?

Candidate vetting to a social club typically looks for anything which the Committee might reasonably need to factor in, when reaching a decision on whether to elect someone. That can cover a broad range, but some obvious questions come to mind: Is there anything in this person’s past which suggests they might potentially be particularly disagreeable? Do they have any unspent criminal convictions? Do they pose a potential threat to the wellbeing of members or staff? Might their association with the Club potentially cause the Club some embarrassment? Obviously, the applicant who has an unspent criminal conviction and press publicity for assaulting someone in a bar is unlikely to do well by such yardsticks, however witty a conversationalist they may be.

Note the emphasis on potential difficulties. A club undertaking vetting should not seek to make bold predictions on whether someone will or will not behave in a particular way; they simply need to decide whether there might be reasonable grounds to raise any doubts at the appropriate stage, supported by evidence.

It is also worth looking at the Club’s own aims and objects. For some clubs, these are very clear: travel, sports, arts, sciences, politics, vocations, etc. However, for many social clubs, there may not be a formally-defined object, but there will most certainly be a distinctive culture that is widely-recognised among the membership. There needs to be a keen appreciation of that by those undertaking the vetting, to address the question, “Would this candidate be likely to uphold the Club’s objects and culture?” This is particularly the case when dealing with status-seeking applicants who are keen to secure election to a prestigious club, presumably on the assumption it will raise their social standing, rather than having any real interest in the Club or what it represents. Electing such members can seriously dilute the very raison d’être of a club, particularly if done in large numbers over time; so it is entirely legitimate, for instance, for an arts club to look into whether the candidate has a history of publicly berating and belittling the role of the arts - whatever they may say in their application form.

Proportionality

Above all, there needs to be a doctrine of proportionality in everything that is done in the course of background checks. Clubs need to be mindful of their responsibilities to act fairly, particularly (as noted by Ashton & Reid) with regards to any risk of unlawful discrimination. It is justifiable to probe in more detail substantive issues that may have come up in initial enquiries, but they must always be done without prejudice – in England and Wales, the Equality Act 2010 particularly applies, not only with regards to its specific terms around protected characteristics, but also its overarching principles. With that in mind, a club can proceed to how it does its checks.

It is also worth bearing in mind that when someone has filed an application with a club, they have accepted – implicitly or explicitly – that the Club may need to perform background checks to admit them. Provided that the information raised is not used for anything other than assessing their application, that is an entirely reasonable and proportionate course of action.

The form

The most obvious source for queries is the written information provided by the candidate themselves, on their application form. This is why the Club needs to give serious consideration to the scope and content of the form. While its objective should not be to catch anyone out, it should yield enough information that any embellishments, exaggerations, omissions or outright lies can be easily detected.

It is also important for the application form to be put on the right footing: it is increasingly common for club rules to include a stipulation that any false or misleading information on the original application form shall constitute a breach of the terms of membership, and grounds for expulsion. This therefore raises the importance of full and accurate information in the application form, with a clear paper trail. It further gives compelling grounds for the retention of old application forms, in a retrievable format.

The initial search

The information environment has also changed a great deal from, say, twenty years ago, when the standard response might have been, “Surely a Google search might seem a little overzealous?”, to today's environment of widespread information in the public domain, where an entirely natural question would be, “You mean, you didn't even do a Google search, when all this information is readily available to anyone who looks? Why did nobody check?” Occasionally, such simple checks can throw up apparently-concerning information.

If any issues or lines of enquiry are thrown up from the initial cursory probes, then it is entirely reasonable to follow through and dig a little deeper, making further enquiries. Therefore every applicant is subjected to some basic checks, and if these raise any questions, then further, more detailed enquiries may be wise. Such decisions should be evidence-led, i.e. “Something about the address supplied doesn’t quite figure - and they’re using this address to apply for a country membership discount”, or “We’re not entirely sure it’s the same person, but somebody of that name was involved in a serious crime a few years ago.”

Some helpful sources and approaches

There are a number of public domain sources that can be consulted, using information which is already out there. The public domain aspect is important – the vetting process should not look at “secret” sources. In the early stages of vetting, clubs should more typically be looking for something that protects them as a club against a charge that they did not consider information which was already out in the open, when they might reasonably have been expected to check for that.

A club might start with a simple online search.

Google is not the only search engine; although because of its omnipresence and widespread use, it may be as good as any to start with. And using it covers the “Didn’t you even do a Google search?” test. Yet it has its limitations. It is also not set in stone – it is constantly shifting, and as well as new results coming up, and older ones disappearing or becoming less prominent, the order and prominence of its listings varies, often depending on things like the location of the person conducting the search.

If Google proves unilluminating, it can be useful to use a different search engine. Investigative journalists often use DuckDuckGo, which uses a very different algorithm and so can throw up results not always found in Google.

Search engines can help in other ways. If you visit a search engine and start typing in a name, it uses autocomplete to suggest possible extra words, related to that topic. This is influenced by common word searches made by other users in relation to the words you have already entered. So if you enter “john smith”, it may suggest “john smith world famous novelist”, or it may suggest “john smith notorious axe murderer”. The autocomplete suggestions may give some clues as to any outstanding issues to be looked into, based on common word associations.

When dealing with search engine results, it is worth being sure that you have the right person. Have they used a variant of their name? Are they being mistaken for somebody with the same name, or a similar one? Remember that the use of quotation marks around a name in a search engine can be both a help and a hindrance in searching for an exact phrase, but also excluding other potentially relevant results. If you search for the exact phrase, in quotation marks, you are much more likely to find references to the intended person (unless it is an extremely common name, like “John Smith”). But you may also find it helpful to search for just one of their names, particularly if they have a distinctive first name or last name – while that carries the risk of also bringing up extraneous results for unrelated people, it can also bring up extra sources, like press coverage which only refers to the candidate by one name. So for instance, you may search for “dr seth thevoz”, “seth thevoz”, “seth alexander thevoz”, and just “thevoz”, and each may bring up very different results. Similarly, it is worth a vetting body familiarising itself with Boolean searches – never underestimate how many millions of people routinely use search engines, yet are unaware of how to use the full range of functions of search engines.

Press coverage will vary wildly, but you can use Google's ‘News’ search function to search for press coverage involving a candidate. Often, small local outlets will give far more coverage to relatively unknown figures, compared to national or international newspapers. Performing such searches thoroughly may involve a considerable financial outlay in subscriptions, to get behind a paywall for the most relevant information. Subscription tools such as LexisNexis will also give more specific news searches, for example around trade presses.

If you find an interesting source – let us say, a press story that mentions the candidate – it can also be worth searching for that source being cited elsewhere. For instance, you can highlight the URL address of the press story, right-click to “copy” that, then go to a search engine, and “paste” in the address into the search bar, and hit “enter”. That would then throw up instances where the news story itself has been cited and linked, even if the candidate is not mentioned by name (which means it would not have come up in a simple Google search for the candidate's name), and that can give a better understanding of any wider reputational issues around the coverage.

Candidates are often asked in their application forms for their CV particulars, so if the Club has been given this information, it is reasonable to check that the details are consistent with what the candidate has circulated elsewhere. Many/most professionals have a LinkedIn account, and a quick browse can show if their LinkedIn CV differs markedly from what they have told the Club on their application form. Do the start and end dates for jobs tally? Is employment omitted? Are there any CV gaps? These are reasonable questions to ask.

People also work through companies as well as individuals, so a quick check of the Companies House website often yields some straightforward information, which may corroborate or contradict what is in their application. They may trade through a small company which is basically an extension of themselves – particularly if it is a one-person company – so you can check that everything is in order with that firm, and that there are no obvious “red flags”, like a confirmation statement which is a year overdue, or a string of dissolved companies behind them. These may not be unlawful (while failure to file a confirmation statement is a criminal offence, liability may not always rest with the company’s directors – they may have diligently filed on time, and Companies House simply failed to process the paperwork), but they may be causes for concern which are worth checking. Or they may have been “named and shamed” by HMRC on the publicly-visible current list of deliberate tax defaulters.

If someone is an employer, you can check their company on Glassdoor, where former employees can leave reviews – positive and negative – on aspects like the working conditions of a former employer; while subjective, these reviews can sometimes be revealing. “A wonderful workplace experience” is very different feedback to half-a-dozen people all claiming, “There was endemic bullying at this small employer.”

Applicants will often have some form of social media output, so a quick check of this may show any signs of views not compatible with the Club's values set out in its Objects – for instance, have they been posting selfies of themselves attending a violent riot, or have they expressed support for a proscribed terrorist organisation? Twitter, Facebook, and Instagram (both as apps as well as websites) are the most common platforms to check, although there will be others, such as Mastodon and Bluesky. This will be particularly important with younger applicants, because they may have a much smaller “online footprint” (in terms of websites detailing past jobs, etc), so their postings on social media can often be the strongest public source on that candidate, in the absence of a more extensive CV on LinkedIn, for instance. They may have a “private” profile with hidden postings, and there is nothing you can (or should) do to get around that – and it should not be inferred that there is anything wrong with that, either; plenty of people simply prefer their privacy. But many people have publicly-visible profiles and postings on social media, and again, it is the public domain information which should be of interest. Is the information which they present of themselves in their application consistent with what they say on social media?

Another part of social media is with video channels. Do they have a YouTube or Tik-Tok channel? Do they regularly post videos on their views, raising anything concerning, which may not be compatible with the objects or culture of the Club? Have they given YouTube interviews to others? Video sites like YouTube and TikTok (and to a lesser extent, Instagram) differ from other sources listed here, which are typically in written form – and so for that reason, those conducting vetting will need to remember to be cautious against any unconscious bias in how someone puts themselves across onscreen. The Club should be interested in what they are saying, not how they say it. But people are very often more candid, and less guarded, in conversation on video, which can make this a useful medium to check.

Generally speaking, a candidate is judged on their own merits; but this gets more complicated if, for instance, they are seen to keep questionable company. Someone who was regularly photographed in the tabloids attending what are widely represented as louche parties, for instance, may well be of impeccable character and have conducted themselves with decorum at all times; but the publicity connecting them to others may still carry an obvious reputational risk to the Club. Against that, they may answer any questions with laudable honesty as to a past chapter of their life, in company they are keen to distance themselves from. How this is handled in part depends upon how online searches bring up information, and whom it reflects well or badly upon. This is part of the nature of vetting: you cannot control what information around the candidate is already in the public domain. Context is everything, and so you may find yourself broadening your search to wider groups or individuals connected to the candidate. Caution needs to be taken here, and any link needs to be strong, and evidence-based.

If a candidate belongs to a profession that is regulated, it may be worth checking with the organisations which play a regulatory role in their industry, who will often keep a public domain directory online; for instance, you can check with the Law Society website that a solicitor is in good standing, or with the Bar Standards Board website for a barrister; or for doctors, you can consult the General Medical Council database; or for those providing financial services in the UK, the Financial Conduct Authority’s Financial Services Register; or in the case of lobbyists, the Office of the Consultant Registrar of Lobbying's register will show whether they are registered, and if so, which clients they have declared lobbying on behalf of. The relevant body will depend on the profession and jurisdiction.

If there are concerns about past brushes with the law, you can always check court rulings in both civil and criminal cases – both Bailii and the National Archives’ case law search are particularly helpful for live civil judgements in England and Wales. The UK also keeps a public-access bankruptcy and insolvency register, listing undischarged bankrupts. Again, given the need for proportionality, you might not go straight here in the first instance for every candidate – but if there are any financial questions raised (for instance, a string of dissolved companies), it can be worth double-checking with the bankruptcy register.

Has the applicant ever served as a trustee of a charity? If so, you can check the charity's listing on the Charity Commission website, to see that they have filed their accounts on time, and to view those accounts, as well as to see a list of any other charities they are currently a trustee of. Otherwise, if they've been active in other, non-charitable organisations, the website of that organisation may yield more information, for instance through annual accounts, annual reports, etc.

Any titles and credentials claimed by the candidate are also worth verifying; you may be surprised at how common it is to find embellishment in this area, particularly among those seeking election to a prestigious club. For instance, I use the post-nominals FRHistS – these can be verified by anyone visiting the Royal Historical Society website, where the current fellowship and membership are listed; most learned societies do the same. Similarly, any styles and titles can easily be cross-checked – for instance, verifying inclusion in a past honours list on The Gazette website, rather than someone having “bought a plot of land in Scotland that makes me a real [sic] Lord.”

All this gives some idea of the avenues of inquiry that can be pursued, and the wealth of public domain information which can be gleaned on the vast majority of candidates, simply from their digital footprint in the public domain, which may confirm or contradict the particulars in their application form. It is by no means a comprehensive appraisal of the public domain sources of information open to those conducting such checks - there are many more possible avenues of enquiry.

Remember, if the information is already out there, then sooner or later, any questions arising from it may come up – so it is better for the Club’s Committee to be able to say that they considered all issues from the outset, than for the Club to be caught unawares by undiscovered issues, later on.

What should be done with the information gleaned?

This is a very important point. The vast majority of cases do not throw up any evidence or findings that are remotely concerning; but a small minority of cases may turn out to raise some findings that are very concerning indeed. It is for that reason that all findings need to be handled with great sensitivity.

Firstly, confidentiality must be paramount. The information should only be shared with the Club’s Committee tasked with making the decision on whether to elect or not to elect. The Committee needs to be keenly aware of its responsibilities around privacy and data protection, in not sharing that information any further, even within other bodies in the Club, if they do not have a directly relevant remit. (Defamation law is of supreme relevance in this area. If there are adverse findings, it must be borne in mind that under English law, even a single dissemination could theoretically constitute publication and therefore give rise to an action for libel. In practice, however, recent judgements such as Amersi v Leslie have shown the courts to be extremely reluctant to take up cases involving a negligible number of recipients; and so it is desirable for all handling of such sensitive material to severely curtail any information-sharing to only those directly involved in an active decision-making. If in doubt, never hesitate to seek proper legal advice.) Those doing the vetting, and those on the Committee, are not seeking to make any public representation. That is why outputs must be restricted to the Committee.

Secondly, any report needs to be clear and well-sourced, and any recommendations should be evidence-based. Findings should avoid sensationalism or strong opinion, and should be measured, sticking to the facts, and to what is or is not known.

Thirdly, there is the question of whether the candidate merits an interview in light of the findings. Some clubs insist on interviewing all candidates. Other clubs insist on never interviewing any candidate. Many clubs fit somewhere in between, only interviewing a candidate if there is something they specifically wish to clear up. There is no ‘best’ solution for all scenarios. If you do want to hold an interview, then the best argument for it is to give the candidate a right of reply – there may be some simple misunderstanding, or mere ambiguity, which they can clear up over a five-minute chat. Against that, the strongest reason against holding an interview is that the line of questioning will strongly hint at the reasons for declining an application, should that candidate be rejected – and so the interview may be counter-productive. If there is an interview, there needs to be a strong sense among the interviewers of why it is being held, how it can be held fairly, and provision for a succinct written report for the Committee.

Fourthly, the Committee will ultimately have to plough through all the available information to reach a decision. They will decide the spirit and framing of the discussion, and the final decision. The outcome of the ballot should be swiftly communicated to the candidate – but only whether it was successful or unsuccessful. On no account whatsoever should a Committee ever be drawn into giving vote breakdowns, feedback, or its own reasoning for its decision – even if the candidate asks for it, and if it seems an innocent request. While this can seem harsh, to do otherwise would be to invite disgruntled candidates to try to bully and litigate their way into a club. That is why clubs have a strict policy of only giving an outcome: whether or not a candidate attracted enough support to secure election.

Finally, there needs to be a recognition that the information from vetting has a time-limited purpose, around the election decision. While the Club may choose to archive all application forms (for which it needs a strict archiving policy, compliant with data protection laws), it is strongly recommended to not retain any copies of vetting materials, once the decision has been reached. This is because the data will have been processed with a specific purpose in mind, and that purpose will have elapsed once a vote has been held on the member’s application. Given that the potential for privacy issues is much greater than with the simple archiving of application forms, there is a strong case for the destruction of all copies of any vetting information after the ballot.

Remember, rigorous vetting helps preserve a club’s culture and reputation, and keeps the Club (and its members and staff) safe – but it needs to be done with the greatest of caution, even-handedness, thoroughness and professionalism.

Last year, I joined a discussion on the ‘Private Club Radio’ podcast in the US, with host Denny Corby, and experienced club vetting professional Paul Dank, for a detailed discussion on this topic - you can listen to the episode here.

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