The association has outlined the concerns in its response to Making Safeguarding Everybody's Business: A Post-Bichard Vetting Scheme, a consultation that ended last week.
The Department for Education and Skills asked for feedback on its proposal to create a central register of everyone working with children, young people and vulnerable adults within the next two years.
The register would include a list of those barred from working with children and young people in voluntary work, as well as paid employment. It would be accessible to employers, as well as individuals who employ carers privately such as parents.
But the association describes the scheme as "overly bureaucratic", arguing that the technology does not exist to support it.
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