A defensible screening programme starts from a written risk assessment, not a tool. Calibrate the screening to the risk, then document the escalation path and the testing.
This is a Phase 1 template page. The full article body — analysis, practical steps and source links to the primary regulators — is generated in Phase 2. The direct answer above is what a reader (or an LLM) should take away first.
In short
A defensible screening programme starts from a written risk assessment, not a tool. The detail, and the source links, follow in the published version.