No, Rooney, I think you're wrong. As I understand it, this amendment applies only to the those organisations and companies providing Air Traffic Services and certain security services to or on behalf of the CAA, and not to airlines or other customers of the CAA.
In any case, in my experience, no pilots have been asked by the airlines or by BAA (or other airport operator) for greater than Basic Disclosure. That is the crux of the matter.
Scroggs