Changes to DBS Guidelines on Identity Verification
A Disclosure and Barring Service (DBS) check can allow individuals access to positions of trust, so it is essential that a DBS check is carried out on an individual’s true identity to enable the disclosure of all relevant information. In a bid to reduce any potential abuse of the system new guidance were released on the 28th May 2012 by the Criminal Record Bureau updating its identity checking guidelines. Registered bodies providing DBS checks have been given a three month period to comply with the new guidelines, with all registered bodies to be compliant by 1st September 2012. The guidance provides details of all the Routes that can be completed to confirm an applicant’s identity, what documents can be used in confirming the identity, along with how to precede if an applicant’s identity cannot be verified in line with the Criminal Record Bureau’s guidelines. Procedures are being made more robust by removing the use of documentary evidence that is considered to be from less reliable sources, with a total of twenty one documents being removed. Removing these documents aims to lower the risk of an individual using a fake identity to hide their criminal record. To counteract the possibility that the removal of these documents may exclude some applicants from obtaining a DBS check, due to not having sufficient approved documentation, the Criminal Records Bureau has introduced the ability to use external identity validation as part of Route 2. External identity validation is provided by a third party company which uses a wide range of electronic databases to independently validate the individual's identity.
Route One
All applicants must initially be considered for Route One.
Can the applicant produce a Group 1 document? If yes, then the applicant must produce 3 documents:
1 document from Group 1 (refer to list of Valid Identity Documents); and
2 further documents from Group 1, 2a or 2b; one of which must verify their current address.
Group 1 – Primary Trusted Identity Credentials
Current valid Passport.
Biometric Residence Permit (UK). Your biographic details (your name, and your date and place of birth); and your 'biometric information' (fingerprints and facial image). It also shows your immigration status and your entitlements while you are in the UK.
Current Driving Licence (UK) (Full or provisional) Isle of Man /Channel Islands;
Photo card only (a photo card is only valid if the individual presents it with the associated counterpart licence; except Jersey).
Birth Certificate (UK and Channel Islands) - issued at the time of birth;
Full or short form acceptable including those issued by UK authorities overseas, such as Embassies, High Commissions and HM Forces.
If the applicant has satisfied this route, then the document check is complete. If the applicant cannot produce a Group 1 document then go to Route Two.
NOTE – EEA Nationals (Non-UK):
Where an EEA National has been resident in the UK for five years or less, the Registered Body should validate identity via Route One through the checking of a Current Passport or Current UK Driving Licence (photo card only) plus 2 further documents.
In the absence of a Group 1 document the Registered Body must satisfy themselves of a valid reason for using Route 2.
Route Two
The applicant must produce: 3 documents from Group 2 comprising of;
1 document from Group 2a; and
2 further documents from Group 2a or 2b; one of which must verify their current address.
Group 2a – Trusted Government/State Issued Documents
Current UK Driving licence (old style paper version).
Current Non-UK Photo Driving Licence (valid only for applicants residing outside of the UK at time of application).
Birth Certificate (UK and Channel Islands) - (issued after the time of birth by the General Register Office/relevant authority i.e. Registrars.
Marriage/Civil Partnership Certificate (UK and Channel Islands).
Adoption Certificate (UK and Channel Islands).
HM Forces ID Card (UK).
Fire Arms Licence (UK and Channel Islands).
Group 2b – Financial/Social History Documents
Mortgage Statement (UK or EEA)** (Non-EEA statements must not be accepted).
Bank/Building Society Statement (UK or EEA)* (Non-EEA statements must not be accepted).
Bank/Building Society Account Opening Confirmation Letter (UK).
Credit Card Statement (UK or EEA)* (Non-EEA statements must not be accepted).
Financial Statement ** - e.g. pension, endowment, ISA (UK).
P45/P60 Statement **(UK & Channel Islands).
Council Tax Statement (UK & Channel Islands). **
Work Permit/Visa (UK) (UK Residence Permit). **
Letter of Sponsorship from future employment provider (Non-UK/Non-EEA only – valid only for applicants residing outside of the UK at time of application).
Utility Bill (UK)* – Not Mobile Telephone.
Benefit Statement* - e.g. Child Allowance, Pension.
A document from Central/ Local Government/ Government Agency/ Local Authority giving entitlement (UK & Channel Islands)*
and
The organisation conducting the ID check will then need to ensure an appropriate external ID validation service is used to check the applicant against their records to establish the applicant’s name and living history footprint.
If you have endeavoured to use Route Two, but have been unable to validate the applicant’s identity successfully, you may consider proceeding to Route Three.
Please be advised that Route Three should only be used in circumstances once you have fully explored with the applicant why their identity has not been successfully validated via Routes One or Two. To do this, you should hold a probing discussion with the applicant about the likely reasons why their identity has not been validated before considering using Route Three. You should keep a record of this discussion for internal purposes as it is the Registered Body’s responsibility to establish the true identity of the applicant through the examination of a range of documents as set out in this guidance.
Should you still be unable to validate the applicant’s identity using Routes One, Two or Three, then you should indicate this on the application form at Box W59 and return the form to the DBS. The applicant will then need to be sent for fingerprinting by the Police, which you should be aware is likely to cause delay to the DBS application process and subsequently to your recruitment processes.
Route Three
ALL Registered Bodies must have exhausted Route One and should have endeavoured to have accessed an external validation check (Route Two) before you consider processing them via Route Three.
If the applicant cannot meet the requirements of Route One and Two, you should have had a probing discussion with them to establish why they could not meet these requirements and whether there has been a recent or previous change of name that has not been declared.
For Route Three, the applicant must produce:
Birth certificate (UK and Channel Islands) – (issued after the time of birth by the General Register Office/relevant authority i.e. Registrars – Photocopies are not acceptable) and
4 further documents from Group 2 comprising of:
1 document from Group 2a; and
3 further documents from Group 2a or 2b; one of which must verify their current address.
If the applicant fails to produce the required document set at Route Three, they will need to be sent for fingerprinting by the Police which you should be aware is likely to cause delay to the DBS application process and subsequently to your recruitment processes.
What if I cannot establish the applicant’s ID using one of the three routes?
If you or your ID checker cannot establish an applicant’s identity in accordance with DBS ID guidelines then you should mark W59 on the application form with a NO. Applicants who are unable to provide the required documents will then be asked to give their consent to have their fingerprints taken in line with the current procedure. Registered Bodies should be aware that this will require attendance by the applicant at a Police Station at an appointed time, and may add delay to the overall application process.
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