Verifying the applicant's identity

When the applicant has completed their Application Form, they must then show you their identity documentation for you to review. 

The list of acceptable documents can be viewed here.

When checking the applicant's documents you should have their application form in front of you, so that you can compare the information from their documents against the information they have entered on their application form. If this isn't possible for whatever reason, you should take copies of the documents and compare them as soon as you can.

The accuracy of the ID checking and address validation process is crucial to the effectiveness of the disclosure process and directly impacts the integrity of the disclosure result. A poor or inaccurate ID check will result in a worthless disclosure being issued.

The Recruiter MUST:

• Only accept valid original documentation.
• See at least one document in the applicant’s current name.
• See at least one document which confirms the applicant’s date of birth.
• Make sure that any details of current and valid passport, driving licence and National Insurance Number are included on the application form.
• Follow the three route ID checking guidance set here.
• Seek photographic identity documents (passport, driving licence, e-Visa or PASS card) in the first instance. This can be used to compare the applicant’s likeness. Check and validate the information provided on the application form by the applicant.
• Check that the application form is completed in full and the information it contains is accurate.  For example, that all addresses lived at in the last 5 years and names known by have been declared and are accurate. Failure to do this can result in delays in processing and the withdrawal of applications.
• Make sure the applicant fills in the address part of the form correctly if they have an unusual address, for example if they live abroad, in student accommodation or a hostel.
• Use a document type only once in the document count. For example, don’t accept two bank statements as two of the required documents if they are from the same bank
• Not alter or amend the application form without the knowledge or agreement of the applicant.
• Make notes if there were any discrepancies discussed as part of the ID verification process
• See relevant documentation to validate a name change (e.g. a marriage certificate/deed poll/civil partnership certificate/divorce decree absolute or civil partnership dissolution certificate).

The Recruiter MUST NOT:

• Check ID for yourself or an applicant related to you (ask another recruiter for your organisation to do this).
• Accept photocopies of any identification documents.
• Accept documents which don't meet the ID checking rules (e.g. a utility bill that is more than three months old, or an out-of-date passport).
• Accept documentation printed from the internet e.g. online bank statements.
• Accept the foreign equivalent of an identity document if that document is listed as ‘UK’ on the list of valid identity documents.

You should cross-match all identity and proof of address documents with the information provided on the disclosure application form and any other information you have been provided with as part of the recruitment process such as their CV (name, previous names, date and place of birth, address etc.), and compare any photo ID against the applicant's likeness.

This can highlight if important information has not been given e.g. if the applicant’s CV shows that they have worked in Liverpool in the last five years but the application form only shows London addresses, you may wish to question the applicant further about this.

If the applicant is unable to provide proof of a name change, then the DBS states that you must have a probing discussion to ascertain why they are unable to show this evidence.

Further information and advice around checking ID can be found at:https://thirtyoneeight.org/help-and-resources/ebulk-recruiter-resources/dbs-id-checking-requirements/ 

Three options for seeing the applicants documents

Option one

The ID check should be done in person, allowing the ID checker to view the physical documents, or eVisa, or digital PASS card, in the presence of the individual.

If you cannot use option 1, please consider using digital identity verification before considering option 2.

Option two

The Recruiter can conduct the ID check via video link – for example Zoom. In these circumstances the Recruiter must be in possession of the physical documents. These can be posted to the Recruiter in advance of the virtual call. Any risks identified when using live video must be assessed and mitigated by you. You must not rely on the inspection of the documents via a live video link, or by checking a faxed or scanned copy of the document.

If option two is used, you must record on the ID check section of online application record of why option one was impossible. The rationale must be specific to the individual ID verification.

Option three

The ID check can be completed via video link – for example Zoom – without the Recruiter being in physical possession of the ID documents. The details of the documents, as set out above, must be recorded and stored at the time of the video call. The documents must be presented to the Recruiter on the first day of employment or volunteering. The Recruiter must record the date the ID check was completed in person and cross reference the details recorded from the video link ID check. If there are any discrepancies the DBS check may be invalid.

If option three is used you must record on the ID check section of online application record of why option two were impossible. The rationale must be specific to the individual ID verification.

For any questions about the DBS process call our Disclosure Helpline, Mon-Fri, 9am-5pm on 0303 003 1111.