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Catholic Safeguarding Advisory Service (CSAS)Procedures Manual

11B Home Office Guidance on ID Verification Process/Checking the Accuracy of Documentation

Guidance on ID Verification Process

What is the process for verifying an applicant’s identity?

Can any of the 3 routes be used to verify the identity of a DBS applicant?

What is Route 1?

What if the applicant cannot produce a Group 1 acceptable document?

What if the applicant has insufficient documents for Route 2 or the external ID check cannot validate the person’s identity (namely produce a “Fail” result)?

What if the applicant has no acceptable Group 1 or Group 2a/2b documents and therefore Route 1, 2 and 3 are not able to validate the applicant’s identity?

How can I explain and reassure an applicant about the ID verification process used by the Church?

I am really confused about the 3 routes and which route should be used in which scenario. Is there any other information I can access?

What about Non-EEA Nationals who require a DBS Disclosure?

What about EEA Nationals (Non-UK)?

Are members of Clergy or Religious required to undertake the ID verification process?

What about 16 - 19 year old applicants in full-time education?

Is there a charge for fingerprinting and if so, who pays it?

How long are the fingerprints retained for?

Will there be any change to the fee currently charged for a DBS Disclosure check?

Guidance Regarding How to Check the Accuracy of Original ID Documentation

How can I check driving licences?

What if the applicant has been adopted?

What if the applicant has changed their name recently and cannot provide ID documents in this new name?

The DBS application form can only hold 3 name changes. What do I do for applicants who have changed their name more than 3 times?

What should a Registered Body do if they suspect false identity or documents?

How do I check for indicators of fraud?

How do I check a passport?

How do I check a photo driving licence?

How do I check an old style driving licence (no photograph)?

How do I check a birth certificate?

How do I check an EU Photo Identity Card?

How do I check an HM Forces ID card?

How do I check a firearms licence?

What about other forms of identification?

Where can I find information about checking Biometric Residence Permits?

Is there any other information available concerning European documents?

 

Guidance on ID Verification Process

What is the process for verifying an applicant’s identity?

As of 28th May 2012, there are 3 routes available.

It is important that every applicant is attempted to be ID checked via Route 1 initially, should they have insufficient documents available, then Route 2 must be considered and Route 3 should only be used if Routes 1 and 2 are not possible or the external ID validation check (under Route 2) has been obtained and a “Fail” result produced.


Can any of the 3 routes be used to verify the identity of a DBS applicant?

No. It is a requirement of the DBS that every Registered Body exhausts Route 1 and should endeavour to complete Route 2 before Route 3 is considered.


What is Route 1?

  1. Establish if the applicant can produce a Group 1 acceptable document;
  2. If the applicant has a Group 1 document, then they must also produce a further 2 documents from either Group 1; Group 2a or Group 2b document types;
  3. One of these documents MUST verify their current address;
  4. If all of the above requirements are met, then the ID is successfully validated via Route 1;
  5. The ID Verification form should be completed indicating the original documents produced; ensuring they are valid, in date and show no signs of tampering or fraud;
  6. The original documents must then be photocopied and sent to the Counter-Signatory with the completed and signed ID Verification form;
  7. In successful Route 1 cases, the ID Verifier should clearly print their name in line W58 of the rear page of the DBS application form and also cross “Yes” at Line W59.


What if the applicant cannot produce a Group 1 acceptable document?

Then Route 2 must be pursued.

  1. Establish if the applicant can produce 3 documents from Group 2 comprising of:
    1. 1 document from Group 2a; AND
    2. 2 further documents from Group 2a or 2b.
  2. One of these documents MUST verify their current address;
  3. If all of the above requirements are met, then the ID Verification form should be completed indicating the original documents produced; ensuring they are valid, in date and show no signs of tampering or fraud;
  4. The original documents must then be photocopied and sent to the Counter-Signatory with the completed and signed ID Verification form. PLEASE NOTE:  ROUTE 2 IS NOT YET COMPLETE AS THIS ROUTE REQUIRES THAT AN “EXTERNAL ID VALIDATION CHECK” IS UNDERTAKEN WHICH IS CARRIED OUT BY OR ON BEHALF OF THE COUNTER-SIGNATORY;
  5. The DBS Application form should NOT be completed on lines W58 and W59 by the ID verifier (at local level) as the identity of the applicant has not yet satisfied the entire Route 2 process;
  6. Once the Counter-Signatory receives the completed and signed ID Verification Form; the DBS application form (with lines W58 and W59 left blank) and photocopies of documents produced, they will access the online ID check service (provided by GB Group Ltd). The online ID check meets the HMG Level 2 (Remote) standard as stipulated by the Cabinet Office. The applicant’s consent must be obtained before the online ID check can be carried out and the consent is contained within the Declaration of the ID Verification Form (version dated August 2012);

In the event that a pre-August 2012 Catholic Church ID Verification form is completed in error and an external ID check is necessary to fully validate the applicant’s identity, the applicant must then complete the Supplementary Consent Form (Forms Library) before the external ID check can be undertaken.

  1. The online ID check service will provide an instantaneous “Pass” or “Fail” result to the applicant’s full name; date of birth; current and former addresses (where relevant) and any other applicant supplied information by comparing the data input against a range of independent, external data sources i.e. Electoral Roll. Where possible, in order to increase the likelihood of obtaining a Pass result, the bank account number (8 digits) and sortcode AND/OR Electricity Supply Meter Number should be obtained from the applicant.
  2. The online ID check should only need to be conducted once per DBS application and a record of the online check will be retained by the Counter-Signatory (per our Safe Storage; Handling & Retention Policy) to evidence correct ID verification practice  to the DBS.
  3. Once the online ID check has been carried out and the check produces a “PASS” result, then the Counter-Signatory completes line W58 and W59 as the applicant’s identity has then successfully been validated via Route 2.


What if the applicant has insufficient documents for Route 2 or the external ID check cannot validate the person’s identity (namely produce a “Fail” result)?

Then Route 3 must be pursued.

Route 3 should ONLY be used in circumstances once you have fully explored with the applicant why their identity has not been successfully validated via Routes 1 or 2. It requires that the Counter-Signatory have a discussion with the applicant about the possible reasons why the applicant’s identity has not been successfully validated (for example a married woman who has no utilities in her name and perhaps only appears on the Electoral Roll). A record of the discussion must be kept for internal purposes as the Registered Body is solely responsible for establishing the true identity of the applicant through the examination of a range of documents and therefore must take appropriate measures to record key discussions that occur within the recruitment process.

  1. The applicant must produce a Birth Certificate (UK and Channel Islands) which can be issued after the time of birth by the General Register Office;
  2. This must be accompanied by 4 further documents from Group 2a or 2b:
    1. 1 document from Group 2a; AND
    2. 3 further documents from Group 2a or 2b.
  3. One of these documents MUST verify their current address;
  4. If all of the above requirements are met, then the ID Verification form should be completed indicating the original documents produced; ensuring they are valid, in date and show no signs of tampering or fraud;
  5. It is important to note that if Route 3 is pursued following a failed external ID check result, then the Counter-Signatory must decide if they wish to see the original Route 3 documents themselves or notify the ID verifier of the pursuit of Route 3 so they complete a new ID Verification Form accordingly to accompany the document photocopies. In such cases the Counter-Signatory completes lines W58 and W59;
  6. If Route 3 is pursued because the individual cannot supply sufficient documents to satisfy Route 1 or pursue the external ID check via Route 2, then the ID Verifier must notify the Counter-Signatory in the first instance so the appropriate discussion can be had (refer to first paragraph of this section concerning the discussion and its purpose) BEFORE Route 3 documents are provided and checked. If the ID Verifier sees original satisfactory Route 3 documents, then the ID Verifier can complete lines W58 and W59 before sending the completed forms (including the DBS application) to the Counter-Signatory.


What if the applicant has no acceptable Group 1 or Group 2a/2b documents and therefore Route 1, 2 and 3 are not able to validate the applicant’s identity?

In such instances, the ID Verification Form should be completed by the ID Verifier indicating that the individual has insufficient documents available. This should be sent with the DBS Application Form to the Counter-Signatory. The Counter-Signatory may then wish to have a discussion with the applicant about the reasons for the lack of available ID documentation. Following that discussion, if the DBS application is to proceed, the Counter-Signatory completes line W58 and clearly marks line W59 as “NO”. 

Applicants who are unable to provide the required documents will then be asked by the DBS to give their consent to have their fingerprints taken. This will require attendance by the applicant at a Police Station at an appointed time. The DBS will organise this and notify the applicant upon receipt of the completed DBS Application form. The requirement for fingerprinting in such cases will inevitably cause delay to the DBS application process and the subsequent recruitment & selection process for the Church/ “Employer”.


How can I explain and reassure an applicant about the ID verification process used by the Church?

CSAS has produced a single sheet which hopefully answers some of the key questions that may arise. This can be located in the Forms Library and also on the Documents tab of the CSAS website (www.csas.uk.net). It is entitled “How is my identity checked for DBS application purposes by the Catholic Church of England & Wales?”


I am really confused about the 3 routes and which route should be used in which scenario. Is there any other information I can access?

CSAS has produced a single sheet flowchart that aims to steer you through the revised ID verification process requirements. This can be located in the Forms Library.


What about Non-EEA Nationals who require a DBS Disclosure?

The DBS require that all Non-EEA Nationals should be validated via Route One Only.


What about EEA Nationals (Non-UK)?

The DBS require that where an EEA National has been resident in the UK for 5 years or less, the identity of the applicant should be validated via Route 1 by checking a Current Passport or Current UK Driving Licence (photo card only) plus 2 further documents (refer to Route 1 above).

If the applicant cannot provide a Group 1 document, then Route 2 must be pursued to validate the applicant’s identity satisfactorily.


Are members of Clergy or Religious required to undertake the ID verification process?

Yes. Any individual who requires a DBS check (whether they be ordained Clergy, Religious, employee; volunteer or post holder) must be ID verified according to the DBS guidelines and Home Office requirements. A DBS check cannot be completed and submitted for processing without the identity of the DBS applicant having been verified through the stated process as dictated by the Disclosure and Barring Service.


What about 16 - 19 year old applicants in full-time education?

A letter confirming their identity from their Head Teacher or College Principal is accepted as a Group 2b document as part of the range of required documents. This may verify their name and any other relevant information required e.g. address or date of birth. It should be noted such a letter cannot and should not be used in isolation from the required list of valid identity documents.


Is there a charge for fingerprinting and if so, who pays it?

There are no costs for the applicant, the Employer or the Registered Body should the individual be asked to provide fingerprints in order to proceed with their DBS Disclosure application.


How long are the fingerprints retained for?

Fingerprints taken for DBS application purposes are only retained when required in connection with an offence. When not relevant to an offence the fingerprints are destroyed and not retained by either the DBS or the Police National Fingerprint Database.


Will there be any change to the fee currently charged for a DBS Disclosure check?

The DBS advise us that there is no planned fee increase as a consequence of the revision of the ID verification requirements.


Guidance Regarding How to Check the Accuracy of Original ID Documentation

How can I check driving licences?

Do not accept licences, other than those stated in the list of Valid Identity Documents.

English, Welsh and Scottish driving licence numbers contain information about the applicant's name, sex and date of birth. This information is written in a special format but can be gleaned and matched against the information provided by the applicant in Section A.

Please note that the date of birth on English, Welsh and Scottish driving licences, issued before 1977, is not recorded as a separate entry on the licence. The date of birth can be deciphered from the driving licence number and checked against the date of birth field on the application form.

For example the format of the number for Christine Josephine Robinson, born 2 July 1975:

R O B I N 7 5 7 0 2 5 C J 9 9 9 0 1
N N N N N Y M M D D Y I I C C C C C

N = 1st five letters of the surname (if the surname begins MAC or MC it is treated as MC for all)
Y = YEAR of birth
M = MONTH of birth (In the case of a female, the number represented by the first M will have the value 5 added to the first digit e.g. a female born in November (i.e. 11) would display '61' in the MM boxes or if born in February (i.e. 02) would display ‘52’)
D = DAY of month of birth
I = Initial letter of the first two forenames - if only one, then 9 will replace the second letter. If the licence indicates that the applicant has a middle name, ensure that one has been provided in Section A
C = Computer generated

Please note, for Northern Ireland; Isle of Man and Jersey driving licences the licence number is in a different format. The licence number is unique to the driver and the ‘name’ or ‘date of birth’ validation, as shown above, cannot be used.


What if the applicant has been adopted?

Registered Bodies should inform applicants that if they were adopted before the age of 10, they do not need to provide their surname at birth in Section A of the DBS application form, they should give their adoptive name in this section.

This is because the age of criminal responsibility is deemed to be 10 years, under the Children and Young Persons Act 1933, Chapter 12, Section 50. This means that there is no possibility that an individual could have a criminal record in a name that was used until the age of 10.


What if the applicant has changed their name recently and cannot provide ID documents in this new name?

The Home Office introduced the new ID validation process in order to provide a framework to establish an applicant’s true identity. In particular it is intended that this approach should make it more difficult for individuals to conceal criminal records by changing their name and is part of an ongoing Government improvement programme that will enable easier detection of undeclared changes of name in the future. 

The new process requires the Registered Body or designated evidence checker to have sight of the necessary legal documents to validate the applicant’s details including name changes. If the applicant cannot comply, then a probing discussion should be held to clarify why and to satisfy themselves as far as possible that an identity is not being concealed.


The DBS application form can only hold 3 name changes. What do I do for applicants who have changed their name more than 3 times?

In these instances you must return a “Continuation Sheet” (this is a DBS specific form) with the DBS application form showing the other name changes.


What should a Registered Body do if they suspect false identity or documents?

If you suspect that you have been presented with a false identity or documents at the time of application, do not proceed with the application process.

Contact the DBS who will be able to advise of on the routes through which suspected identity fraud can be reported.  If you suspect identity fraud AFTER a DBS check has been submitted, the DBS must be notified immediately.


How do I check for indicators of fraud?

Always check for signs of tampering when checking identity documents. Documents should be queried if they display any signs of damage, especially in the areas of personal details such as the name and the photograph. Further specific guidance is provided about particular document types.


How do I check a passport?

Check the general quality and condition of the passport. Treat it with suspicion if it is excessively damaged; accidental damage is often used to conceal tampering. Photographs should be examined closely for signs of damage to the laminate or for excessive glue or slitting of the laminate; these signs would indicate photo substitution. If the photograph appears excessively large, this might indicate an attempt to hide another photograph underneath. There should also be an embossed strip embedded into the laminate, which will catch a portion of the photograph.

Check there is no damage to this area. If the passport is from a foreign national, you can still follow the same general procedures as above.


How do I check a photo driving licence?

Examine the licence for evidence of photo tampering or any amendment of the printed details.


How do I check an old style driving licence (no photograph)?

Remove the document from the plastic wallet and check that it is printed on both sides. It should have a watermark visible by holding the licence up to the light and there should be no punctuation marks in the name or address. The ‘Valid To’ date should be the day before the bearer’s 70th birthday (unless the bearer is already over 70). The ‘Valid To’ date can therefore be cross-referenced with the applicant’s date of birth detailed in Section A.


How do I check a birth certificate?

Birth certificates are not evidence of identity, and are easily obtained. Although certificates issued at the time of birth may give more confidence that it belongs to the individual, unlike a recently issued certificate they will not show if any information has been corrected or superseded by a new registration.

Check the quality of paper used; genuine certificates use a high grade. There should be a watermark visible when the document is held up to the light. Any signs of smoothness on the surface would indicate that original text might have been washed or rubbed away. There should be no signs of tampering, changes using liquid paper, overwriting or spelling mistakes.

The following list provides some general information about certificate completion which may help to establish whether the certificate and/or the details have been falsified. This is provided solely as a guide and is not exhaustive:

  • The certificate format used should be appropriate for the year of registration;
  • Only the surname should be entered in upper case, not the forename(s);
  • Dates of birth should be shown with the day and month in words and the year in figures.

The following information might indicate that the certificate has been altered:

  • Spacing between falsely added particulars might be irregular compared to original information. ‘Thick’ or ‘thin’ spacing might infer particulars have been added;
  • False particulars might not have been aligned with other words;
  • Characters may not be of the same size or shape with the rest of the particulars;
  • Movement of handwriting may look mechanical and does not flow with the rest of the particulars;
  • Changes might not be consistent e.g. parents’ surnames might be altered, but not the signatures;
  • The area around falsely added or removed particulars may react differently under an ultra violet light i.e. show signs of staining. In addition, such areas of paper may appear thinner where the paper fibres have been disturbed by abrasion.


How do I check an EU Photo Identity Card?

Examine the card for evidence of photo tampering or any amendment of the printed details.


How do I check an HM Forces ID card?

Examine the card for evidence of photo tampering or any amendment of the printed details.


How do I check a firearms licence?

Check the licence is printed on blue security paper with a Royal crest watermark and a feint pattern stating the words ‘Home Office’. Examine the licence for evidence of photo tampering or any amendment of the printed details, which should include home address and date of birth. The licence should be signed by the holder and bear the authorising signature of the chief of police for the area in which they live, or normally a person to whom his authority has been delegated.


What about other forms of identification?

Ensure all letters and statements are recent, i.e. within a three month period. Do not accept documentation printed from the internet. Check letter headed paper is used, bank headers are correct and all documentation looks genuine. The address should be cross-referenced with that quoted in Section B.


Where can I find information about checking Biometric Residence Permits?

Some useful guidance is available on the CSAS website under “Documents” (www.csas.uk.net) and can be located on the UK Visas and Immigration website.


Is there any other information available concerning European documents?

Yes, this can be found at the Council of the European Union Public Register of Authentic Identity and Travel Documents Online (PRADO) website.