CRB ID Checking Routes as from 31 August 2012 How to use the External Validation Service & Identity Checking Scenarios 1 Board of Education Church House Cathedral Close Blackburn BB1 5AA Tel (01254) 503070 Fax (01254) 699963 VAT Registration Number 846 4862 89 Since the introduction of The Protection of Freedoms Act 2012 there have been many changes to the CRB Checking Process. As this Bill is extremely complex it is taking time for the necessary Government Guidance to be clarified. Confirmation of the final position will be provided in 2013 following the implementation of the final round of changes arising from the Act. As these changes are being rolled out over the next few months we will endeavour to keep you informed as to how they will affect the CRB Application process by email and on the Board of Education website. Unfortunately, this may come at short notice, as we can only respond, when the information is released by the Home Office. In the meantime, as you are aware the CRB introduced a number of changes to the CRB ID Checking process which changed on the 28th May 2012. We are just contacting you to remind you that the period of grace is now over and that you must now comply with the new ID Checking Process. Regarding Route two of the ID Checking Process the Diocese has engaged the services of Compliance Assist working through Experian to act as our External ID Validation Service. The cost of providing this service is currently being met by the Board of Education and free to our schools should they need to use it. This service should only be used where an applicant genuinely cannot satisfy Routes One and or Two the ID Validating purposes. It is not to be used lightly, the applicant should endeavour to provide enough ID as required by the new ID checking Routes. We hope that you find this information helpful. Yours in God Debbie Debbie Jagger School Building and CRB Administration Office 2 What process should I follow to check an applicant’s ID? You should follow the three routes as outlined below. List of Accepted ID Documents GROUP 1 – Primary Trusted Identity Credentials Current Valid Passport - UK,,EEA or Non-EEA (or NonEEA in combination with a Biometric Residence Permit or current Work Permit/Visa Birth Certificate (UK & Channel Islands) Issued within 12 months of birth – full or short form acceptable including those issued by UK authorities overseas, such as Embassies, High Commissions and HM Forces Current Photocard Driving Licence (UK) (Full or Provisional) – England/Wales/Scotland/Northern Ireland/Isle of Man. A Photocard Licence is only valid if the individual presents it with the counterpart licence; except Jersey. Bio Metric Residence Permit (UK) GROUP 2a – Trusted Government/State Issued Documents Current Valid Passport (UK, EEA or Non-EEA) Old Style Paper Driving Licence Copy Birth Certificate (UK) issued after 12 months of birth (full or short form acceptable) HM Forces ID Card (UK) Bio Metric Residence Permit (UK) Marriage/Civil Partnership Certificate Adoption Certificate Fire Arms Licence (UK) Group 2b – Financial/Social Documents ** Mortgage Statement ** Financial Statement e.g. pension, endowment, ISA (UK) **P45/60 statement (UK) ** Council Tax Statement (UK & Channel Islands) *Bank or Building Society Statement (UK) * Credit Card Statement (UK) * Utility Bill (Gas Water Electric., telephone) NOT Mobile Telephone) *Benefit Statement- e.g. Child Allowance, Pension ** Work Permit /Visa (UK) (UK Residence Permit) A Document from Central/Local Government/Government Agency/Local Authority giving entitlement (UK and Channel Islands) e.g.: Document from Department for Work and Pensions The Employment Service Customs & Revenue Job Centre, Job Centre Plus, and Social Security EU National ID Card 3 Cards Carrying the PASS accreditation logo (UK) Letter from Headteacher – 16-19 year olds in full time Education only NB. * Documentation should be less than three months old ** Issued within the last 12 months. Not denoted – it can be more than 12 months old 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. 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 Evidence Checker/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; 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 An external ID validation check is an alternative way of verifying the identity of an applicant. It will involve you providing an applicant’s details (as presented on the application form) to your chosen supplier, who will compare the data you have obtained from the applicant against a range of independent, external data sources. ROUTE TWO - Using the External ID Validation Service The Criminal Records Bureau recently released an update to its identity checking guidance regarding the use of an external identity validation check for Route 2 of the identity checking process. 4 In order to comply with the CRB’s ID validation requirements the Diocese has employed ‘Compliance Assist’ to act as the service provider for our External ID Validation Service. Evidence Checkers will be able to access this service by contacting the Diocesan Board of Education to request an External ID Validation check only when required to satisfy Route Two. To validate an individual’s identity the Evidence Checker will need to provide the following: 1. 2. 3. 4. 5. The Individual’s FULL NAME Their CURRENT ADDRESS ANY previous address if they have moved in the last 3 years The Individual’s DATE of BIRTH The Individual must also be asked to provide consent to their identity being validated electronically. Please contact either Debra Jagger on 01254 503410 or Helen Morris on 01254 503404 at the Board of Education to enable the checks to be carried out on your behalf. We will require the signed, dated & written consent of the applicant prior to carrying out the check. Plus the information requested above. Please use the Diocesan External ID Validation Check Consent Form which will be supplied on request (sample copy attached). 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 Organisation’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 CRB. 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 CRB application process and subsequently to your recruitment process 5 Board of Education Church House Cathedral Close Blackburn BB1 5AA Tel (01254) 503070 Fax (01254) 699963 VAT Registration Number 846 4862 89 Details required to undertake an External ID Validation Check Please use BLACK INK and CAPITAL LETTERS throughout. Dear As part of the process to confirm your identity we need to undertake an external identity validation check. This will be undertaken by a company called Compliance Assist, a partner company of Experian. This process involves checking the details you supply against those held on a number of specific databases Experian has access to. A record of this process will be kept but in no way will have an impact on your credit record. External ID Validation checks cannot be carried out unless the Applicant has provided their consent for the ID to be validated electronically. Please return this form to the Diocese to enable External ID Validation Check to be processed. Name of Individual ___________________________________________________________ Date of Birth __________________ Other Names: Surname_____________________ Forename(s) ________________________ Dates to and From [from] ___/___/______ [to]___/___/_____ (please include any others on separate sheet) Current Address of Individual: Address: Town City: County: UK Postcode _______________________________________________________________ _______________________________________________________________ _______________________________________________________________ _________________ _________________ Country__________________________ Date at current address since __________________ Other Addresses (you must provide addresses where you have lived in the last three years) Address: Town/City: County: UK Postcode _______________________________________________________________ _______________________________________________________________ _______________________________________________________________ ____________________ ____________________ Country___________________________ 6 Date from __________________ __ Date to ___________________________ Please include any other addresses in the last 3 years on a separate sheet CRB Administration Office Insert Your Organisation name & Address below:- Blackburn Diocese Board of Education Church House Cathedral Close Blackburn BB1 5AA Date : ___ /____ /_______ [Insert date] Consent for External ID Validation Check Dear Sir You may undertake a search with Experian for the purposes of verifying my identity. To do so Experian may check the details I supply against any particulars on any databases (public or otherwise) to which they have access. They may use my details in the future to assist other companies for verification purposes. A record of the search will be retained. I understand that my employer will be carrying out this check for the purposes of confirming my ID as part of the CRB Identity Checking Process. This will be carried out through the Diocese of Blackburn Registered Body via their service provider Compliance Assist. The parties involved in this process will keep the Confidential information strictly confidential and not disclose any part of the same to any person except by or required for the purposes of obtaining a CRB Disclosure. Signed [Applicant’s Signature]: Please Print Name Below [BLOCK CAPITALS]: _____________________________________________________ 7 Route Three ALL Organisations conducting an evidence checking process 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: 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 CRB 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 cannot establish an applicant’s identity in accordance with CRB 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 8 What to do if you cannot satisfy any of the three routes In the event of an applicant being unable to satisfy any of the three Routes, the Registered Body should have a probing discussion with the applicant before considering whether to declare ‘No’ at section W59 of the application form. If the Registered Body has done everything within reason to acquire the necessary documentation without success, the only further option is the applicant would need to be fingerprinted which may cause delays. The DBS are preparing further guidance for such cases which will be communicated along with the details of the external ID validation service Changes in the rejection rules The Countersignatory, or their approved evidence checker, is required to confirm an applicant’s true identity and respond appropriately to the question at section w59 which states: “Have you established the true identity of the applicant, by examining a range of documents as set out in CRB guidance, and verified the information provided by the applicant in sections a and b, by completing the verification check boxes?” Unfortunately, the CRB receives a significant number of applications where the ‘no’ box has been crossed in response to this question; of which approximately 75% of cases are found to have been completed in error when the Countersignatory confirms that the ‘yes’ box should have been crossed. Therefore, from 3 September 2012, if an application form has a cross at ‘no’ in section w59, we will return the form immediately to the relevant Countersignatory. This will provide an opportunity for the Countersignatory to re-check the form or, if appropriate, arrange to contact the applicant to review if their identity can be validated using CRB guidance. If you receive a form back and find that you have crossed ‘no’ at w59 in error, or you now can establish the applicant’s true identity, please cross and circle the ‘yes’ box in this section and return the application form to be processed as normal. If you cannot establish the applicant’s true identity using Routes One, Two or Three as specified in the guidance, then you should leave section w59 unaltered, marked with a ‘no’, and return the application form to the DBS. If the applicant cannot provide evidence of their identity, you should advise the applicant they will be contacted by the DBS to give their consent to attend a police station at an appointed time to have their fingerprints taken, which will unfortunately delay the overall application process and, subsequently, your recruitment processes. 9 You should be aware that fingerprinting will not confirm an applicant’s true identity. Fingerprinting is undertaken to ascertain if the applicant has a criminal record held on the Police National Computer (PNC) with corresponding fingerprints and cannot determine if the person has any other record that does not contain fingerprints. This information needs to be clearly communicated to anyone that is involved in the identity checking and recruitment processes within all organisations. Countersignatories and approved evidence checkers need to be particularly vigilant when checking the forms, especially section w59, prior to sending them to the DBS 10 Identity checking scenarios Below are a number of scenarios which will demonstrate the documents you may be presented with as part of the new identity checking process, and how to use the appropriate route to establish an applicant’s identity. Please refer to the acceptable document lists contained within the new guidance. Satisfying Route One The applicant must produce 3 documents as follows: address. Scenario one John is 17 and is volunteering as a Group Leader with a national organisation working with 5-16 year olds. He provides the following documents: bank statement dated within the last month (Group 2b) John has a Group 1 document (valid UK passport), so the organisation should first investigate the use of Route One. In addition to this Group 1 document, he also has a further Group 1 document, and a Group 2b document which confirms his current address. T Scenario two Ruth is applying to a local NHS Trust to work as a staff nurse. She provides the following documents: ounterpart) (Group 1) Scenario two Ruth is applying to a local NHS Trust to work as a staff nurse. She provides the following documents: p 1) Ruth has provided only 2 valid documents. Whilst a TV Licence is now not an acceptable document for the purposes of identity verification, it could be a useful indicator of what other documents Ruth may be able to provide. In this case, Ruth’s TV Licence suggests she is a homeowner or lives in rented accommodation, and she may be able to produce another 11 document such as a council tax statement. Through a combination of the two Group 1 documents provided, and by now questioning Ruth, she can provide a council tax statement as a Group 2b document which confirms her current address. Ruth has satisfied the requirements for Route One. Scenario three Mohammed is applying to go to teacher training college and is required to undergo a CRB check as he will be going on school placements. He provides the following documents: -month old bank statement (Group 2b). He is adamant he has no other documents from Groups 1, 2a or 2b. This combination of documents provides insufficient evidence, and would not satisfy any of the routes available. The college may wish to advise Mohammed that he could obtain a copy of his birth certificate (Group 2a) from the General Register Office (GRO) at http://www.gro.gov.uk/gro/content/certificates/default.asp. If he were to provide this, he would now have one document from Groups 1, 2a and 2b, and as the bank statement confirms Mohammed’s current address, this would satisfy the requirements for Route One. Satisfying Route Two If the applicant is unable to provide a Group 1 document, then you should proceed to Route Two. In the first instance, the applicant must produce 3 documents in total: address. Once satisfied with these documents, you need to use an appropriate external ID validation service to establish the applicant’s name and living history footprint. Full details of how to source an external ID validation provider can be found on pages 6 & 7 of the revised and enhanced ID checking guidelines. Scenario four James is 20 years old and applies for a post as a care worker with a supply agency. He provides the following documentation for identity validation: ued last month verifying his address (Group 2b) As James has not provided a Group 1 document, the agency is unable to validate his identity using Route One. However, he has provided sufficient documents to be processed by Route Two. 12 A Director of the Agency searches the internet to ascertain which organisations provide an ID verification service that meets the requirements of a Level 2 (Remote) check. She contacts a number of service providers before deciding on which one bests suits their needs e.g. cost and payment method; terms and conditions; timescale; printable or hard copy result. Although the organisation does not have any in-depth knowledge of what a “Level 2‟ check involves, the chosen service provider is in a position to give an assurance that they comply with the standards described within the published guidance. The agency has set up the required procedures and is able to progress with James‟ application and verify his identity using Route Two. A “pass” result is provided by the ID verification service provider and the ID check is complete. Scenario five Adrian is applying for the post of a physiotherapist with his local NHS trust. He is required to undertake a CRB check and provides the following documentation: As Adrian has no Group 1 document, you are unable to use Route One. The Registered Body (RB) have sourced an external ID verification service, so they decide to progress to Route Two. The result from the ID verification service provider is a “pass”. The RB can be assured that Adrian’s identity has been verified to the required level and the ID validation process is complete. Scenario six Tahney is a 17 year old school leaver (leaving school in 5 weeks) and is applying for the post of nursery assistant. She is required to undergo a CRB check and produces the following documentary evidence: d the counterpart (Not acceptable) She is adamant she has no other documents from the list provided that she could use. Tahney has produced insufficient documents to validate her identity using Route One. As she has mislaid the counterpart to her driving licence the document is invalid. The RB would advise her to contact DVLA about this. Tahney is 17 and still at school and could get a letter from her headmaster confirming her name, address and any other details they feel appropriate. She does not have sufficient documents to use Route 2, but after a probing discussion the RB decide to let her get a 13 letter from the headmaster confirming her name and address and agree to process her through Route Two. The RB contact the ID verification service provider and the result obtained is a “Fail”. It would appear that Tahney may not have yet established a living history footprint and they would now need to consider using Route Three. However, Tahney has now informed them that she has acquired a replacement counterpart of her driving licence from the DVLA. This now means she has a Group One document and coupled with her birth certificate and Building Society statement, the RB may now process by validating her ID using Route One. Satisfying Route Three All Registered Bodies must have exhausted Route One and should have endeavoured to use Route two before considering processing any applicant by Route three. You should have had a probing discussion with the applicant to establish why they were unable to be processed by Routes one or two. Scenario seven Doris has recently retired, and wishes to volunteer at her local adult care home. She has not travelled abroad for some time, therefore her passport has expired. She has never driven, and her birth certificate issued at the time of birth is lost; but she does possess a birth certificate issued 15 years ago. Therefore, she has no Group 1 documentation, and could not satisfy the requirements for Route One. She explains that all the household bills are in her husband’s name. Following a discussion, the Registered Body establishes that Doris can provide the following documents: Doris has sufficient documents to satisfy the requirements for Route Two. However, on this occasion, the Registered Body have been unable to carry out an external ID verification, despite endeavouring to do so. As Doris possesses a copy of her birth certificate (Group 2a), we can move on to assessing her other documents. She has a Marriage Certificate (Group 2a), and also three further Group 2b documents, one of which verifies her address and therefore she has satisfied Route Three. 14 Scenario eight David is applying to work as a volunteer Youth Leader with under 14‟s and has no Group 1 document. He provides the following documents: recent credit card statement (Group 2b). As David has no Group 1 documentation, the Registered Body moves on to Route Two. In this case, David has sufficient documents to satisfy the requirements for Route Two. However, on this occasion, the Registered Body carried out an external ID verification which resulted in a “fail‟. Having endeavoured to carry out an external validation check without success, and following a probing discussion with David, the Registered Body would now move on to Route Three. In order to be able to satisfy Route Three, David would have to obtain a certified copy of his birth certificate from the General Register Office (GRO) at http://www.gro.gov.uk/gro/content/certificates/default.asp. Upon doing this, he would then have sufficient documentation to satisfy Route Three. What to do next? In the event of an applicant being unable to satisfy any of the three Routes, you should have a probing discussion with the applicant before considering whether to declare “No‟ at section W59 of the application form. If you have done everything within reason to acquire the necessary documentation without success, the only further option is the applicant would need to be fingerprinted which may cause delays. Non UK/EEA applicants only 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 two further documents from groups 1, 2a or 2b; one of which must verify their address. In the absence of a Group 1 document the Registered Body must satisfy themselves of a valid reason for using Route 2. Scenario nine Agnetha is a Swedish national that has resided in the UK for the last 2 years. She is applying to a local NHS Trust to work as a consultant. She is required to undergo a CRB check and provides the following documentation: one month old bank statement verifying her address (Group 2b) 15 Agnetha has resided in the UK for less than five years and is able to produce a current passport (Group 1 document). The two further documents enable Agnetha to be processed by Route One and the document check is complete. 7 Non UK/EEA applicants only 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 two further documents from groups 1, 2a or 2b; one of which must verify their address. In the absence of a Group 1 document the Registered Body must satisfy themselves of a valid reason for using Route 2. Scenario ten Pierre is a French national that came to the UK a month ago on his EU identity card. He is residing with a friend prior to studying here for a year and has volunteered to work with the local church supporting young people in the community. He is required to undergo a CRB check and produces the following documents: Pierre has not produced a Group 1 document and therefore he cannot be processed using Route One. The Registered Body has a case conference and decides that the option of using Route Two may not yield a “pass‟ result as he has never lived in the UK and is unlikely to have a sufficient living history footprint to successfully validate his identity. They discuss the issues with Pierre and establish that he does possess a valid French passport which his mother has in his family home in Bordeaux. He agrees to get her to post this to him. However, the bank statement confirms his previous French address; and he advises that he intends to open a bank account in the UK. Pierre returns 10 days later with the following documentation: A bank statement from a French bank issued four weeks ago (Group 2b) Pierre can now be processed by the use of Route One as he has provided more than sufficient evidence and the documentation check is complete. Non UK/Non-EEA applicants only All Non-EEA Nationals should be validated via Route One only. 16 Scenario 11 Pauline is an Australian national and has applied to come to the UK to work for an NHS Trust. The application for her CRB is processed by the NHS Trust prior to Pauline coming over to the UK – She provides the following documentation to a representative of the Trust in Sydney: rom the Trust verifying Pauline’s current address. (Group 2b) Pauline has a Group 1 document and 2 further documents from Groups 2a and 2b which enables the RB to process her application through Route One. Scenario 12 Javeed is an Indian national and has been living in the UK for two years. He has a year to run on his work permit and applies to work in a private school teaching special needs. The school requires Javeed to undergo a CRB check and he produces the following documentation: ss (Group 2b) Javeed has not provided sufficient evidence to be processed by the use of Route One. As he is a non-UK/non-EEA applicant, he may not be processed other than by Route One. You explain to Javeed that if he is not able to provide a Group One document, the only option would be for him to go for fingerprinting at a local Police station which would result in a delay to the CRB process. Javeed accepts that he should not have mislaid his passport and has suggested that he request a new passport from the Indian embassy. He returns a few days later with a new valid Indian passport which now enables you to process his application through Route One. * If you or your ID checker cannot establish an applicant’s identity in accordance with CRB 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. The following scenario highlights the fingerprinting process. Scenario 13 Andrew is 18 years old and is applying for the position of an Assistant Care Worker in a local Care Home. The Care Home uses the services of an Umbrella Body to process their CRB Checks. He provides the following documentation to the Care Home: 17 statement issued 2 months ago. The bank statement is an acceptable Group 2b document, but the mobile phone bill can‟t be accepted. Andrew has insufficient documentary evidence and the Umbrella Body return the completed application form to the Care Home requesting further documentary evidence. The Care Home Manager discusses with Andrew and he is adamant he has no other documents contained on the valid identity documents list. The Umbrella Body submit the application to CRB and indicate “No‟ at w59 – They have not established the true identity of the applicant. In the first instance, the CRB return the form to the Umbrella Body, in line with the rejection procedure applied from 03 September 2012; the reason being that they had indicated „No‟ at w59 on the form. The Umbrella Body contact the Care Home and they in turn contact Andrew direct and explain that if he fails to produce any further documentary evidence, the only alternative will be to have him sent for fingerprinting at a local police station – This will delay his application. Andrew is once again adamant he can’t provide anything further, so the form is returned to the CRB. This time, Andrew’s form is processed to CRB‟s Customer Services where he is requested to attend a police station at a given time. He is asked to complete a consent form and produce three identical size photographs with his name clearly written on the back of each photograph with his customer reference. Andrew attends the police station at the given time and the result is that there is “no match‟ against all records that are checked and held by the police and other law enforcement agencies. A clear CRB certificate is issued – It should be noted: process took considerably longer than normal. ndrew’s identity – It just provides evidence that the police were unable to match the fingerprints against any records they searched. 18