ID checking guidelines for countersignatory applications (2023)

Introduction

This guidance will help you validate the identity of a candidate as part of the countersignatory application process.

A candidate for countersignatory or lead countersignatory status with us must provide specific identification documents as part of the application process.

As a registered body you must:

• check and validate the information provided by the candidate on the application form / continuation sheet
• establish the true identity of the candidate through the examination of a range of documents as set out in this guidance
• make sure the candidate provides details of all names by which they have been known and all addresses where they have lived in the last 5 years
• check the application form is fully completed and the information is accurate

If there are any discrepancies in the information provided by the candidate and/or the identity documents supplied, and fraud is not suspected, please seek clarification from the candidate. Failure to do this may compromise the integrity of the DBS service.

You must not attempt to amend the application form without the candidate’s knowledge and agreement as it will invalidate the declaration by the candidate and may breach data protection legislation.

What you must do as part of the ID checking process

• you must only accept valid, current and original documentation
• you must not accept photocopies
• you must not accept documentation printed from the internet e.g. internet bank statement
• identity information for the candidate’s name, date of birth and address must be validated
• you should, where possible, ask for photographic identity (e.g. passport, new style driving licence, etc. and for this to be compared against the candidate’s likeness)
• all documents must be in the candidate’s current name (see below for guidance on recent changes of name)
• one document must confirm the candidate’s date of birth
• you must see at least one document to confirm the candidate’s current address B which is no older than three months
• you must provide a full and continuous address history covering the last five years. Where possible you should get documentation to confirm this address history
• you should cross match the candidate’s address history with any other information you have been provided with as part of the recruitment, such as their CV. This can highlight if an address has not been given e.g. if the candidate’s CV shows that they have worked in Liverpool in the last 5 years but the application form only shows London addresses, you may wish to question the candidate further about this.

Only one document from each of the subgroups in group 2 should be included in the document count e.g. do not accept two bank statements as two of the required documents, if they are from the same bank.You cannot accept the foreign equivalent of an identity document if that document is listed as ‘(UK)’ on the list of valid identity documents.

If an identity document is provided in a foreign language, you must obtain a translation of that document, certified by a Notary Public.

When applying for lead or countersignatory status at least one document must show the candidate’s signature.

Check if the document in the list of valid identity documents is denoted with * - it should be less than three months old. Denoted with ** - it should be issued within the past 12 month. Not denoted – it can be more than 12 months old.

What if the candidate has been adopted?

You should inform candidates that if they were adopted before the age of 10, they do not need to provide their surname at birth, they should give their adoptive name.

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 candidate has changed their name recently and cannot provide ID documents in this new name?

Documents in a previous name can be accepted only where the candidate can provide documentation supporting a recent change because of:

• marriage/civil partnership (marriage/civil partnership certificate)
• divorce/civil partnership dissolution (decree absolute/civil partnership dissolution certificate)
• deed poll (Deed Poll certificate)

In these instances, you must return a continuation sheet with the application form clearly stating:

• current and previous names
• date of the change
• reason for the change
• the document you have seen to support this change

Make sure that all ‘Previous names’ and ‘Dates used’ are recorded.

Identity documents that can be used for the checking process

Documents that we have divided into two groups: group 1 and group 2. At least three documents must be provided:

• if the candidate can produce a document from group 1, three documents must be seen in total - one document from group 1 plus any two from groups 1 or 2.
• if the candidate cannot produce a group 1 document, five documents from group 2 must be seen.

If the candidate has insufficient identity documents, please call us for advice on 03000 200 190.

Group 1 and group 2 valid identity documents

Group 1

Group 2

At least one document must confirm the candidate’s current address and at least one document must confirm the candidate’s date of birth.

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. The following guidelines should help you look out for any suspicious signs when authenticating documents.

Checking 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 candidate’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 candidate in Section A.

Please note that the date of birth on English, Welsh and Scottish driving licences, issued before1977, 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 candidate has a middle name, ensure that one has been provided in Section A.

C = Computer generated.

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.

Checking 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 procedures as above.

HM Passport Office have produced a guide to be used when checking passports for identification.

Checking a photo driving licence

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

Checking 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 candidate’s date of birth detailed in Section A.

Checking 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.

For more information on checking birth certificates, please refer to HM Passport Office document General Register Office guide to birth certificates.

Checking an EU photo identity card

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

Checking an HM Forces ID card

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

Checking a firearms licence

Check the licence is printed on blue security paper with a Royal crest watermark and a faint 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.

Checking a biometric residence permit

View the features of a permit and how to check them on the UK Visas and Immigration website.

Other types of ID

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.

What should you do if you 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.

• report suspected identity fraud through the Action Fraud website
• further information on identity fraud can be found on the Metropolitan police website
• if you suspect identity fraud once a DBS check has been submitted, you must call us on 03000 200 190

You are also advised that under Section 8 of the Asylum and Immigration Act 1996 all employers in the United Kingdom are required to make basic document checks to help prevent anyone from working illegally.

By carrying out checks employers will be able to establish a defence for themselves if any of their employees are found to be working illegally at a later date.

Further details are available on the UK visas and immigration website or by calling the employer helpline on 0845 010 6677.

Where to go for help

Employers can go to the public register of authentic identity and travel documents online on the PRADO website to identify the basic safeguards contained in European documents and a few more other nationality documents.

The PRADO website is provided by the Council of European Union.

DBS helpline

If you need any further advice on checking a candidate for lead or countersignatory status, phone us on 03000 200 190.