The new guidelines will run in parallel from 24th October 2017 with the existing ID checking guidelines until 25th January 2018, when the existing guidelines will cease to apply. You can start using the new guidance from the 24th October; however you have three months to transition to the new guidance.
The enhancement is being introduced so that the DBS’s identity checking process is aligned to ‘Right to Work’ checks whereby employers must prevent illegal working in the UK by carrying out document checks on people before employing them to make sure they are allowed to work.
The changes tighten up the document requirements for non-EEA nationals who are applying for DBS checks for paid work so that they are consistent with the existing Right to Work document list.
ID checking guidelines for DBS check applications
The applicant must provide a range of ID documents as part of the DBS check application process. As an employer you must:
- follow the three route ID checking process as outlined
- check and validate the information provided by the applicant on the application form/ continuation sheet
- establish the true identity of the applicant through the examination of a range of documents as set out in this guidance
- make sure the applicant provides details of all names by which they have been known
- make sure the applicant provides details of all addresses where they have lived in the last five years
- check that the application form is fully completed and the information it contains is accurate. Failing to do this can result in delays
If there are any discrepancies in the information provided by the applicant and/or the identity documents supplied, and fraud is not suspected, please ask the applicant to clarify. If you don’t do this it may compromise the integrity of the DBS service and introduce risk to your recruitment or licensing arrangements.
As an employer you must not attempt to amend the application form without the applicant’s knowledge and agreement. Doing this will invalidate the declaration by the applicant 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 statements
- identity information for the applicant’s name, date of birth and address recorded on the DBS application form must be validated
- you should in the first instance, seek documents with photographic identity (e.g. passport, new style driving licence, etc.) and for this to be compared against the applicant’s likeness
- all documents must be in the applicant’s current name
- one document must confirm the applicant’s date of birth
- you must ensure that the applicant declares all previous name changes, and provides documentary proof to support the change of name. If the applicant is unable to provide proof to support the change of name, you should hold a probing discussion with the applicant about the reasons why before considering to validate their identity
- you must see at least one document to confirm the applicant’s current address
- you must provide a full and continuous address history covering the last five years. Where possible you should seek documentation to confirm this address history
- you should cross-match the applicant’s address history with any other information you have been provided with as part of the recruitment, such as their Curriculum Vitae (CV). This can highlight if an address 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
- a document from each of the groups should be included only once in the document count e.g. don’t accept two bank statements as two of the required documents, if they are from the same bank
- you should not accept the foreign equivalent of an identity document if that document is listed as ‘(UK)’ on the list of valid identity documents
The documents needed will depend on the route the application takes. The applicant must try to provide documents from Route 1 first.
It’s important to note that a DBS check does not provide evidence of a person’s right to work in the UK. You must do a separate check to make sure a job applicant is allowed to work in the UK which also includes roles for voluntary work.
If the applicant isn’t a national of the UK or the European Economic Area (EEA) they must use a different route to apply for paid work in the UK. They can use Route 1 for voluntary work.
Three routes of ID checking
Route 1
The applicant must be able to show:
- one document from Group 1, below
- 2 further documents from either Group 1, or Group 2a or 2b, below
At least one of the documents must show the applicant’s current address.
If the applicant isn’t a national of the UK or the EEA and is applying for voluntary work they may need to be fingerprinted if they can’t show these documents.
Route 2
Route 2 can only be used if it’s impossible to process the application through Route 1.
If the applicant isn’t a national of the UK or the EEA and is applying for voluntary work they can’t use Route 2.
If the applicant doesn’t have any of the documents in Group 1, then they must be able to show:
- one document from Group 2a
- 2 further documents from either Group 2a or 2b
At least one of the documents must show the applicant’s current address. The organisation conducting their ID check must then also use an appropriate external ID validation service to check the application.
EEA nationals who’ve been resident in the UK for 5 years or less may need to be fingerprinted if they can’t show these documents.
Route 3
Route 3 can only be used if it’s impossible to process the application through Routes 1 or 2.
EEA nationals who’ve been resident in the UK for 5 years or less can’t use Route 3.
For Route 3, the applicant must be able to show:
- a birth certificate issued after the time of birth (UK and Channel Islands)
- one document from Group 2a
- 3 further documents from Group 2a or 2b
At least one of the documents must show the applicant’s current address. If the applicant can’t provide these documents they may need to be fingerprinted.
Group 1: Primary identity documents
| Document | Notes |
| Passport | Any current and valid passport |
| Biometric residence permit | UK |
| Current driving licence photocard – (full or provisional) | UK, Isle of Man, Channel Islands and EEA |
| Birth certificate – issued within 12 months of birth | UK, Isle of Man and Channel Islands – including those issued by UK authorities overseas, for example embassies, High Commissions and HM Forces |
| Adoption certificate | UK and Channel Islands |
Group 2a: Trusted government documents
| Document | Notes |
| Current driving licence photocard – (full or provisional) | All countries outside the EEA (excluding Isle of Man and Channel Islands) |
| Current driving licence (full or provisional) – paper version (if issued before 1998) | UK, Isle of Man, Channel Islands and EEA |
| Birth certificate – issued after time of birth | UK, Isle of Man and Channel Islands |
| Marriage/civil partnership certificate | UK and Channel Islands |
| Immigration document, visa or work permit | Issued by a country outside the EEA. Valid only for roles whereby the applicant is living and working outside of the UK. Visa/permit must relate to the non EEA country in which the role is based |
| HM Forces ID card | UK |
| Firearms licence | UK, Channel Islands and Isle of Man |
All driving licences must be valid.
Group 2b: Financial and social history documents
| Document | Notes | Issue date and validity |
| Mortgage statement | UK or EEA | Issued in last 12 months |
| Bank or building society statement | UK and Channel Islands or EEA | Issued in last 3 months |
| Bank or building society statement | Countries outside the EEA | Issued in last 3 months – branch must be in the country where the applicant lives and works |
| Bank or building society account opening confirmation letter | UK | Issued in last 3 months |
| Credit card statement | UK or EEA | Issued in last 3 months |
| Financial statement, for example pension or endowment | UK | Issued in last 12 months |
| P45 or P60 statement | UK and Channel Islands | Issued in last 12 months |
| Council Tax statement | UK and Channel Islands | Issued in last 12 months |
| Letter of sponsorship from future employment provider | Non-UK or non-EEA only – valid only for applicants residing outside of the UK at time of application | Must still be valid |
| Utility bill | UK – not mobile telephone bill | Issued in last 3 months |
| Benefit statement, for example Child Benefit, Pension | UK | Issued in last 3 months |
| Central or local government, government agency, or local council document giving entitlement, for example from the Department for Work and Pensions, the Employment Service, HMRC | UK and Channel Islands | Issued in last 3 months |
| EEA National ID card | – | Must still be valid |
| Cards carrying the PASS accreditation logo | UK, Isle of Man and Channel Islands | Must still be valid |
| Letter from head teacher or college principal | UK – for 16 to 19 year olds in full time education – only used in exceptional circumstances if other documents cannot be provided | Must still be valid |
Applicant s who aren’t a national of the UK or the European Economic Area (EEA)
An applicant who wants to do paid work and isn’t a national of the UK or European Economic Area (EEA) must be able to show:
- one primary document
- 2 supporting documents
If an applicant is unable to provide this documentation they can’t submit a DBS check. This is because the right to work in the UK can’t be established. They can’t use any other route.
Applicants for voluntary work who aren’t UK or EEA nationals must use Route 1.
Non-EEA national who are eligible for a DBS check and receiving payment for work, even if it is an allowance e.g. a foster carer must use the paid work route. Route 1 only can be used by adult household members:
- in a fostering household
- in a childminding household
- in a host family
- living where ‘work with children’ takes place e.g. living in a boarding school
Documents for non-EEA nationals doing paid work
The documents must be originals, not copies.
At least one of the documents must show the applicant’s current address.
| Primary Documents
Document
A current Biometric Immigration Document (Biometric Residence Permit) issued by the Home Office to the holder indicating that the person named is allowed to stay indefinitely in the UK, or has no time limit on their stay in the UK. |
Notes
UK |
| A current Biometric Immigration Document (Biometric Residence Permit) issued by the Home Office to the holder which indicates that the named person can currently stay in the UK and is allowed to do the work in question.
A current passport endorsed to show that the holder is exempt from immigration control, is allowed to stay indefinitely in the UK, has the right of abode in the UK, or has no time limit on their stay in the UK. |
UK
Any current and valid Passport |
| A current passport endorsed to show that the holder is allowed to stay in the UK and is currently allowed to do the type of work in question. | Any current and valid Passport |
| A Certificate of Application issued by the Home Office under regulation 17(3) or 18A (2) of the Immigration (European Economic Area) Regulations 2006, to a family member of a national of a European Economic Area country or Switzerland stating that the holder is permitted to take employment which is less than 6 months old together with a Positive Verification Notice from the Home Office Employer Checking Service.
An Application Registration Card issued by the Home Office stating that the holder is permitted to take the employment in question, together with a Positive Verification Notice from the Home Office Employer Checking Service.
Applicants providing one of the following documents must also provide a current valid Passport:
A current Residence Card (including an Accession Residence Card or a Derivative Residence Card) issued by the Home Office to a non-European Economic Area national who is a family member of a national of a European Economic Area country or Switzerland or who has a derivative right of residence. |
UK
UK
UK |
| A current Immigration Status Document containing a photograph issued by the Home Office to the holder with a valid endorsement indicating that the named person may stay in the UK, and is allowed to do the type of work in question, together with an official document giving the person’s permanent National Insurance number and their name issued by a Government agency or a previous employer. | UK |
| A current Immigration Status Document issued by the Home Office to the holder with an endorsement indicating that the named person is allowed to stay indefinitely in the UK or has no time limit on their stay in the UK, together with an official document giving the person’s permanent National Insurance number and their name issued by a Government agency or a previous employer. | UK |
Supporting documents
The applicant must be able to show 2 documents from any of these groups.
Group 1
| Document | Notes |
| Passport | Any current and valid passport |
| Biometric residence permit | UK |
| Current driving licence photocard – (full or provisional) | UK, Isle of Man, Channel Islands and EEA |
| Birth certificate – issued within 12 months of birth | UK, Isle of Man and Channel Islands – including those issued by UK authorities overseas, for example embassies, High Commissions and HM Forces |
| Adoption certificate | UK and Channel Islands |
A passport or biometric residence permit can only be used as a supporting document if it’s not already been used as a primary document.
Group 2a
| Document | Notes |
| Current driving licence photocard – (full or provisional) | All countries outside the EEA (excluding Isle of Man and Channel Islands) |
| Current driving licence (full or provisional) – paper version (if issued before 1998) | UK, Isle of Man, Channel Islands and EEA |
| Birth certificate – issued after time of birth | UK, Isle of Man and Channel Islands |
| Marriage/civil partnership certificate | UK and Channel Islands |
| Immigration document, visa or work permit (for applicants living and working outside the UK) | Issued by the country where the role’s based |
| HM Forces ID card | UK |
| Firearms licence | UK, Channel Islands and Isle of Man |
Valid only for roles outside of the UK.
All driving licences must be valid.
Group 2b
| Document | Notes | Issue date and validity |
| Mortgage statement | UK or EEA | Issued in last 12 months |
| Bank or building society statement | UK and Channel Islands or EEA | Issued in last 3 months |
| Bank or building society statement (for applicants living and working outside the UK) | Countries outside the EEA | Issued in last 3 months – branch must be located in the country in which the applicant lives and works |
| Bank or building society account opening confirmation letter | UK | Issued in last 3 months |
| Credit card statement | UK or EEA | Issued in last 3 months |
| Financial statement, for example pension or endowment | UK | Issued in last 12 months |
| P45 or P60 statement | UK and Channel Islands | Issued in last 12 months |
| Council Tax statement | UK and Channel Islands | Issued in last 12 months |
| Letter of sponsorship from future employment provider | Non-UK or non-EEA only – valid only for applicants residing outside of the UK at time of application | Must still be valid |
| Utility bill | UK – not mobile telephone bill | Issued in last 3 months |
| Benefit statement, for example Child Benefit, Pension | UK | Issued in last 3 months |
| Central or local government, government agency, or local council document giving entitlement, for example from the Department for Work and Pensions, the Employment Service, HMRC | UK and Channel Islands | Issued in last 3 months |
| EEA National ID card | – | Must still be valid |
| Cards carrying the PASS accreditation logo | UK, Isle of Man and Channel Islands | Must still be valid |
| Letter from head teacher or college principal | UK – for 16 to 19 year olds in full time education – only used in exceptional circumstances if other documents cannot be provided | Must still be valid |
Please click here to view the new DBS ID checking guidelines for Basic applications that take effect when the DBS take over Basic applications for England and Wales from Disclosure Scotland when our system is updated on December 18th 2017.
