The UK Government’s Digital Identity and Attributes Trust Framework (DIATF) is now live, governing the way Right to Rent, Right to Work and DBS checks are conducted online. As a certified Digital Identity Service Provider (IDSP) to provide digital identity verification, GBG is on hand to help organisations to understand the new guidelines.
Some of the most commonly asked questions are covered below, along with a helpful list of acronyms.
IDSP: Identity Service Providers
IDVT: Identification Document Validation Technology
GPG-45: Good Practice Guide 45 (government standard for verifying an identity)
RTR: Right to Rent
RTW: Right to Work
DBS: Disclosure and Barring Service
When does this change come into effect?
From 30th September 2022 all remote checks governed by the Trust Framework schemes for RTR, RTW and DBS must be completed using IDVT.
What is IDVT?
Identification Document Validation Technology refers to the identify verification process that must be undertaken to conduct one of the applicable checks online.
What checks are covered by the Trust Framework?
Right to Rent, Right to Work and the Disclosure Barring Service (DBS) for basic, standard and enhanced checks.
Is this process mandatory?
From 30th September, yes – but any checks completed using the process that was in place prior to the deadline don’t need to be reconducted retrospectively.
Do landlords and employers have to use a certified IDSP?
It’s not mandatory for RTR and RTW checks to be carried out by a certified IDSP (although likely will be in 2023), but it is recommended by the Home Office – it is the landlord/employer’s responsibility to ensure that the IDSP has conducted the check correctly (if not, it is invalid) so using a supplier that has been certified to meet the framework is essential to provide the necessary confidence.
For DBS checks, employers must use a certified IDSP.
What happens if the RTR check is not completed compliantly?
If the check has not been carried out compliantly, it is void and the penalties could apply (which for landlords includes unlimited fines and even prison for renting a property to someone who is not permitted to live in England).
What happens if the RTW check is not completed compliantly?
The employer remains liable for the civil penalty (even when working with an IDSP) and if it’s found that the employee is working without the requisite permission and it is reasonably apparent that the check has not been completed correctly.
The Trust Framework refers to levels, what does this mean?
The Trust Framework specifies the level of confidence required for each check.
For RTR, RTW or DBS (basic) – A medium confidence level is required
For DBS (standard) or DBS (advanced) – A high confidence level is required
What about individuals who don’t have a UK or Irish passport or Irish ID card?
The Trust framework supports UK/Irish nationals only, so a different journey is required for non-UK/Irish nationals (the share code process is used to confirm eligibility of non-UK/Irish nationals).
The framework may be extended in future to incorporate other nationalities, but that would be up to the government.
What if the automated check fails?
The IDVT is responsible for providing the result of the identity check, which cannot be changed. If the first check fails, the guidance states that there must be an alternative route available for the individual to be validated through.
GBG’s Identify offering provides multiple profiles that can be applied and if the individual is not able to pass via the automated route there is a team of identity document experts who can complete the check manually.
When is a RTR check required?
Before the start of a new tenancy, all tenants aged 18 and over, even if:
When is a RTW check required?
All employers are required to conduct RTW checks for all prospective employees.
Not all companies advertising IDSP services have achieved the accreditation, you can check if they have by consulting the list of certified IDSPs on the UK Government Trust Framework website.
It is important to use a certified provider to make sure that they are working to the standards required – remember, it is your responsibility to make sure that the IDSP is fulfilling their obligations, if they are not, the check becomes invalid, and the statutory excuse is void. Do you have a clear understanding of the components of the check to make sure that you are satisfied that the IDSP is fulfilling their obligations?
Certification is awarded at product level, so even when an organisation has achieved certification, this does not automatically cover their entire product offering. Make sure that the product or service that you are procuring is certified to the Trust Framework.
The Trust Framework mandates that the IDSP must provide alternative routes for approval should the identity check be unsuccessful in the first instance. Whilst IDVT is extremely reliable, candidates may have technical issues (such as problems with their mobile phone camera) which prevent them from successfully passing an automated process.
Offering a manual verification route is essential for providing an inclusive journey and ensuring that all candidates can be verified. Only a certified IDSP can provide this approval because their process has been audited and certified. The alternative is to conduct an in-person check which is likely to be costly and time-consuming. Ensuring that your supplier has a robust manual process means that you can provide an efficient journey for all candidates.
Check with your supplier to understand the process – is the document review team based in the UK? If not, does this impact response times and are you satisfied with data leaving the UK? What are the availability times for this team and are there instances when candidates may be waiting a long time to be processed?
Long delays to the manual review will create a poor experience for the end user, possibly resulting in application abandonment.
Many organisations worked quickly to create a product that could be certified in accordance with the Trust Framework in order to be ready for the deadline of 30th September 2022, when the online checking process introduced as a response to the covid pandemic ended and the requirement for IDVT became live.
Some suppliers based their offerings on temporary agreements, or on data or functionality that is not likely to be sufficient to pass their next certification. Partnering with a supplier that may need to perform significant changes to their product or may lose certification can introduce significant risk to your business. Make sure to ask your potential supplier about any upcoming significant changes that might affect your usage and think about the impact it would have on your business to be without an IDVT process should any issues arise.
In today’s competitive recruitment environment, it is essential to keep candidates engaged and process their application as efficiently as possible. Getting off to a great start with applicants is important – what will they experience? Is it a seamless, user-friendly experience? Make sure to understand the candidate journey to make sure that it meets your expectations and will send the right message to your future employees.
How long has the company been trading? Do they have experience in this area? Are they successful? When choosing a partner to perform an integral service, make sure that they have the relevant experience and expertise, and that they have a long and secure future.
Will you have access to an Account Manager? Who can you contact to obtain support and answer your questions? Is there a helpdesk to assist your end users? These elements will prove invaluable to ensure that the process starts and continues smoothly.