Legal and Professional Standards Department - Authentication procedure for new employees (P04a)

1. Summary of changes

1.1. This standard operating procedure (SOP) was reviewed in October 2023 - no amendments to content have been made. 

2. What this procedure is about

2.1 This SOP is about the authentication procedure that must be completed by those responsible for recruiting individuals, be they employed by, or working in partnership with Kent Police, before vetting is undertaken. In respect of Kent Police officers and police staff, this procedure is carried out by HR Recruitment.

2.2 Authentication, when supported by recruitment vetting (RV), incorporates all aspects of His Majesty’s government (HMG) Baseline Personnel Security Standard (BPSS), and is therefore a pre-requisite for all levels of force vetting (FV) and national security vetting (NSV).

2.3 Authentication is used to confirm an individual’s:

• identity
• nationality
• employment eligibility
• residency qualification

2.4. Authentication approval does not allow access to police classified assets or unescorted access to any police premises.

2.5. The BPSS is a specific level of clearance within HMG. However, the BPSS, on its own, is not an acceptable level of clearance for the requirements of the College of Policing's Vetting Code of Practice and APP Vetting. All aspects of the BPSS have been incorporated within this authentication policy, other than references, which are included in the recruitment process.

2.6. The authentication procedure underpins all levels of force vetting and national security vetting.

3. Detail the procedure

3.1. Identity check

3.1.1 Verification of identity is essential before any individual can begin their appointment. Identity can be verified by physically checking a range of appropriate documentation (e.g. passport or other photo identification together with utility bills, bank statements, etc).

3.1.2 Proof of identity (e-government interoperability framework) (E-GIF) - Identity will be verified in accordance with E-GIF level 3 by production of at least one form of photographic identification and two other forms of non-photographic identification. Where applicants do not have photographic identification it is expected that they obtain this prior to making an application.

3.1.3 The increasing availability of good quality false documentation makes establishing identity difficult; particularly so if un-trained and busy line managers are expected to spot sophisticated fraudulent documents. However, unless identity is confirmed, any other checks that might be undertaken become meaningless.

3.1.4 During the recruitment process, and in advance of any firm offer of appointment, individuals must, as a minimum, be asked to provide:

• confirmation of name, date of birth and address
• national insurance number or other unique personal identifying number where appropriate
• full details of previous employers (name, address and dates)
• confirmation of any necessary qualifications/licences
• educational details and/or references when someone is new to the workforce when these are considered necessary
• confirmation of permission to work in the UK (a separate verification of nationality and immigration status should still be carried out prior to the commencement of appointment and must be undertaken if an excuse against a civil penalty liability is to be obtained by the employer). This information must be checked to ensure that there are no obvious gaps and that it is consistent by cross-referencing the data provided

3.1.5 The individual’s full name and signature, date of birth and full permanent address should be corroborated using as many of the following qualifying documents as is considered necessary on a case-by-case basis. If, in exercising risk management, the required level of assurance can be obtained by the production of a single document, this must include a photo of the individual. Any photograph or identifying information (such as date of birth indicating age) contained in the corroborating document should be compared with the physical appearance of the individual.

3.1.6 Where a signature has not been provided (e.g. because of an e-application) the individual should be asked to provide it at a later date (e.g. at interview) for checking against relevant documentation. It is also good practice to request the same documentation the subject presented at interview on the first day of appointment.

3.1.7 Only original documents should be used for identification purposes. Copies are not acceptable.

• current signed full passport, travel document national ID card and/or other documentation relating to immigration status and permission to work
• current UK photo-card driving licence 
• current full UK driving licence (old version)
• current benefit book or card or original notification letter from the Department for Work and Pensions (DWP) confirming the right to benefit
• building industry sub-contractor's certificate issued by His Majesty's Revenue and Customs (HMRC)
• recent HMRC tax notification
• current firearms certificate
• birth certificate (issued within six weeks of birth)
• adoption certificate
• marriage certificate
• divorce, dissolution or annulment papers
• civil partnership certificate
• recent original utility bill or certificate from a utility company confirming the arrangement to pay for the services at a fixed address on prepayment terms
• local authority tax bill (valid for current year)
• bank, building society or credit union statement or passbook containing current address
• recent original mortgage statement from a recognised lender
• current local council rent card or tenancy agreement
• court order

3.1.8 There is no definitive list of identifying documents and not all documents are of equal value. The ideal is a document that is issued by a trustworthy and reliable source, is difficult to forge, has been dated and is current, contains the owner’s name, photograph and signature, and itself requires some evidence of identity before being issued (e.g. a passport).

3.1.9 Where individuals do not have photo ID, they should be asked to provide additional identifying documents from the list. Where they are unable to provide adequate identifying documents (e.g. because of age, lack of residence, etc), departments and agencies should exercise discretion taking into account all other material obtained through the recruitment process. Where this appears genuinely to be a problem, the individual should be asked to provide a passport sized photograph of him/herself endorsed on the back with the signature of a person of some standing in the individual’s community (e.g. a GP, medical practitioner, officer of the armed forces, teacher, lecturer, lawyer, bank manager, civil servant, etc.) and accompanied by a signed statement, completed by the same person, stating the period of time that the individual has been known to them (minimum three years). The statement itself should always be checked to ensure that the signature matches the one on the back of the photograph and that it contains a legible name, address and telephone number. The signatory should be contacted to confirm their status and check that he or she did, in fact, complete the statement.

3.1.10 In circumstances where verification of identity was not straightforward but a decision is nevertheless taken to appoint the individual(s), departments and agencies must accept and record any associated risk.

3.1.11 In examining documents, the following simple steps can assist:

• when checking documentation it should be remembered that a small proportion of applicants may not be who they say they are. There can be a number of reasons for this including concealment of birth, illegal immigration, concealment of identity for the purpose of crime, terrorism or espionage, benefit fraud or tax evasion
• insist that original documents are produced and not transcripts or photocopies
• examine the documents to ensure they are originals – modern photocopiers produce excellent results. Compare them with other examples you may have to hand
• check that the paper and typeface are similar to any others you may have to hand, or may have examined already. Check also that the watermark, where appropriate, is present (passports and driving licences contain a watermark)
• examine the documents for alterations or signs that the photograph or signature have been removed or replaced
• check that any signature on the document tallies with other examples in your possession. If in doubt ask the applicant to sign the document in your presence
• check that details given in the documents produced correspond with what you already know about the individual
• take care to note the date of issue of documents produced to you. Particular care should be taken in respect of documents that have been issued recently, especially if the documents are new, and there is a lack of corroboration from other sources, for example if the applicant is unable to provide suitable referees.

3.2. Nationality check

3.2.1 Verification of nationality and immigration status (including an entitlement to undertake the work in question) is required. Nationality and immigration status can be verified by physically checking appropriate documentation or, in exceptional circumstances only, by means of an independent check of UK Visas and immigration records. Departments must take the necessary steps to ensure that an individual has the right to remain in the United Kingdom and undertake the work in question.

3.3. The Immigration, Asylum and Nationality Act 2006

3.3.1 Immigration and nationality checks are based on the current provisions on preventing illegal migrant working in the UK as set by the Immigration, Asylum and Nationality Act 2006. These provide that an employer may be liable for a civil penalty by employing someone subject to immigration control aged over 16 who does not have permission to be in the UK or to undertake the work in question. An employer may establish an excuse against this civil penalty liability by undertaking specific documentary checks on the individual before the employment commences in accordance with the Immigration (Restrictions on Employment) Order 2007. View further details and a list of the documents required to establish a statutory excuse. 

3.3.2 Whilst government departments and agencies may have no civil penalty liability because of crown immunity, they are still required to undertake all appropriate document checks. Where the individual has a limited entitlement to remain in the UK, repeat checks should be undertaken not less than 12 months after the previous check was undertaken or, if sooner, before the previous leave has time expired. This will ensure that migrant workers will not be able to continue working after their leave has expired up until the next annual check. These checks will not be required once the appointee can demonstrate that he or she has indefinite leave to be in the UK by producing appropriate documents or the appointment comes to an end. Documents that demonstrate that the employer has established an excuse from a liability for appointing an illegal migrant worker must be retained during the period of employment and for not less than two years after the employment has come to an end.

3.3.3. Comprehensive guidance for employers is available. This includes images of immigration documents and two Codes of Practice (on the civil penalty and how to prevent illegal working whilst avoiding unlawful discrimination). It also contains further information on the Workers Registration Scheme.

3.4. Verification of immigration and nationality documentation – sources of further guidance

3.4.1 The PRADO Public Register of Authentic travel and identity documents online contains images and information relating to passports, visas, residence permits, driving licences and other identity and travel documents issued by EU member states. This includes details of their first level security features and how to check their authenticity. The website is available in all the official languages of the EU.

3.5 Residency criteria/checkable history

3.5.1 See SOP PO4k.

3.6 Process

3.6.1 After the four-stage authentication process has been conducted the following checks should be carried out:

References:

• Business Centre send for references, which must include employment history for the past three years (required for BPSS)
• referee coverage can give a level of assurance as to identity, particularly where the reference is provided by a reputable organisation or by someone known to members of the force. References can be easily forged and should be treated with caution

Other checks:

• Business Centre examine academic qualifications if appropriate
• Business Centre submit applicants' details to the Central Vetting Unit who will carry out appropriate checks, in accordance with the Vetting Code of Practice and APP Vetting. On completion a vetting team leader will issue vetting clearance or refusal and retain documentation on the central vetting database, Corevet

3.7. Counter Terrorism and Security Act

3.7.1. The Counter Terrorism and Security Act 2015 places a duty upon specified authorities (which includes the police) to ensure that their functions are discharged having due regard to the need to prevent people being drawn into terrorism. Our staff are not immune from radicalisation, therefore if such concerns regarding an individual or institution are identified, these should be referred to the Kent Police Prevent Team via the FIMU at Kent SB JIU.

4. Equality Impact Assessment (EIA)

4.1 An EIA has been carried out and shows the proposals in this policy would have no potential or actual differential impact on grounds of race, ethnicity, nationality, gender, transgender, disability, age, religion or belief or sexual orientation.

5. Risk assessment

5.1 This SOP has been assessed as medium risk.

6. Consultation

• Human Resources
• Business Centre
• Central Vetting Unit
• Health and Safety
• IT Security
• Legal
• FOI
• Finance

7. Monitoring and review

7.1 This SOP will be monitored, and reviewed after two years, by the Force Vetting Manager. The monitoring will take into consideration any changes in relevant legislation or procedures impacting on the authentication procedure.

8. Other source documents

None listed.

9. Security

9.1 Kent Police has measures in place to protect the security of your data in accordance with our Information Management policy (Policy W1000 – Information Management).

10. Retention and disposal of records

10.1 Kent Police will hold data in accordance with our Records Review, Retention and Disposal policy (Policy W1012 – Records Review, Retention and Disposal).