What is your role and how have you worked with Department for Digital, Culture, Media and Sport (DCMS) to introduce Digital Identity for DBS checks?
Within my role as Head of Identity at DBS, I look after the introduction of digital ID checks into DBS products and service offerings. We have worked closely with DCMS to align DBS digital identity requirements (DBS Trust Scheme) to the UK digital identity and attributes trust framework, allowing DBS to become one of the first user cases for DBS checks, alongside the Home Office and the Right to Work and Right to Rent checks.
What would you say to employers, or candidates who are uncertain about adopting digital ID checks and benefits you can see from it?
Whilst we introduce digital identity checking, DBS will also be maintaining existing routes for employers and candidates. However, digital identity service providers (IDSP) will allow people to upload images of their personal documents to verify their identity remotely and submit electronic DBS checks. Working time and hours spent undertaking checks will be reduced, as employers will no longer need to physically examine identity documents. Providers of digital identity check services will also be able to carry out checks on behalf of employers at scale, for example in large recruitment campaigns when a high number of new employees are recruited.
How does the framework work and what obligations will a registered body have?
The DCMS Trust Framework sets out the rules and standards for digital identity verification. These rules not only apply to DBS checks but in future will also be used by other industry sectors such as pensions and finance, travel, age verification and home buying and selling. This means an identity used in one sector can be used for another purpose, thereby enabling interoperability. The DBS and right to work/right to rent identity trust schemes are the first Government sectors to adopt the Trust Framework and require an identity provider to certify their products and services to the standards set out in the new Framework.
The role of the Registered Body (RB), as the relying party, is to ensure identity checks are compliant with DBS requirements. In practice, this means using a certified IDSP to ensure the appropriate level of identity assurance is achieved and the applicant’s current address is verified prior to applications being submitted.
There seems to be some uncertainty about when digital ID checks can be used. Can you shed some light on the process which needs to be followed to allow a registered body to use a digital identity solution, and the timeline for this?
DBS published its identity trust scheme in January 2022. However, the scheme requires Identity Service Providers (IDSPs) to be certified by the DCMS Trust Framework. The audit and certification phase is currently ongoing for the IDSPs, and once approved RBs may contract with IDSPs (or seek IDSP accreditation themselves) to process DBS checks.
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So a registered body will have to wait for IDSP’s to be certified, and then look to integrate a certified provider into the current journey?
That’s right. Once an IDSP has been approved by DCMS, their name and the confirmation of their certification will be published on GOV.UK.
Will digital ID checks work alongside manual document checking and not be a direct replacement?
Yes – we have been very clear within digital identity guidance that manual document checking is equivalent to the digital identity checking guidance. That means organisations have a choice on which method to use when processing an application.
How will an employer know that a registered body they work with is using a certified identity provider?
DCMS will publish certified IDSPs via GOV.UK and which trust schemes they have been approved for (either DBS checks, Right to Rent/Right to Work, or both). Employers will be able to confirm with RBs that the IDSP is one of the listed providers. DBS will also receive, as part of the application, the name of the IDSP and will be auditing RBs to ensure only certified providers are being used.
How will digital ID checks affect what documents people can use when applying for a DBS check?
DBS has always been very prescriptive about which documents an applicant can use to verify their identity. This varies based on if they are a UK or overseas applicant, and if the role is paid or voluntary.
The digital approach to identity verification allows DBS to specify a Level of Confidence which must be met in order to confirm the identity is genuine. For Enhanced and Standard DBS checks, DBS specify a high level of confidence, and for a Basic DBS check, DBS specify a medium level of confidence.
IDSPs will support applicants to achieve the required level of confidence using a range of identity documents and proofing techniques, dependent on what the applicant holds. The strongest piece of documentary evidence is a Passport containing a biometric chip. DBS recommend an applicant always use the strongest available document they hold.
Some people may worry about digital ID checks – how secure are they?
The Trust Framework outlines the standards an IDSP must meet to ensure the data being processed and stored is secure. IDSPs who achieve certification will have a proven the provision of sufficient Information Security Management Systems (ISMS), compliance with the Data Protection Act and the necessary fraud controls. The current version of the DCMS Trust Framework can be viewed here: UK digital identity and attributes trust framework – alpha version 2 – GOV.UK (www.gov.uk)
Can you clarify identity vs eligibility – for example, will an identity check in isolation be enough for a registered body to process a criminal record check?
Eligibility for Standard or Enhanced DBS checks is still a matter for the employer and RBs to establish in line with DBS guidance. Once eligibility for these checks is established any identity verified by a certified IDSP to the appropriate level of confidence can be used.
Finally, we share a passion for digitisation of the recruitment process – what’s next? Will we be seeing a digital version of the certificate and do DBS have any further plans?
We share that passion also and appreciate digitisation will help speed up the recruitment process and help people into work quicker. From an identity perspective we will be doing more work to support marginalised groups to prove their identity remotely. These are people who may not have access to the necessary technology or hold the right documents.