Identity checks

COVID-19 indemnity and litigation

Seeking high levels of assurance about a person's identity during COVID-19 continues to be of primary importance as this is essential to validate all other pre-employment checks that need to be obtained as part of the recruitment process. 

The temporary measures outline how employers verify a person's identity remotely while government restrictions on staying safe by social distancing still apply. These adjustments are aligned to guidance issued by the Home Office on right to work checks and the Disclosure and Barring Service in regard to obtaining criminal record checks. It is recommended that all three checks are verified at the same time to avoid any unnecessary duplication of requirements which may be challenging at this time.

It is important to note that these temporary measures only apply where it is not safe or practical to follow normal checking procedures outlined in the identity check standard.

Further information about right to work and criminal record checks can be found under COVID pre-employment checks and assurances section of the NHS Employers website.

How to conduct the verification of identity check

1. Ask the applicant to provide a scanned copy or photo of their original identity documents via email or by using a mobile app/ This should include one of the following combinations:

Combination 1:

  • two forms of photographic personal identification
  • one form of identity showing the applicants' current residing address

Combination 2:

  • one form of photographic personal identification
  • two forms of identity showing the applicants' current residing address

Combination 3:

  • A current passport-compliant photograph of themselves. NB: employers can temporarily accept expired passports, as long as they are within six months of their expiration date, as proof of identity
  • two forms of identity confirming their current residing address
  • two forms of non photographic identity

A list of recommended forms of identity can be found in Appendix one of the identity check standard.

2. Arrange a video call with the individual and ask them to hold up the original documents to the camera and check them against the digital copies sent by email or mobile app.

3. Record that a check has been done remotely because of COVID-19 and the date of that check.

Employers must continue to seek original documentation as soon as practical. As a minimum, individuals should be asked to show one form of photographic personal identity when they first take up the position or are required to undertake induction or other type of training. Other original documents may need to be presented at this point, if they have not already been seen and validated earlier in the process (e.g. where the interview was conducted face to face).

Employers should be mindful, that because of COVID-19, some individuals may be unable to provide the necessary documentary evidence. During this period, employers must take extra care to ensure applicants are not discriminated against because they genuinely cannot present the prescribed range of documents. In such cases, employers should take a risk-based approach to recruitment based on the range of documents applicants can reasonably provide at this time.

Seeking assurances

Every assurance should be obtained to ensure documents are bona fide and the identity can actually be attributed to the individual being appointed. Including checking that photographs are a true likeness of the person presenting themselves.

Documents containing biometrics, registration/issue numbers or other security features should be verified in the usual manner utilising any digital platforms which are available such as, the Home Office settlement scheme/employer checking service or the DVLA. These platforms not only help to provide assurance about the document's integrity and validity, but it may also provide the necessary assurances that a document has not been reported as lost or stolen and therefore may be subject to identity fraud.

For other documents such as bank and utility statements, we recommend that these are validated by asking the applicant to access their account while on the video call and a screenshot taken of any relevant information so that this can be retained on file.

Where checks return information that contradicts the details provided by the applicant and raises concerns, employers should:

  • proceed in a sensitive manner, there is often a reasonable explanation for apparent inconsistencies
  • attempt to address any concerns directly with the applicant.

In exceptional circumstances, where checks reveal substantial misdirection, employers may feel in appropriate to report these concerns to the NHS Counter Fraud Authority or the local police. Employers can also call the 24-hour fraud and corruption reporting line on 0800 028 40 60.





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