Vouching for DBS Checks: IS IT Compliant?
Vouching is a straightforward but uncommonly used method of confirming someone’s identity. It's generally used in situations where an individual doesn’t have enough proof of identity. Essentially, it's when a professional with a good reputation, like a teacher or a doctor, confirms someone's identity.
The vouching process is simple: a person needing their identity verified reaches out to a qualified professional. This professional, based on their knowledge and relationship with the individual, vouches for their identity.
However, it's important to make it clear that vouching isn’t suitable in all situations, one of which is when applying for DBS Checks.
We'll explore more about where vouching fits in and where it doesn't, especially in the context of DBS checks, in the following sections.
Why is vouching needed?
Essentially, vouching is a method of identity verification that can be done without traditional ID documents. This is either down to practicality or because the individual doesn’t have the documents.
A common example is when registering for certain GP services. Members of practice staff can vouch for a patient's identity if they have known them for several years. Even if the patient is unknown, they can vouch for their identity by asking them to confirm information from their patient record. Doing this means that patients can sign up to services they need without having to go away to collect documents to confirm their identity.
Another situation is with teenagers, applying for proof of age ID cards. It's extremely common for under-21s to not have enough or appropriate proof to confirm their identity. A teacher who knows the pupil could vouch for their identity when they’re applying for an ID card. This is because they have known the individual for several years and can confirm it is a real identity.
Who can vouch for someone’s identity?
When it comes to vouching, not just anyone can step in. The UK government has a specific list of professionals who are considered trustworthy enough to vouch for someone's identity.
The positions of authority who can vouch for people are:
accountant
administrator (permanent) at a GP or dentist’s surgery
administrator (permanent) at a school, college or university
airline pilot
bank, building society or credit union official
registered care home manager
registered chiropodist (also known as ‘podiatrist’)
civil servant
commissioner for oaths
councillor, for example a local or county councillor
dentist
registered dietitian
director of a limited company
doctor or surgeon
engineer or technician (professionally registered with the Engineering Council)
financial services intermediary, for example a stockbroker or insurance broker
fire service official
funeral director
High Court enforcement officer
insurance or assurance agent (chartered)
Jobcentre Plus work coach
Justice of the Peace
lawyer, barrister or solicitor (including trainee solicitors and anyone on a Legal Practice Course or Bar Practice Course)
legal secretary (fellow or associate member of the Institute of Legal Secretaries and PAs)
licensee of a public house
local government officer
manager or personnel officer of a limited company
member, associate or fellow of a professional body
Member of Parliament
Merchant Navy officer
minister of a recognised religion
notary
registered nurse
officer of the armed services
registered optician
paralegal (certified paralegal, qualified paralegal or associate member of the Institute of Paralegals)
registered pharmacist
registered physiotherapist
police officer
Post Office official
president or secretary of a recognised organisation
probation officer
social worker
solicitor
surveyor
teacher or lecturer
trustee of a registered charity
valuer or auctioneer (fellow or associate members of the incorporated society)
Warrant Officers and Chief Petty Officers
You cannot accept a vouch from anyone who is not named in the list above.
What makes these individuals suitable for vouching is that they are considered to be in positions of authority in the community. In a lot of cases, they will have had to confirm the individual's identity themselves already.
Vouching and DBS Checks: Non-Compliance
The DBS's stance on vouching is rooted in both legislation and its own Code of Practice. The Police Act 1997, specifically The Criminal Records (Registration) Regulations 2006, sets the groundwork.
The Conditions of Registration state:
7 (f) prior to making a statement under section 113A(2)(b) or 113B(2)(b) of the 1997 Act in relation to an application for a criminal record certificate or an enhanced criminal record certificate, a registered person or his authorised agent shall verify the identity of the applicant and in so doing comply with such conditions as the Secretary of State thinks fit and has notified to the registered person in writing;
(g) where a registered person uses the services of another person to verify the identity of applicants, the registered person shall—
(i) ensure the suitability of that person to conduct such checks;”
This means that registered persons must verify a DBS applicant's identity themselves, or, if using an ‘authorized agent’, then this person as the ID verifier needs to have some kind of relationship with the applicant being verified.
The DBS Code of Practice reinforces this, emphasizing the need for a direct relationship between the verifier and the applicant. This approach ensures a more thorough assessment when compared to the broad criteria allowed by vouching.
These broad criteria mean that the vouching process could potentially be abused in the context of a DBS application. With the complexity of modern criminals, it would be no difficult feat to fake or forge the credentials of an applicant and an ID verifier and essentially bypass a proper DBS Check.
So, while vouching is accepted in some contexts, its use in DBS checks contradicts these specific legal and procedural requirements.
You can find the full code of practice here.