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When you manage background checks in Employment Hero that are processed through Zinc, you may need to manually verify a candidate's identity before the DBS (Disclosure and Barring Service) application can be submitted. This article explains when manual verification is required and walks you through the process of conducting and recording these checks in accordance with Zinc's procedures.
This article will show you how to manage the following:
- Identify when a manual identity check is required
- Complete a manual identity verification check
- Understand acceptable documents and routes
- Confirm verification in Employment Hero
- Manage name discrepancies
- Further information
Identify when a manual identity check is required
Employment Hero attempts to verify a candidate's identity digitally using the UK Digital Identity and Attributes Trust Framework. If this fails, you will need to complete a manual identity check before the DBS application can be submitted.
A manual check is required when the digital route cannot be completed. This typically happens because:
- A persistent issue with document quality such as blurriness was not resolved after six resubmission attempts
- The candidate provided a UK birth certificate and proof of National Insurance, which are not eligible for the digital route
- The candidate could not provide the identity documents required for the digital process
- The candidate's digital address history could not be verified at their current address
- The candidate reached the reset limit for a name or date of birth mismatch (three resets without a successful match)
Important
Manual verification applies to all DBS applicants, including volunteers, not just employees. Your organisation must retain a record of the documents checked for at least two years. This is a DBS compliance requirement. When a manual check is required, you will see an Attention Needed status in Employment Hero and receive an email asking you to complete the manual review.
Complete a manual identity verification check
You have three options to conduct a manual identity check. Use Option one wherever possible.
The candidate is physically present with their original documents. This is the default and preferred route.
During the in-person check, you must:
- See the original physical documents
- Check the likeness, authenticity, consistency, and validity of the documents
- Confirm the documents belong to the applicant by comparing them with the candidate in person
- Record which documents were checked by keeping copies or making a clear written record
- Retain that record for at least two years from the date of the check
- Document who performed the check, when, and how
You hold the candidate's original physical documents while the candidate joins via live video. Use this option only where Option one is not possible.
During the live video check, you must:
- See the original physical documents (you hold them)
- Check the likeness, authenticity, consistency, and validity of the documents
- Confirm the documents belong to the applicant by comparing them with the candidate on video
- Record which documents were checked and retain that record for at least two years
- Document who performed the check, when, and how
The candidate holds their original documents on a live video call with you. Use this option only in cases of remote working or other exceptional circumstances.
If you use Option three, the documents must still be verified in person before the candidate starts employment, at the latest on their first day. The check is not complete until in-person verification has taken place.
During the live video check, you must:
- Check the likeness, authenticity, consistency, and validity of the documents displayed on video
- Confirm the documents belong to the applicant by comparing them with the candidate on video
- Record which documents were checked and retain that record for at least two years
- Document who performed the check, when, and how
- Arrange a follow-up in-person verification before employment begins
Understand acceptable documents and routes
The document groups are the same regardless of DBS check type. The difference between a Basic DBS and a Standard or Enhanced DBS is the number of documents required at each route and the availability of a third route for Standard or Enhanced checks.
You must use Route one where possible. Move to Route two only if the applicant cannot provide Route one documents and only after discussion with the applicant confirming there is a valid reason.
Route one
- One document from Group one
- One further document from Group one, Group two a, or Group two b
- The combination must confirm the applicant's name and date of birth. A third document may be added if needed
Route two
- One document from Group two a
- Two further documents from Group two a or Group two b
- The combination must confirm the applicant's name and date of birth
If the applicant cannot meet Route two requirements, they cannot submit a Basic DBS application.
You must use Route one where possible. Move to Route two only if Route one is impossible, and to Route three only if both Routes one and two are impossible.
Route one
- One document from Group one
- Two further documents from Group one, Group two a, or Group two b
- The combination must confirm the applicant's name and date of birth
Route two
- One document from Group two a
- Two further documents from Group two a or Group two b
- The combination must confirm the applicant's name and date of birth
- Your organisation must also use an appropriate external ID verification service
Route three
- One birth certificate issued more than twelve months after the time of birth (UK, Isle of Man, and Channel Islands)
- One document from Group two a
- Three further documents from Group two a or Group two b
- The combination must confirm the applicant's name and date of birth
If the applicant cannot meet Route three requirements, they may need to be fingerprinted.
| Document | Notes |
| Passport | Any current and valid passport. A UK passport can be expired by up to six months |
| eVisa | Accessed via the View and Prove service. The applicant should request an immigration status share code |
| Biometric Residence Permit (BRP) | UK. A BRP showing Indefinite Leave to Remain, Indefinite Leave to Enter, or No Time Limit can be used up to eighteen months past the BRP expiry date |
| Application Registration Card (ARC) | Issued by the Home Office. Must be checked against the Home Office Employer Checking Service |
| Current driving licence photocard (full or provisional) | UK, Isle of Man, and Channel Islands. Must be current and valid |
| Birth certificate issued within twelve months of birth | UK, Isle of Man, and Channel Islands. Must be the original certificate |
| Adoption certificate | UK and Channel Islands |
| Document | Notes |
| Current driving licence photocard (full or provisional) | All countries outside the UK (excluding Isle of Man and Channel Islands). Must be current and valid |
| Current driving licence (paper version issued before March 2000) | UK, Isle of Man, and Channel Islands. Must be current and valid. All information including name and address must be up to date |
| Birth certificate issued more than twelve months after birth | UK, Isle of Man, and Channel Islands |
| Marriage or civil partnership certificate | UK and Channel Islands |
| Immigration document, visa, or work permit | Issued by a country outside the UK. Valid only for roles where the applicant is living and working outside the UK |
| HM Forces ID card or HM Armed Forces Veteran card | UK |
| Firearms licence | UK, Isle of Man, and Channel Islands |
| Document | Location | Issue Date or Validity |
| Mortgage statement | UK | Issued in last twelve months |
| Bank or building society statement | UK and Channel Islands. A printed statement stamped and signed by the bank is acceptable if hard copy statements are unavailable | Issued in last three months |
| Bank or building society statement | Countries outside the UK. Branch must be in the country where the applicant lives and works | Issued in last three months |
| Bank or building society account opening confirmation letter | UK | Issued in last three months |
| Credit card statement | UK | Issued in last three months |
| Financial statement (for example, pension or endowment) | UK | Issued in last twelve months |
| P45 or P60 statement | UK and Channel Islands. Original only, cannot be an online document or PDF printout | Issued in last twelve months |
| Council Tax statement | UK and Channel Islands | Issued in last twelve months |
| Letter of sponsorship from future UK employment provider | Valid only for applicants residing outside the UK at time of application | Must still be valid |
| Utility bill | UK. Not a mobile telephone bill. Cannot be printed from an online account | Issued in last three months |
| Benefit statement (for example, Child Benefit or State Pension) | UK | Issued in last twelve months |
| Central or local government or agency document giving entitlement | UK and Channel Islands (for example, letters confirming PIP, free school meals, Universal Credit, asylum support) | Issued in last twelve months |
| HMRC (Her Majesty's Revenue and Customs) self-assessment letter or tax demand letter | UK | Issued in last twelve months |
| European Health Insurance Card (EHIC) or Global Health Insurance Card (GHIC) | UK | Must still be valid |
| EEA (European Economic Area) National ID card | Must still be valid | |
| Irish Passport Card | Cannot be used alongside an Irish passport | Must still be valid |
| Cards carrying the PASS accreditation logo | UK, Isle of Man, and Channel Islands. Digital PASS cards are acceptable where issued by an approved digital PASS provider | Must still be valid |
| Letter from head teacher, college principal, or apprenticeship provider | UK. For sixteen to nineteen year olds in full-time education or an apprenticeship. For exceptional circumstances only | Issued in last month |
A deed poll, change of name deed, or similar document can explain why names differ, but it must not be counted as one of the required Group one, Group two a, or Group two b identity-route documents. These documents are not listed in the DBS document groups.
A UK or Channel Islands marriage or civil partnership certificate is different. It is listed as a Group two a document and can count where the selected manual route allows a Group two a document.
For example, for a Standard or Enhanced DBS Route one check, a passport plus utility bill plus deed poll is not enough because the deed poll does not count as a route document. The applicant needs one more valid listed Group one, Group two a, or Group two b document.
Confirm verification in Employment Hero
Once you have completed the manual identity check, you must confirm this in Employment Hero. Follow these steps:
- Go to the candidate's report
- Find the Identity Verification box
- Click I have verified their identity
This step creates an audit trail recording who completed the check and when. The DBS application cannot be submitted until you complete this step. Once confirmed, Employment Hero will automatically proceed with submitting the application.
If one person checks the documents and someone else clicks the verification button, Employment Hero records the name of the team member who clicks I have verified their identity. You can separately record the name of the team member who physically reviewed the documents in the candidate's report comments. If your organisation needs to show who physically inspected the documents (when different from the person who clicked in Employment Hero), keep an internal record such as the comments section of the candidate's report so it can be audited.
Manage name discrepancies
If the name on a candidate's documents does not exactly match their application form, do not automatically reject the documents. The DBS expects you to ask the applicant for clarification and satisfy yourself that the discrepancy is legitimate. If you are satisfied it is, make sure all name variations are captured on the application form.
If a candidate has recently changed their name through marriage, deed poll, or similar, they may not yet have updated all their identity documents. This is acceptable, provided:
- The change can be evidenced (for example, by a marriage certificate or deed poll)
- Both the old and new name are included on the application form, with "from" and "to" dates entered in ascending order
- You are satisfied the documents are genuine and the candidate's explanation is consistent
The DBS guidance does not set a specific timeframe for how recent the change must be. This is a judgment call. If the gap between the legal change and the check seems unusual, ask the candidate to explain.
This evidence explains the connection between names. It does not reduce the number of DBS route documents required. However, the document type still matters. A UK or Channel Islands marriage or civil partnership certificate is listed in Group two a and can count where the selected manual route allows Group two a. A deed poll or change of name deed should not be counted as proof of ID for the manual identity route.
A driving licence may not include a middle name, particularly if it was converted from a paper to photocard licence. If you accept a document with a missing or additional name, enter the applicant's full name (including the missing or additional name) as the current name on the application form. Leave the previous names section blank if the name has not actually changed. The document just does not show it in full.
Minor spelling differences such as an alternative spelling of a first name or a missing hyphen do not need to be entered as previous names unless the variation is materially different. Use the correct spelling as identified by the applicant. If the variation is significant enough to affect how records might be searched, enter it as a previous or other name.
For any name discrepancy you have resolved, note in your records that there was a discrepancy, what the candidate's explanation was, and that you were satisfied it was legitimate. Employment Hero's comments section on the candidate's report is a practical place for this.
Further information
In all manual identity checks, you are assessing the following four elements:
- Likeness: Do the documents match the person in front of you
- Authenticity: Do the documents appear genuine
- Consistency: Do the documents agree with each other on name, date of birth, and other details
- Validity: Are the documents current and within any applicable expiry limits
Does the manual check process apply to volunteers?
Yes. The manual verification process and all associated obligations, including document retention, apply to all DBS applicants regardless of whether they are employed or volunteering with your organisation.
Do we need to retain copies of the identity documents?
Yes. You must retain a record for at least two years from the date the check was completed. This can be copies of the original documents or a clear written record of the document details. You must be able to evidence who performed the check, when, and how.
Why cannot Employment Hero submit the DBS until I complete the manual verification step?
The DBS requires identity to be verified before an application can be submitted. Until you click I have verified their identity in Employment Hero, the application remains on hold. This step also creates the audit trail required for compliance.
Can one team member check the ID documents and a different team member confirm in Employment Hero?
Yes, as long as your organisation keeps an auditable record of who physically verified the ID. Employment Hero will only log the team member who clicks I have verified their identity.
Can I accept foreign versions of UK-only documents?
No. If a document is marked as UK-only in the document lists, you must not accept a foreign equivalent.
What is the difference between Option two and Option three for the manual check?
In Option two, you (the checker) physically hold the candidate's original documents during a live video call. In Option three, the candidate holds their own documents during the call. Option three carries an additional requirement. The documents must still be verified in person before employment or volunteering begins.
What if the candidate cannot provide any of the required documents?
For a Basic DBS, if the applicant cannot meet Route two requirements, they cannot submit an application. For a Standard or Enhanced DBS, if the applicant cannot meet Route three requirements, they may need to be fingerprinted. Contact Employment Hero Support if you are unsure how to proceed.
About this article
This article provides guidance based on Zinc's DBS manual identity verification procedures. For the complete official documentation and detailed guidance, visit Zinc's Help Centre article on manual identity verification for DBS checks.