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March 16, 2020
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COVID-19 (coronavirus) updates

We have published and sent to all clients our current plans to mitigate any impact of the COVID-19 (coronavirus) pandemic. This document is designed to reassure clients that we are working hard to continue providing the services they need, while maintaining our robust security and data protection measures and ensuring the safety of our colleagues and their families.

Clients with access to our portal can see a copy of the plan here. All other updates will be posted below.

26 March 2020, 17:25

Multiple updates related to various checks

As various countries and data sources decide on how best to enact contigency plans to lesen the impact of coronavirus, we're starting to understand more how this may impact the background screening sector. Here are the latest updates that we have for you today:

Please note: some of these updates may be repeated from earlier updates and act as a reminder.

Right to Work verification – right to Work Audit (UK)

The Home Office are not aware of any immediate decisions to relaxing the rule around face to face meetings and the need for original documents. Any updates will be announced on their website. Therefore, existing requirements remain in force:
There has been some relaxation around visa regulations. You can read more about these at the Home office website.

Right to Work verification - Right to work (UK) aka as Conditional Right to Work check

There is significant disruption at present.  We are hopeful that the current backlog will be resolved over the weekend.

Criminal Records Checks - Northern Ireland

AccessNI has partially activated the Priority Plan their coronavirus Contingency Plan. As of today, Registered Bodies can request an urgent check of the Barred Lists to enable individuals to begin work in advance of completing a full AccessNI check.

This service is only available for positions where the applicant is urgently required to undertake work in response to the current COVID-19 crisis and must be followed up with a full Enhanced Disclosure Application in the normal way.

Driving Licence -  Northern Ireland

We have been unable to speak directly with the DVA but were reassured last week that it was business as usual.  They have an automated message advising that all first time licence applications and some other applications are suspended until 22 June 2020 and that no calls will be answered.

We will continue to seek confirmation of the disruption but at this time it is expected that delays are inevitable.


No disruption to service at this time

Criminal records assistance and validation (SAR) 

The Spanish Parliament extended emergency measures until 12 April 2020. Whilst the document required to process the check can be posted to the Ministry of Justice, each candidate is required to submit an ID document that has been stamped by a Notary Public. Given the current lock down restrictions, we expect significant delays

Italy National Criminal, Civil and Bankruptcy Search

Whilst we are able to place these checks, we expect significant delays in receiving results

India Criminal Record Check

Whilst we are able to place these checks, we expect significant delays in receiving results

Lithuania Police Criminal Record Check

Not available at this time

France Criminal Record Extract

This remains unavailable. From 16 March the National Criminal Records has participated in the effort essential to curb the spread of the COVID-19 coronavirus. Consequently, no request for a criminal record extract (Bulletin 3) can be processed, whether it is sent by digital or postal mail, and telephone reception is no longer guaranteed.

Senegal Criminal record check

Senegal has joined the list of countries on lockdown. We are able to place orders but expect delays to receiving results

Poland Criminal record check

Polish Mail have resumed distribution of Registered mail, we are able to place checks but expect delays to receiving results

Cyprus Certificate of Character

The Authorities have confirmed they will accept digitally signed applications and authority forms meaning candidates are no longer expected to post documents to Verifile.  

Switzerland Extract from the Criminal Record

Whilst we are able to place these checks, we expect significant delays in receiving results.

25 March 2020, 09:10

DBS allows temporary video I.D. verification for all checks

The Disclosure and Barring Service (DBS), has allowed a temporary relaxing of their identity verification requirements in response to the coronavirus lock down.

They are now allowing candidates’ identity to be verified via video link or by sending a scanned electronic copy to employers or their agents for Basic, Standard and Enhanced checks.

Previously they had only relaxed these rules for Standard and Enhanced checks.

In an advisory sent to Verifile, they said:

"Due to current measures that have been put in place as a result of the coronavirus outbreak, we’re aware that organisations are having difficulty following the DBS ID checking guidance.

"Currently, when validating ID documents, it is best practice to carry the examination out face-to-face with a live video link as an alternative method. Under the current guidance, the ID checker must be in physical possession of the original documents so they can be checked for indicators of fraud.

"As the public is being advised to work from home where possible, this is causing difficulties in receiving the physical documents and is delaying applications, and in some cases, preventing applications from being submitted.

"To ensure that the necessary DBS checks can still be carried out, the DBS ID checking guidance will be changed for a temporary period. The change will come into effect immediately."
The changes allow:
  • ID documents to be viewed over video link 
Or, if it is not possible to verify documents via video link:
  • Scanned images can be viewed in advance of the DBS check being submitted
  • The DBS also advised that this change should only be implemented for urgent cases where it is not possible to follow the normal identity checking guidelines
Under the relaxed guidelines, the applicant must also present the original versions of these documents when they first attend their employment or volunteering role.
In addition: 
  • Similar relaxations were announced by Disclosure Scotland and AccessNI
  • Turnaround Times for DBS checks are being treated as a priority with the government committed. PM Boris Johnson said: "We are speeding up the DBS checks so they can be done in 24 hours and I want to thank and congratulate all the boroughs throughout this country for the way they are harnessing those volunteers.”
  • You can follow live updates on how Verifile is adapting to mitigate the affects of coronavirus here.
For more information on these changes and how they will help you to continue running background checks during this unprecedented time, please contact your account manager or the Client Services Team on +44 (0) 1234 339 350 or via email service@verifile.co.uk

20 March 2020, 15:10

Disclosure Scotland to prioritise key checks

Disclosure Scotland is working closely with the Scottish Government and key stakeholders on their response to the COVID-19 pandemic. They have also invoked their Business Continuity plans to prevent any disruption to safeguarding services at this time of crisis.

The organistaion says they will also prioritise checks for those who have the most sensitive roles in supporting this crisis. The criteria for prioritisation is based upon the roles: 
  • Healthcare
  • Pharmaceutical
  • Childcare
  • Social work
  • Social care
  • Prisons and justice
They add that the list of key roles may change as the situation develops and evolves.

If you have any questions, please contact your Account Manager or Client Services on +44 (0) 1234 339 350 or service@verifile.co.uk

20 March 2020, 15:10

Swiss Criminal Records Checks

The Swiss Register of Criminal records has warned of being "severely restricted". 

In a satement they said: "It is our prime objective to continue to provide our services to the people of Switzerland even in these exceptional times. Because of the coronavirus crisis, the capacities of the Swiss Register of Criminal Records have been severely restricted.

"As a result, until further notice we can only guarantee orders of criminal records excerpts if the order is made over the counter at a post office in Switzerland. Please do not order any excerpts unless it is absolutely necessary. Thank you for your understanding and take care."

19 March 2020, 15:10

Disclosure and Barring Service (DBS) and AccessNI allows temporary video verification

The DBS and AccessNI has said they will temporarily allow ID verification via video for standard and enhanced checks. Basic checks will still have to be carried out face to face. Read their official statement here.

This means that for the checks mentioned, remote video session is now allowed. Employers must ask the individual to present the documents in the video, they must be able to see it clearly and look for signs of tampering and make sure they can match the photos in the documents to the individual.

Our recommendation to all clients using this method is to add a passport verification check as it will help reduce the chance of fraud further. Adding further identity verification to your screening programme adds real value especially at times when recruitment is being carried out remotely.
Employers will still need to see the original documents on the first day the new employee attends their place of work.
19 March 2020, 15:10

IR 35 postponed

The government has announced they will postpone the IR35 reforms due to be launched in April. They will now be implemented in April 2021.

The changes will see every medium and large private sector business in the UK become responsible for setting the tax status of any contract worker they use from April 2020.

The postponement has been made to prevent any delay in hiring contractors, should you need them to support peaks in demand or urgent work within your business due to impact from the coronavirus pandemic.

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March 16, 2020
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The Senior Managers & Certification Regime – Righting Regulatory Wrongs?

As of 9 December 2019, the Senior Managers and Certification Regime (SMCR) became applicable to almost all firms regulated by the Prudential Regulation Authority and the Financial Services Authority, demonstrating that individual accountability remains a key priority for regulators. Chris Brennan (partner) and Zeena Saleh (associate) of White & Case LLP outline the key changes and implications for us.

The global financial crisis spurred a flurry of regulatory activity – large cross-border investigations, record fines and a thirst for more individual accountability – giving further credence to the third law of regulation; for every market action, there is an equal and opposite regulatory reaction.

While regulators have long been successful at holding firms to account for wrongdoing, they have had much less success holding individuals to account. The view from the regulator was that the failure to discipline individuals is often caused by difficulties in attributing control failings to particular individuals, for example, because of collective decision-making.

SMCR was established following the recommendations of the Parliamentary Commission on Banking Standards. The regime seeks to reduce the pool of senior individuals directly approved by the regulators, while encouraging individuals to take greater responsibility for their own actions. It is also designed to make it easier for firms and regulators to hold particular individuals to account for a regulatory failure within a firm. It was first applied to banks from March 2016 and later applied to all dual-regulated firms from December 2018.

To further ensure (as far as possible) a consistent approach across the financial services industry, as of 9 December 2019, the regime was extended again to apply to the 47,000 solo-regulated firms. Firms will have one year (until 9 December 2020) to take certain steps required by the regime. So, what are the implications of this for soloregulated firms and what measures should firms be taking, if they have not done so already?

Key Changes

SMCR aims to “…encourage greater individual accountability and sets a new standard of personal conduct in financial services …” with a view to strengthening confidence in the financial services industry and ultimately reduce harm to consumers.

The extended regime applies to a vast and varied group of firms. The FCA has taken this into account proposing a proportionate and flexible approach to the application of the regime. This is demonstrated by the FCA’s categorisation of firms – limited, core or enhanced – with the regulations under SMCR applying to such firms accordingly.

This short article does not seek to set out all the changes brought about by SMCR. However, the key changes can be summarised into the following three categories:

1. Conduct Rules – – the Conduct Rules replace the Statements of Principle and Code of Practice for Approved Persons (APER) and applies to a broader group of employees.

2. Senior Managers Regime – Senior Management Functions (SMF) replace the previous Significant Influence Functions. Each senior manager must obtain pre-approval from the FCA prior to starting the role. The regime introduces prescribed responsibilities to be allocated to SMFs and the concept of a ‘Statement of Responsibilities’ for enhanced firms which should clearly articulate what that individual is responsible and ultimately accountable for.

3. Certification Regime – The Certification Regime applies to employees in positions where it is possible for them to cause significant harm to the firm, its customers and the market more generally. These individuals will not require pre-approval from the regulator before starting the role but must be certified as fit and proper by the firm.

Key Implications

While it is certainly hoped that, in practice, firms and their senior individuals were acting in a way that reflects the spirit of the new regime, SMCR still arguably constitutes a significant practical change – expanding its reach, placing more responsibility on firms and a greater emphasis on individual accountability. Some key implications include:

1. Conduct rules have a broader reach, applying to a larger pool of employees when compared to the previous APER regime. Firms will need to ensure that its employees are aware of the conduct rules as they apply to them.

2. SMCR has effectively reduced the number of SMFs requiring FCA approval and increased the number of employees that would fall within the certification regime. This places a greater onus on firms. While those holding a SMF will need to obtain the FCAs pre-approval before taking on the role, the burden of assessing a certified employee’s fitness and propriety is now on a firm. Although previously firms would always make an assessment of an individual’s fitness and propriety, the regulator would always have the final say. Firms are now required to reach their own decision on this issue and face the consequences if they get it wrong. Firms are also required to provide regulatory references to a new employer and, given the new employer’s degree of reliance on the reference, will need to carefully consider what information to include and the appropriateness or adequacy of such information.

3. In terms of individual accountability, it should be easier for regulators to identify who is responsible for any given issue within a firm. However, the assessment of whether an individual is culpable for a regulatory failing remains the same. While the new regime introduces some specific rules, any enforcement action is likely to focus on the question of whether the person took reasonable steps. While this is not always easy to demonstrate, it is a relatively low threshold. The problem is that although the FCA has to establish that the individual failed to take reasonable steps, the practical burden will always fall on the senior manager to demonstrate what they did to fulfil their regulatory obligations.


The introduction of SMCR is a positive step for the industry in many ways. Establishing who is responsible for what within a firm, provides clarity for regulators, firms and individuals alike. However, in larger firms, the ability to attribute culpability for a control failing is unlikely to be as ‘black and white’ as it might appear on a Statement of Responsibilities. The regulator must be careful to avoid trying to create a culture of strict liability. The fact that an issue is said to be the responsibility of a particular individual, does not mean that individual has to take the blame. Life is never that simple – not even in politics.


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March 11, 2020
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The future of talent acquisition

HR Grapevine pulled together talent acquisition leaders in London to discuss the future of this crucial business function.

Importance of talent acquisition

Talent is increasingly seen as the core foundation of success in the business sphere. In fact, organisations consider getting hold of the right talent to be so important that according to a recent PwC survey of CEOs, 80% are either extremely or somewhat concerned about getting access to the skills their business needs. This has rocketed up from just over 50% in 2012. But why the anxiety?

It could be that businesses know if they cannot get the right talent then they will not be able to innovate nor pursue market opportunities, resulting in delays to overall strategy. They also might be aware that the talent acquisition space is rapidly changing with, as Deloitte’s 2019 Human Capital report lays out, ‘recruiting becoming harder than ever’. Half of respondents to a separate HR survey noted that competition for the best applicants is fiercer than ever.

The above is compounded by changes that are happening within the talent acquisition function itself. New choices of technology, the rising prominence of data and analytics, the importance of communication, community and networks and better understanding of the impact of branding means that the function now finds itself at a critical moment of change whilst also being seen as critical to business.

This is why Allegis Global Solutions (AGS) and HR Grapevine recently hosted a roundtable of senior HR and talent acquisition leaders from a broad cross-section of different industries: to find out how they perceive their own talent acquisition function’s ability, where the pressure points lie, and how it could change for the better.

Chaired by Ewan Greig, Talent Solutions Analyst at AGS, the leaders discussed why and how they measure their talent acquisition process, how important managers are to the process, as well as the importance of branding, networking, data collection, vendor support and leadership.

Measuring talent acquisition

“In theory, running a project to capture hard metrics and experiential data across the hiring process before deciding on an improvement plan seems like common sense,” explains Greig. His words were corroborated by the roundtable attendees, many of whom agreed that a good place to begin assessment would be whether talent acquisition strategy matches overall organisational strategy, before delving into measuring specific parts of the process.

However, whilst there was an agreement that collecting measurements after each stage of the hiring process would be useful – as well as surveying candidates on their hiring experience – there were questions of how often measurements should take place, with worries over whether too much measurement might cause candidate fatigue. Yet, consensus was that not all data needs to come from candidate feedback. In fact, high-performing talent acquisition functions could be collating data from the performance of everything from their career site to time-to-hire; it’s whether they had the resource to do anything with this data afterwards that most seemed to worry about.

Managerial capability

A recurring theme to the roundtable discussion regarded the importance of line managers to the talent acquisition process. Many believed that talent acquisition should be a supporting function to many hiring processes, creating best practice documents and development programmes for managers to drive their own hiring.

As the leaders in the room saw it, talent acquisition cannot carry out every aspect of hiring due to lack of resources; therefore, it makes sense the function should better align with managers to drive better hiring behaviours.

The danger is, as one or two in the room stated, that if they do not clearly communicate and develop best practice hiring behaviours then poor managerial capability will hurt everything from the success of talent acquisition to employer branding and the bottom line.


One company who attended the roundtable laid out that it treats its employer branding – branding is a crucial part of talent acquisition, as found by an AGS and HR Grapevine research on The Shape of Talent Acquisition Across Europe – like a marketing function, who are tasked with selling the company and the role. Its talent acquisition is interested in ‘selling’ the candidate ‘more than a job’.

Yet, there was a heated discussion over whether employer brand should be left to grow organically or push the brand to grow, what the best way to use social media to grow the brand is, how branding efforts turn into an actual hire and whether it is possible to know if branding engages with the right talent personas.

Regardless, branding was seen as crucial. “The employer brand is the image and representation of what it’s really like to work at an organisation. From a consumer and B2B perspective, having a compelling brand is critical to driving business success,” explains Kristin Shulman, Global Director of Marketing and Brand at AGS.

The employer brand is the image and representation of what it’s really like to work at an organisation

So, where is the talent?

With so many considerations, it can be difficult to understand where the talent is, let alone how to acquire it. As one roundtable attendee says: “How can we hire for future talent if we don’t know what it will be?” Of course, there are many ways to get around this, including understanding the organisational strategy, better understanding the shape of the market and incubating specific communities of talent with key talent personas within this. It’s how they go about this that will be crucial.

Will organisations use technology, data and external partners to drive these necessary changes? Responses from within the room suggest a mixed approach but any change was considered good.

As Jade Clifford, Executive Director and Head of RPO EMEA for AGS, explains: “Each change to improve talent acquisition will make an incrementally positive impact on the chances of success, where key differentiators will fundamentally link back to how easy, fast, and enjoyable the process is.”

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