Whilst there’s a lot of information available about how to check identity documents for Right to Work compliance, there’s little guidance about what action to take when a document fails your checks. Handling counterfeit or fraudulent documents can be nerve-wracking, so our guest blogger, Abbie Pullman, has pulled together some practical advice to tackle this sensitive topic ‘in the moment’ and beyond…
Identity document forgery is rising. Forged ID (particularly EEA identity documents) and Fraudulently Obtained Genuine (FOG) documents remain a key facilitator of immigration crime. In 2016, Frontex, the European Border and Coastguard Agency, reported a 70% year-on-year rise in fake documents held by UK-bound migrants, many using modified identity cards from countries such as Italy and Romania.
Using TrustID identity document verification defends Off To Work from this trend, reduces our exposure to fraud and protects our brand reputation. The software checks visible and non-visible data for accuracy and validity and presents the results in seconds so that we can quickly decide whether to proceed with a candidate. And if we ever have any doubts, we can refer the document to a team of experts with a single click, meaning there’s no need to just ‘use our judgement’.
During my experience leading high-volume, nationwide and international recruitment Right to Work checks, the system has helped me identify many candidates presenting fake identity documents. And when that happens, it can be a very tricky situation so here’s my thoughts on what you should do if you suspect you’ve been given a fake document
1. Be prepared
I have always found it useful to create a simple guide that colleagues from any department can follow. If your business handles a large volume of documents, role-playing a tricky situation of finding an applicant with a fake document could also help prepare your teams to manage the situation calmly and firmly, whilst protecting both themselves and your business.
Create a powerful deterrent for those trying to use fake documents by making it clear throughout your recruitment process that you check all documents thoroughly. Don’t forget to make copies of every document provided by each individual, even if at first sight you think something is clearlyfake.
Wherever possible, avoid scanning or checking documents in front of candidates – I always recommend that you scan documents in a separate room so that you can discreetly consult a colleague or expert if needed. Any reluctance from applicants to hand over documents for you to copy, or attempts to give you a photocopy while holding the original, might be a warning flag that something is amiss…
2. Be calm in the moment
Safety first: The safety of your team is key – everyone reacts differently in uncomfortable situations and humans can be unpredictable. Where possible, discuss the issues with the document holder whilst a colleague is present in case the situation becomes volatile.
You’re not law enforcement: Return all documents to the owner before you discuss their documents – they may want to leave immediately so ensure they have a clear exit route and avoid shutting the door or creating any barriers. Don’t try to confiscate documents – you’ll already have copies at this point and if you’ve scanned them, the data will be saved in your document verification system.
Be sensitive: As with any delicate situation, avoid discussing the matter in front of other candidates to prevent embarrassment. Maintain a controlled, calm tone of voice throughout to de-escalate tension.
Remain neutral: Don’t make accusations or imply that a document is fake or stolen – ‘wear and tear’ makes some real documents look suspicious. Blame it on technology and use phrases like: ‘Unfortunately, your ID card hasn’t passed the checks on our electronic scanner on this occasion. We’re waiting for a full report but until then, I’m afraid we can’t process your application.’ Giving the option to return with an alternative document supports an ‘innocent until proven guilty’ approach (of course it’s highly unlikely that they’ll return if they know they’re using a fake document…)
It’s not personal: Your document verification system is impartial and bases decisions purely on data rather than gut-feeling or unintentional bias. Less experienced team members might find it easier to express that it’s ‘company policy’ to scan all documents, or defer the responsibility to a more senior colleague in a potentially heated situation.
Don’t get into a debate: If the document has failed, be empathetic but firm. Remember that fake documents and stolen identities might be used for much more than working illegally, so try to avoid your personal emotions meaning you give someone the benefit of the doubt. If you’re waiting for a report from TrustID (if it’s an unclear case that needs investigation) then be sure to tell them when you’ll next be in touch.
3. Know what to do once they’ve left
I have always reported counterfeit or imposter identity documents that we’ve come across during Right to Work checks on the government website. You can report anonymously and all information will be treated confidentially, however providing your company details demonstrates your diligence during any future Home Office investigations.
Along with your full TrustID referral .pdf, I’d also advise you to attach address details, National Insurance number or any other information provided by an applicant. This helps the Home Office paint a background picture and decide whether they are a high priority case.
In most cases, the only response you’ll get from the Home Office is that they’re investigating the situation, but make sure you keep all document scans on file so that you can help them in the future if needed. If the applicant made a hasty exit and left any of their original documents with you, hand them in to your nearest police station, with your online immigration report reference number.
4. Help avoid it happening again
If there’s not an electronic way to ‘block’ them from repeating an application, regularly circulate the names to your selection and checking team. If they’ve provided a false document once, that’s fraud, so detailed investigation should take place before processing any future applications.
Whilst this isn’t ‘official’ advice, I’ve always found that taking these steps has meant that my teams have been prepared and have been able to handle illegal applicants in a calm and clear way. I hope it helps you too…
Abbie Pullman, Guest blogger
Spent 4 years overseeing teams recruiting 5500+ hospitality agency staff, experiencing many recruitment challenges including a wide range of tricky immigration situations.
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