Evaluating local data sources for verification purposes

Verification matching requires you to establish the identity of the person applying. This means that local data sets which can be used for this purpose will be limited to those where the resident’s identity has already been established, such as council tax benefit, or housing benefit. 

You should assess the data record you are considering using against the following criteria before using it to conduct local data matching as part of the verification process:

Criteria Notes
Has the applicant provided identity evidence to the data holder?  The data source must record that the applicant has provided documentary evidence to prove their identity to the local authority. This could be;
a) a passport or similar photo ID; 
b) a range of trusted government documents and/or financial and social history documents such as, birth certificate, adoptions certificate, financial statements, utility bills etc.
Has the applicant’s evidence been confirmed as valid by the data holder?  The data source should record that the evidence provided by the applicant has been validated by checking with the issuing authority or against guidance provided by the issuing authority
Has the data holder ensured that the evidence provided belongs to the person applying? The data source should record that the identity of the applicant has been verified by comparison of the applicant to the strongest piece of identity evidence
Does the data holder check that the evidence provided is not fraudulent? The data source should record that the identity of the applicant has been subjected to counter fraud checks and that the document has been confirmed as genuine


Before a data set can be considered suitable for matching, all of the above criteria must be fulfilled.

General considerations for using local data

There is a key difference between data which an organisation has gathered itself, for example its payroll data, and data based on information provided by individuals about themselves. 

Data controllers are responsible for taking reasonable steps to ensure the accuracy of the data they hold and, in the context of which the data is being processed, ensure that data which is inaccurate or incomplete is erased or rectified without delay.

You should consider if the data you are using is reliant on information provided by individuals and assess whether that information is likely to be accurate. For example, applications for library membership may be based entirely on information provided by the service user, with no checks carried out by the local authority on the accuracy of the information. You may conclude that, because of this, their library data is not suitable for local data matching.

You should also ask the data controller whether data standards or good practice exist for the data sources you intend to use and then make a decision as to whether the data controller meets these standards or if it follows good practice. 

For example, the Department for Work and Pensions has set out detailed guidance on good practice for the processing and use of council tax benefit and housing benefit, which includes guidance on the checking of evidence provided to local authorities and how to deal with fraud. If you are an ERO from an authority that delivers its benefits service to these standards you should be confident in using benefits data for local data matching.

Information requested under Regulation 35 or 35A of the 2001 Regulations is exempt from any other statutory or other restriction on its disclosure.1  

This exemption does not extend to data supplied under Regulation 23 of the 2001 Regulations. This means that the provisions of data protection legislation will apply to data gathered in this way. You should seek further guidance from your data protection officer on what you will need to do in order to ensure that any data transactions are compliant with data protection legislation. 

Reviewing your local data matching practices

You should undertake evaluation of any existing local data matching practices. You should be conducting ongoing monitoring and evaluation of the costs and benefits of local data matching, and keeping under review the data sets used. 

Your evaluation should also take into account the other potential uses of local data matching apart from in verification – for example, in identifying potential electors to invite to register, or in sourcing one piece of evidence towards the deletion of an elector who is no longer eligible.
 

Diweddarwyd ddiwethaf: 24 Awst 2020