In some cases, you may make a processing error which results in an applicant who has properly submitted an application not having their identity verified before the determination deadline for publication of the register for an election. For example, a paper application form may be received but misplaced and not properly dealt with, or an online application may be incorrectly processed, resulting in you not requesting documentary evidence for an application made without identifiers.
On discovering this type of processing error, before you can add the applicant to the register, you must still:
be satisfied that the application is made by someone who appears to be the person named on the application
be satisfied that the application was submitted before the deadline (for example, it was time- and date-stamped upon receipt
send the applicant’s personal identifiers to be verified
Depending on the point at which a processing error is identified, it may be the case that the results of the DWP matching process may not be returned in time to be able to be used to verify the identity of the applicant so that they can be added to the register in time to vote, or in the event that the DWP match cannot verify the applicant’s identity, there will be insufficient time for local data matching and/or the documentary exceptions process to take place.
In these circumstances you may also proceed to local data matching and/or the documentary exceptions process before you receive the result of the DWP match.
If you use the documentary exceptions process and an applicant provides you with evidence, you are only permitted to retain this if it ends up needing to be kept as evidence used to determine an application which eventually returned a negative match result.1
Where the IER Digital Service returns a positive match, the documentary evidence is unnecessary and must be destroyed. You will therefore also need to have processes in place to securely destroy documents where necessary. Our data protection guidance for EROs and ROs contains more information on document retention.