As an alternative or supplementary to documentary evidence of identity and address, the applicant’s identity, address and other available information may be checked electronically by accessing other data sources. Each source may be used separately as an alternative to one or more documentary checks.
Care should be taken when using a combination of electronic and documentary checks that different original sources of information are used. For example, a physical check of a bank statement and an electronic check of the same statement of account are the same source.
In respect of electronic checks, confidence as to the reliability of information supplied will be established by the cummulative nature of checking across a range of sources, preferably covering a period of time, or through qualitative checks that assess the validity of the information supplied. The number or quality of checks to be undertaken will vary depending on the diversity as well as the breadth and depth of information available from each source. Verification that the applicant is the data-subject also needs to be conducted within the checking process.
Some examples of suitable electronic sources of information are set out below.
An electronic search of the Electoral Register (not to be used as a sole identity and address check):
- Access to internal or external account database
- An electronic search of public records where available
- In addition to, or integral within, the above process and procedures should exist to guard against impersonation, invented identities and the use of false address. However, if the applicant is non face-to-face, one or more additional measures should be undertaken.
- Financial Exclusion For Applicants Resident In Nigeria
- Access to basic banking facilities and other financial services is a necessary requirement for most adults. It is important therefore that the socially/financially disadvantaged should not be precluded from opening accounts or obtaining other financial services merely because they do not possess evidence of their identities in circumstances where they cannot reasonably be expected to do so. Internal procedures must allow for such instances and must provide appropriate advice to staff on how identity can be confirmed and what checks should be made under these exceptional circumstances.
Where SIAO Partners has reasonable grounds to conclude that an individual client is not able to produce the detailed evidence of his identity and cannot reasonably be expected to do so, the firm may accept as identification evidence a letter or statement from a person in a position of responsibility e.g. solicitors, doctors, ministers of religion and teachers who know the client, confirming that the client is who he says he is, and to confirm his permanent address.
When a financial institution has decided to treat a client as financially excluded, it should make a record of the reasons for doing so along with the account opening documents.
The Firm should satisfy itself that a client is the person he claims to be. Therefore, where a letter/statement is accepted from a professional person, it should include a telephone number where the person can be contacted for verification. The Firm will verify from an independent source the information provided by the professional person.
To guard against financial exclusion and to minimize the use of the exception procedure, financial institutions must include in their internal procedures the alternative documentary evidence of personal identity and address that can be accepted.
SIAO Partners will put in place additional monitoring for accounts opened under the financial exclusion exception procedures to ensure that such accounts are not misused.