According to KPSS it is optional at the moment. Making it mandatory would make a big difference.
DBS CHECKS AND IDENTITY VERIFICATION: SAFEGUARDING LOOPHOLES CREATED BY CHANGES OF IDENTITY
Page 27-29
Recommendation One:
mandatory use of National Insurance numbers for DBS checks and identity changes
A National Insurance number is a number used in the United Kingdom in the administration of the National Insurance or social security system. It is also used for some purposes in the UK tax system. Individuals are normally issued with their National Insurance number just before their 16th birthday.
National Insurance numbers are allocated for life and are unique to each individual. They do not change should an individual change identity, no matter what that change of identity consists of and no matter how that identity change is affected, be that via self-declaration, enrolled or unenrolled deed poll, or by statutory declaration. When an individual obtains legal recognition of acquired gender and is issued with a gender recognition certificate, the individual’s new details are recorded against their existing number. Records of previously used identities are not deleted from the individual’s National Insurance number record. Rather, they are retained, together with the relevant dates of use, until 50 years after the individual’s death.83
No matter how many identities an individual assumes, their National Insurance number is an unchanging and unchangeable constant. National Insurance numbers, therefore, enable all information held about an individual to be tied together in a way that cannot be circumvented by changing identity. Because of this, National Insurance numbers provide an opportunity to contribute much needed rigour, reliability and accuracy into the DBS system. However, whilst the DBS system does not exclude National Insurance numbers entirely, in our opinion they are under utilised and their potential to contribute to the DBS system remains unrealised.
Currently, although an applicant undergoing a DBS check is able to include their National Insurance number as part of the application, this is not a mandatory requirement and checks against an individual’s National Insurance number only take place in very specific, arguably exceptional, circumstances. Thus, the applicant may submit identity documents that display that individual’s National Insurance number, however, other identity documents that do not include the National Insurance number can be used instead. Although the online DBS check application form provides the opportunity to record the applicant’s National Insurance number, to do so is optional.
Checks against an individual’s National Insurance number are far from routine. The Police Act 1997 Part V at section 118 (2A)(d) states that it may be necessary to confirm an applicant’s identity with reference to their National Insurance number. From the response we received to a Freedom of Information Access Request we submitted, it is clear that recourse to National Insurance numbers only takes place in very specific situations where the applicant is either unable to provide the required identity documents, or where a close match on the Police National Computer needs to be confirmed or eliminated.84
National Insurance numbers are not included in the information recorded for individuals who are placed on the Barred Lists.
Our recommendation is that full use be made of National Insurance numbers in order to close the current safeguarding loopholes that exist around identity documents and identity verification.
We recommend:
That it be a mandatory requirement for applicants to submit their National Insurance number during the DBS check application process
That DBS checks include a check against the applicant’s National Insurance number in order that all identities the applicant has used can be retrieved and checked against data held on the Police National Computer, local police force system and the Barred Lists
That individuals placed on the Barred Lists have their National Insurance number recorded against their name
That when an individual makes an application to change their identity on their passport or driving licence, the applicant is required to provide their National Insurance number in order that these identity changes can be included on their National Insurance number record
Currently, the safeguarding loopholes that exist around identity documents and identify verification mean that organisations that request a DBS check cannot be certain that the information displayed on the certificate is complete or accurate. Use of National Insurance numbers would remove this uncertainty and mean that organisations can justifiably be confident that all necessary checks against all current and former identities have been carried out. Using National Insurance numbers also removes the current reliance on the applicant’s honesty to ‘do the right thing’ and provide all previously used names or to go through the Sensitive Applications Route. Incompleteness of information as a result of innocent absent- mindedness is also no longer an issue.
We do not consider that requiring applicants to submit their National Insurance number for the purposes of a DBS check or when changing identity for passport or driving licence to be intrusive, disproportionate or onerous. Indeed, it is a common requirement for individuals to provide their National Insurance number. Many organisations routinely require individuals to provide their National Insurance number including:
HM Revenue and Customs (HMRC)
An individual’s employer
The Department for Work and Pensions, or in Northern Ireland the Department for Social Development, if the individual claims state benefits
The local council, or the Northern Ireland Housing Executive, if the individual claims Housing Benefit
Electoral Registration Officers (to verify identity when an individual registers to vote)
The Student Loan Company, if an individual applies for a student loan
Pensions providers
Individual Savings Account (ISA) providers
Authorised financial service providers.85
In our opinion, requiring an individual to provide their National Insurance number for the purposes of a DBS check is a proportionate measure to further the legitimate aim of safeguarding.
https://kpssinfo.org/dbs-checks-and-identity-verification-pdf/