Information & Verification

Effective: January 1, 2020

The ministry may ask an applicant or a recipient to provide or verify information for the purposes of

• determining or auditing eligibility for assistance,
• assessing employability and skills for the purpose of an employment plan, or
• assessing compliance with the conditions of an employment plan

The ministry requests information by:

• directing an applicant or recipient to supply information within the time and the manner specified by the ministry
• directing an applicant or recipient to supply verification of information:
  • provided to the ministry by an applicant or recipient; or
  • received by the ministry from another source and which relates to the family unit’s eligibility for assistance;
• seeking verification (from a third party, e.g. CRA via data match, banks via direct information request, etc.) of any information supplied to the ministry by an applicant or recipient

Effective: January 1, 2020

If an applicant or recipient fails to provide information or verify information the ministry may declare the family unit ineligible for assistance until the applicant or recipient complies.  

If a family unit is homeless or is at imminent risk of homelessness and fails to provide or verify information under Section 10, the family unit must remain eligible for assistance despite that non-compliance. The ministry may reduce the income assistance, disability assistance or hardship assistance of a family unit [see Related Links - Sanctions].

Effective: January 1, 2020

When requesting information or seeking verification of information is requested, and before applying any sanction, the ministry staff must consider the following :

• there is a reasonable basis to believe the information and/or documentation exists at the time of the request;
• the information and/or documentation is accessible by the applicant or recipient; [For more information, see Policy – Limitations of Section 10]
• the applicant or recipient is clearly informed of the information and/or documentation required;
• the applicant or recipient is given information on how to provide the information and/or documentation to the ministry;
• the applicant or recipient is provided the reason(s) why the information and/or documentation is required;
• the applicant or recipient is given a reasonable timeframe to meet the request
  • the timeframe may vary according to the circumstances of the individual and/or the accessibility of the information/documentation being requested;
• any information and/or documentation requested from a third party is directly related to determining or auditing the applicant’s or recipient’s current, ongoing, or past eligibility;
• the applicant or recipient is advised of the consequences of not complying with the direction; [For more information, see Policy – Failure to Provide or Verify Information] and
• if more time is needed for circumstances beyond the applicant or recipient’s control that would prevent the family unit from providing the requested information, such as dependent child in hospital or a recipient is in a special care facility;
• that a client’s medical condition prohibit them from obtaining the information, such as hospitalization;
• the request for information and/or documentation is reasonable and obtainable for the applicant or recipient to provide; [see Policy - Mitigating Circumstances] 
• staff should act to obtain the information/documentation, if there are valid reason(s) why an application or recipient cannot obtain information/documentation to establish or confirm eligibility (e.g. ministry contact employer directly);
• relevant steps have been taken in the Authority to Direct an Applicant or Recipient section; and
• the applicant or recipient had been clearly advised of what was required and was given adequate time but has not taken reasonable action to comply before applying a sanction [see Related Links - Sanctions].

[For more information, see Policy – Limitations of Section 10]

[For more information, see Procedures – Verification Interview.]

[For information on cheque signalling, see Related Links – Individual Case Management – Policy – Reasonable Attempts Prior to Cheque Signalling.]

Effective: January 1, 2020

The ministry should not be used to declare an applicant or recipient ineligible for assistance when they fail to provide or verify information where:

• the ministry has reasonable basis to conclude that the information or document requested does not exist or is not legally accessible to the applicant or recipient;  (e.g. or a roommate’s information to verify utility costs)
• the ministry has other relevant documentation to determine eligibility;
• the applicant or recipient is prevented by circumstances outside their control from obtaining the verification/information. (e.g. business has closed)
• there is evidence to support an eligibility decision being made under a different section of the legislation. For example,
  • the ministry has documents to show that a sole recipient deposited $1,000 into their bank account;
  • the ministry requested the recipient to provide verification that the $1,000 is exempt from income calculation (e.g., withdrawal from an RDSP);
  • the recipient did not provide the requested verification that the $1,000 is exempt from income calculation;
  • in this case, the ministry may apply the income to current eligibility or calculate an overpayment;
• the ministry can verify/obtain information with/from other persons or agencies directly (e.g. bank or employer), through a data match (e.g. CRA), or through an information sharing agreement or memorandum of understanding (e.g. ICBC);
• where information or documentation does not exist (e.g. paystubs from a business that no longer exists).

Note: The ministry cannot go directly to a third party for information received from another party about a client (e.g., an allegation). The ministry may only ask a third party for verification of information that a client provided to the ministry. For example, if a specific allegation is received that a client is working at ABC Company, staff must ask the client directly if the information is accurate. If they deny they are working, staff may then verify this information with ABC Company. If they confirm they are working, the client is given the opportunity to provide the required employment/payroll documents, and staff only contact the company if the client does not comply.

Effective: February 5, 2024

Third party checks are conducted to verify the income and assets declared by applicants or recipients. Third party checks must not be run unless valid consent is on the case.

Mandatory Third Party Checks

Ministry staff must complete the following mandatory checks for all applicants/recipients at application, unless any of the exemption criteria apply,  and as part of an Eligibility Review or a Compliance Review:

• Personal Property Registry
• BC Assessment Authority
• Insurance Corporation of BC
• Equifax - Consumer Credit Report
• Canada Revenue Agency (CRA)

Note: Some applicants and recipients may have not filed an income tax return for previous years.  Filing an income tax return is not a condition of eligibility.  However, recipients should be encouraged to file an income tax return annually in order to receive exempt tax credits and benefits, such as the Canada child benefit, the GST Credit, Low Income Climate Action Tax Credit,  and Working Income Tax Benefit. 

Exemption Criteria:  The following criteria must be used to waive third party checks prior to granting assistance, unless there is a specific eligibility concern identified:

• Client is under 19 years of age
• Has been in receipt of income or disability assistance in the past one (1) year
• Is currently homeless or at risk of homelessness
• Has been incarcerated in the last three (3) months
• Third party checks have been completed in the last six (6) months, in which case staff should use the original third-party check
• Refugee claimants or persons applying for protection who moved to Canada in the past one (1) year

Third party checks may be completed after the application process, at any time.

Other Third Party Checks may include but are not limited to:

• Landlords
• Employers
• Citizenship and Immigration Canada
• Social Service Agencies in other provinces
• Financial Institutions/Life Insurance Agencies
• WorkSafe BC
• WebAOBlink – Service Canada Employment Insurance database

Outstanding Warrants Verification Check

Ministry staff will need to confirm whether an applicant has an outstanding arrest warrant if:

• applicant discloses they have an outstanding warrant;
• applicant is unsure if they are subject to a warrant;
• ministry is made aware of the possible existence of a warrant; or
• at the Minister’s discretion.

The verification is conducted by Ministry of Attorney General [for more information, see Related Links – Warrants].

Effective: January 1, 2020

Ministry staff have a responsibility to:

• detect and address inconsistencies in client information;
• ensure relevant supporting documentation and information is obtained to establish eligibility;
• prevent overpayments where possible;
• pursue overpayments. [For information on Overpayments, see Related Links – Recoveries] 

The overall objective of the verification process is to maintain the integrity of BC Employment and Assistance programs by:

• ensuring that assistance is available and provided to those who meet the eligibility criteria;
• ensuring that assistance is paid fairly and equitably; and
• reducing error and abuse.

Staff achieve these objectives by:

• In determining or reviewing eligibility for assistance, staff use the declaration and consents provided by the applicant or recipient to seek verification from third parties. 
• All client information must be treated in a confidential manner in accordance with the Freedom of Information and Protection of Privacy (FOIPP) Act and in accordance with the terms and conditions of the respective information sharing agreements and/or memorandums of understanding. When verifying information, staff must not disclose more information than necessary when contacting outside agencies. [For information on Information and Privacy, see Related Links – Information Privacy and Security (FOIPPA).]
• Staff explain the application process to applicants, confirm the accuracy of eligibility information, assist applicants in accessing alternate resources and prevent misuse and error.  Staff are required to identify applicants who may be eligible for other sources of income and assist them to access this income, such as Canada Pension Plan benefits.  In identifying other sources of income, this may help reduce the reliance on assistance.
• The ability to accurately determine eligibility of applicants before assistance is issued is an important component in ensuring program integrity and preventing overpayments.  Staff must be alert to detect inaccurate information or circumstances presented by the applicant(s) or recipient(s) either inadvertently through misunderstanding or deliberately. 
• Staff refer cases to Prevention and Loss Management Services Branch (PLMS) when information suggests that a client has received assistance for more than three months, for which they were not eligible.  PLMS Quality and Compliance Specialists conduct reviews to audit eligibility for assistance and to ensure a recipient’s continuing compliance with the BCEA program. PLMS Ministry Investigators conduct criminal investigations of BCEA program abuse. These reviews and investigations may result in correction to ongoing assistance, recovery of overpayments and legal action. For information on referrals to PLMS, see Related Links – Referral to PLMS for Review or Investigation. 

Effective: January 1, 2020

Service Quality

• Staff treat clients with respect and dignity and ensure the principles of administrative fairness are adhered to. Applicants are informed of the documentation or information required to meet the eligibility criteria and a date for submission.  Eligibility is determined once all required documentation has been supplied.  Applicants who meet all eligibility requirements will not experience a delay in the application process.

Confidentiality

• To prove eligibility, applicants and recipients must provide a variety of personal information.  The ministry must treat all information received in a confidential manner and in accordance with the Freedom of Information and Protection of Privacy (FOIPPA) Act.  Staff must be sensitive to client privacy concerns when verifying information.  Staff must not divulge more information than necessary when contacting outside agencies.  Questions and/or concerns regarding the disclosure of personal information can be directed to the Privacy, Compliance and Training Branch (PCT) Corporate Information and Records Management Office [see Contacts].

Applicant Consent

• Staff must make every effort to ensure that applicants understand they are providing consent to the ministry’s collection of personal information, including from third parties, when they apply for assistance or complete a re-application form (HR0080R). Staff are responsible for explaining the implications of providing consent to each applicant and confirms that the applicant indicates they understand what they are signing.
• When completing an application by telephone, staff must review the content of the application form with the applicant and obtain verbal consent from the applicant to collect, retain and verify the information the applicant has provided, with third parties.  Staff must document the verbal consent on the activity plan and the HR0080A and advise the applicant this consent is valid for 5 business days.  Within these 5 business days, the applicant is required to make physical contact with the ministry office or trusted third party site to sign the HR0080A.
• The signed application authorizes the ministry to disclose information provided by the applicant for the purposes of verification.  This authority is granted under Section 10 of the Employment and Assistance Act and Employment and Assistance for Persons with Disabilities Act. 

Right to Reconsideration and Appeal

The applicant or recipient has the right to request reconsideration and to appeal decisions to deny, discontinue, or reduce assistance and must be advised of that right [see Related Links – Reconsideration and Appeal].

Case Information

Applicants and recipients have the right to access information on their BC Employment and Assistance case under the FOIPPA. Where an individual asks for the return of a document that the applicant or recipient provided, the worker may supply a photocopy of that document, or may return the original and retain a copy where the original is of value and/or significance to the individual, i.e., their passport, or birth certificate.  Any questions with regard to records management of client case, and/or access to information should be directed to Information Access Operations (IAO) [see Contacts]. 

Effective:  January 1, 2020

Section 10 of the Employment and Assistance Act and the Employment and Assistance for Persons with Disabilities Act, in effect, gives the Minister the authority to impose on any client the responsibility to provide all information and documentation necessary to demonstrate eligibility for assistance.

In cases where a recipient does not provide the necessary supporting information and documentation to assess eligibility, staff will determine what consequences (reduction or discontinuation) may be appropriate. The onus is on the client to provide all documents and information required in order for staff to determine eligibility for assistance.  Staff may assist the client in obtaining the documents where the client requires help. 

[For information and examples on how and when staff may assist clients who require help in obtaining documents, see Related Links – Individual Case Management – Policy – Staff Assisting Clients.]

[For more information about clients requiring assistance or the duty to accommodate, see Related Links – Individual Case Management – Policy and Procedures – Duty to Accommodate.] 

Effective: January 1, 2020

Correctly assessing eligibility during the application process or subsequent reviews relies on good communication and interviewing skills, common sense, curiosity, and skilled interpretation and analysis of documents.

Interviewing for Assessing Eligibility

It is the ministry staff’s role to assess eligibility for assistance and assist the clients in accessing alternate resources.  The best tool that staff have in determining eligibility is the effective use of interviewing and interpretation skills.  Good interviewing, listening, observation and analytical skills are essential to accurately determine eligibility and help staff to identify those clients and circumstances most prone to supplying false, inaccurate or misleading information, and to follow up effectively with the client when specific concerns have been identified. 

Staff should conduct interviews with a focus on curiosity rather than judgment and provide the applicant or recipient with an opportunity to explain circumstances, and should use open-ended questions, direct questions, paraphrasing and other good interviewing skills to elicit as much information as possible related to eligibility. 

While completing the application or review process, staff should follow these guidelines:

• Review information prior to the interview using past case history and information on current documents 
• Put the person at ease, using a friendly but professional manner.  Remember that people tend to understand and provide more accurate information when a relationship of respect and trust has been established with the worker.
• Ask questions that are clear and easy to understand.  Ask one question at a time.
• Explain carefully the declarations, notification and consents ensuring the applicant or recipient understands how their information will be used and retained (if completing an application or re-application (HR0080R).
• Explain carefully the appropriate policy/regulations and interpret how it relates to the applicant or recipient’s situation.
• Emphasize reporting responsibilities and how they are to be met, as well as consequences for not reporting accurately. 
• Request supporting documents if required before making an eligibility decision
• Make thorough, accurate notes during and immediately after the interview meeting. 
• Makes notes and complete activity plan steps and for application, include how the applicant supported themselves in the past, what has changed, what resources have they exhausted and what are their plans for the near future.
• Assess whether the information provided is logical in the situation and makes sense, given what is known about the circumstances, and recognizing one’s own potential bias.
• Listen to information and observe any contradictions in information provided.
• Review statements by the applicant or recipient and information contained in documents or other information for consistency. 
• Review third party checks for information that supports or is inconsistent with information provided by the applicant or recipient.

Effective: January 1, 2020

Third party checks must not be run unless valid consent is on the case.

Staff must keep in mind at all times the need to protect client confidentiality.  When contacting third party sources of information related to eligibility, identify yourself as ministry staff, and state the purpose of your inquiry, i.e., determination of eligibility.  Staff must not disclose information about the applicant or recipient beyond what is necessary to obtain the required information. 

Third party checks are to be conducted only for administering the Employment and Assistance Program.  Staff must not access third party information for any other purpose or for personal use.  Breaches are considered a serious issue and may result in disciplinary action. 

Mandatory Third Party Checks

The following are Third Party Checks that are completed for all applicants at application and for recipients as part of an Eligibility Review or a PLMS Review:

• BC Online
  • Personal Property Registry
  • BC Assessment Authority
• ​Consumer Credit Report (Equifax)
• Insurance Corporation of British Columbia (ICBC)
• Canada Revenue Agency (CRA)

Below are details of what each individual check may provide:

• BC Online

BC Online is a web-based service (www.bconline.gov.bc.ca) that offers access to the following public databases:

• BC Assessment Authority (BCAA) – information about real property and property assessments.
• Corporate Registry – information about registered companies, firms and societies.
• Manufactured Home Registry (MHR) – information about mobile home ownership.
• Personal Property Registry (PPR) – charges, liens, security interest, and encumbrances filed against personal property (chattels).

A fee is charged to the ministry for each search completed.

[For BC Assessment and Personal Property training material for staff, see Additional Resources.]

• Equifax Canada

Equifax Canada is a private company that gathers, records and sells consumer and commercial credit information through a web based service. 

An Equifax report provides information on loans, mortgages, credit cards, bank accounts, employment, residency and marital status.  Equifax does not guarantee the accuracy of this information.  All information must be verified with the client. Use this information as an indicator or investigative tool in assisting with eligibility determination.

The ministry’s Equifax searches are 'masked' and therefore, do not display as inquiries on the client's Equifax report when it is searched by another third party.  The intention of this masking is to prevent unintentional disclosure that a client is in receipt of assistance to other organizations searching the client's Equifax report.

If a client requests a copy of their own Equifax report, direct them to Equifax to obtain a copy of their own credit records.  When clients access their own consumer report, all inquiries are listed, including the ministry.

All Equifax reports received, including “No-Hit” reports, must be attached to the relevant Service Request related to the inquiry (e.g. Application, Eligibility Review, or PLMS Review).
 

• Insurance Corporation of British Columbia (ICBC)

ICBC maintains vehicle license plate and vehicle registration histories.  These records display active and historical vehicle license plates associated with a specified driver's license.  It is also possible to enter the vehicle identification number (VIN) to confirm the registered vehicle owner's name.

ICBC information may relate to assets, bank accounts (if Autoplan is present), financial interdependency (if a vehicle is jointly owned or a lease is jointly held, or if there is a different Owner than Principal Operator), or income (if purchase or insurance for a vehicle indicates potential other income).

• Canada Revenue Agency (CRA)

The ministry has an Information Sharing Agreement with the Canada Revenue Agency.

Clients sign a separate consent to allow Canada Revenue Agency to release information relating to eligibility for assistance.  The signed consent is valid for the year of signature, two calendar years prior to the year of signature and all subsequent consecutive years that the client continues to receive assistance.      

Ministry staff must check each file to ensure a valid signed consent is in place and review the specific timeframe of the consent before accessing taxpayer information.  Verbal consent obtained during the application process is not sufficient for staff to query tax information. 

Taxpayer information is available in ICM on the contact’s Tax Request tab. The information must not be printed.

Ministry staff analyze the taxpayer information to verify income and assets at the application interview, compliance review, or at an eligibility review.

Effective: January 1, 2020

Staff may require additional information or documentation to assess eligibility for assistance.  The following outlines circumstances when third party verification may be required and information sources that may be used to verify. 

• Outstanding Warrants

Ministry staff will need to confirm whether an applicant has an outstanding arrest warrant if:

• applicant discloses they have an outstanding warrant;
• applicant is unsure if they are subject to a warrant;
• ministry is made aware of the possible existence of a warrant; or
• at the Minister’s discretion.

[For more information on how to verify outstanding warrants, see Related Links – Warrants Procedures.]

WebAOBlink

The WebAOBlink is a web-based application supplied by Service Canada that allows ministry staff to directly access selected client information from the federal Employment Insurance database.  It is a secure and encrypted systems application, with access restricted to designated users in ministry offices. 

Effective: January 1, 2020

In addition to Third Party Checks, ministry staff have other resources they can use to verify an applicant or recipient’s information.

Verifying Identity

The following are examples of scenarios associated with documentation / identification that warrant further verification:

Documentation / Identification

• Required identification for the client and/or family unit is lacking; no photocopies or scanned copies of identification are on the file/case from a previous application and ministry staff is unable to verify the client’s identity.
• The client does not have a Social Insurance Number (SIN) and is not a refugee claimant or person applying for protection or other client exempt from SIN requirements (for more information, see Related Links- Identification Requirements- Policy- Verification of Social Insurance Number).
• Identification documents appear altered, forged, invalid, or inconsistent with the information provided.
• Documentation reflecting the client’s situation is lacking, or the information provided is inconsistent.

Information sources to confirm identification:

• ID Guide
• BC Online
• Employer records
• Canada Revenue Agency (e.g., SIN may be verified on the Notice of Assessment)
• Consumer Credit Report (Equifax)
• Client Identification Process (CIP)

[For identification requirements, see Related Links –BC Employment and Assistance Application - Stage 2 – Procedures – Documents Required for Eligibility Interview.]

[For information on CIP, see Related Links – Identification Requirements – Procedures – Establishing Proof of Identity.]

[For information regarding valid birth certificate documentation, see Additional Resources – Vital Statistics Agency.]

Service Canada Identification Guide

The Identification Guide produced and maintained by Service Canada contains sample copies of authentic documents from all of the provinces and territories.  The guide includes Birth Certificates, Motor Vehicle Operator’s Licenses, Immigration Documents, Health Care Cards, Firearms Acquisition Certificates (FAC) and Sample Social Security Cards.  Every Employment Assistance Office has a copy of the Identification Guide.

Note:   Staff who receive allegations or have suspicions of “personation” or “duplicate identification” must immediately contact the local PLMS office and speak to a Ministry Investigator prior to taking any further action.  Staff should not discuss or approach the client with respect to this concern. 

[see Related Links – Referral for PLMS Review or Investigation]

Accommodations and Living Arrangements

Staff may verify living arrangements if:

• The mailing address is different than the street address without a reasonable explanation.
• The address does not appear to be a residence
• Mail is returned from the address
• There appear to be too many people at the address (e.g. 7 clients residing in what appears to be a one-bedroom apartment)
• Another client reports the same address as their new address but does not report sharing with the current client
• The client is recently separated from their spouse with a history of repeated separation and reconciliation, or the client has provided contradictory information regarding the whereabouts of the ex-spouse.
• The client’s current roommate was formerly declared as a spouse.  [For detailed information on spousal and dependency, see Related Links – Family Composition – Procedures – Dependency Relationship Assessment Guide.]
• The client’s family composition is different from a previous application without a reasonable explanation.
• The client has changed residence but has the same landlord.
• The client is unable to provide shelter receipts (rent receipts, mortgage, taxes, etc.) or receipts appear to be suspect.

Information sources to confirm living arrangements:

• BC Assessment Authority (BCAssessment.ca) can identify if the accomodation is a residence and its approximate size
• Landlord or Owner
• Utility company records
• Canada Revenue Agency
• City reverse directories
• Consumer Credit Report (Equifax)

[For Spousal and Dependency, see Related Links – Family Composition.]

[For Residency Verification, see Related Links – Individual Case Management – Policy.]

No Bank Accounts

Note: “bank” refers to banks, trust companies, credit unions, and similar financial institutions. Clients who report no bank accounts may be asked to provide records from the agency where they cash their cheques. Verification may be requested if:

• Other information points to the existence of a bank account (Payroll by EFT, Autoplan for ICBC payments)   
• Client who reports no bank account currently but has reported one previously.
• Bank account closed just prior to application for assistance.
• Client had joint account previously.

Information sources used to confirm bank accounts:

• Consumer Credit Report (Equifax)
• BC Online – Personal Property Registry
• Banks (bank profile) 
• Bank information on the case

Status in Canada / Sponsorship

• The client is living in Canada under a current sponsorship agreement.
• The client is unable to provide proof of immigration status or immigration status is unclear.
• Immigration documents are expired or appear to be altered.
• Immigration documents are unfamiliar.

Information sources to confirm immigration status:

• FASB Sponsorship [see Contacts]
• Reported Sponsors

[see Related Links – Citizenship Requirements]

[see Related Links – Sponsorship Undertaking Default]

Income / Assets

Staff may seek verification if:

• Information or documentation is lacking on the value of assets:  vehicles, investments (for example, Registered Retirement Savings Plans), trust funds, or other assets.
• Information or documentation is lacking relating to the disposal of assets in the last two years, or the case was previously closed due to excess assets and the assets are no longer declared.
• The client’s banking records show unusual banking activity (for example, the client is unable to explain deposits), or the client has no bank account.
• The client’s banking records show no evidence of expenses paid (for example, a rent receipt for $500 is submitted but the bank shows no withdrawal consistent with rent payments, or all funds were spent on other expenses and insufficient money remains to have paid $500 rent)
• The client’s expenses are higher than income with no reasonable explanation (for example, unusually high shelter costs).
• Information or documentation is lacking relating to the source of income.
• The client may be eligible for another income support program (for example, WorkSafe BC, CPP, OAS, EI and pensions from other countries).

Information sources used to confirm income:

• Canada Revenue Agency
• Consumer Credit Report (Equifax)
• EI records (WebAOBlink)
• Landlord
• Employer
• Banks (bank profile and statements) 
• BC Online Companies Search

[see Related Links – Income Treatment and Exemptions]

Information sources used to confirm assets

• BC Online – Personal Property Registry
• Banks
• Consumer Credit Report (Equifax)
• Canada Revenue Agency

[see Related Links – Assets and Exemptions]

Self Employment

Verification may be obtained if

• The client is the owner of a small business or is a self-employed person and does not have business statements.
• Client has not accounted for a business which was sold recently or business assets.
• Applicant has previously operated a business.
• BC Online shows the client owns a business

Information sources used to confirm self employment:

• BC Online – Personal Property Registry and Companies Search
• Consumer Credit Report (Equifax)
• Canada Revenue Agency
• Internet
• Banks, Trust Companies, if known
• Vehicles (for business or recreational vehicles)

Out of Province / On Reserve
Client has been in receipt of assistance in another province or jurisdiction or history of moving from province to province.

• Client recently moved off reserve or frequently moves on or off reserve. 

Information sources used to confirm Out of Province/On Reserve:

• BC Online – Address Verification
• Social Service Office for province or band
• Consumer Credit Report (Equifax)
• Banks
• Ministry of Health (MSP cancelled if out of province)