Accountant in Bankruptcy (AiB) identity verification process: FOI release

Information request and response under the Freedom of Information (Scotland) Act 2002.

Information requested

1. Please list the services that require users to verify their identity by sending in physical forms of documentation (e.g. a passport)?

1a. For each of these services, how many identities were verified in this way in your 2019/20 financial year, and what did it cost to process?

1b. Are these verifications performed by a third party or conducted by an in-house team?

2. Please list the services that allow users to use a digital method for proving their identity; and name the methods used (e.g. Gov.UK Verify or other equivalent digital biometric identity method)?

2a. For each of these services, how many identities were verified in this way in your 2019/20 financial year, and what did it cost to process?


1. The Accountant in Bankruptcy (AiB) is not routinely required to verify an individual’s identity and require them to provide physical forms of identification. However, there are a number of statutory duties that AiB is required to undertake that can require AiB to request an individual does provide proof of identification.

For example, evidence of identity can be required to: support an individual’s personal Data Protection Act subject access request; confirm that the debtor is appointing a third party to act on his/her behalf and, comply with Money Laundering legislation when an individual is purchasing an asset in a bankruptcy.

1a. In 2019/20:

  • Eight individuals provided proof of identify to AiB in support of their Data Protection Act, subject access requests.

  • 19 individuals have been identified as having been required to provide evidence of their identity in respect of bankruptcies being administered by two Insolvency Practitioner firms (providers) operating on behalf of AiB.

One other provider is unable to identify how many individuals they have asked to provide proof of identity during this period, as they do not keep a specific record of this task.

In order to identify the exact number of their cases where an individual’s proof of identification was requested, this would require the provider to review circa 2,390 live bankruptcy cases, at approximately five minutes per case, which equals 199 hours of work. The cost of this work would exceed the appropriate cost limit of £600, for responding to Freedom of Information requests. Therefore, in accordance with Section 12 of FOISA, I am unable to provide you with the precise number of individuals who were asked to submit evidence of their identity.

It is not envisaged that the total number of ID checks completed by this provider will be much higher, or lower, than the combined number (19) identified by AiB’s other two providers.

Neither AiB, nor AiB’s providers, calculate and record the specific time and cost for the task of asking an individual to submit evidence of their ID. Therefore, in accordance with Section 17 of FOISA, I am not able to provide you with this information, as the information is not recorded.

This task is one of many duties that are performed during the administration of a bankruptcy, the cost of which is included in the administration fee charged by AiB and the providers against each bankruptcy.

The statutory administration fee charged by AiB are recorded in The Bankruptcy Fees (Scotland) Regulations 2018.

One of our providers has estimated that the cost of undertaking this task is £4.25 per ID check.

1b. Evidence of an individual’s ID can be requested both by AiB staff and by the staff of the providers. Information about the providers is on AiB’s website at:

2. One provider operates the ID3 system. Neither AiB, nor the other providers, operate any digital method to verify an individual’s identity.

2a. No evidence of an individual’s identity has been requested using the ID3 system in 2019/20.

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Please quote the FOI reference
Central Enquiry Unit
Phone: 0300 244 4000

The Scottish Government
St Andrews House
Regent Road

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