Indirect Sales Proof Policy Indirect Channel Version 12 7 May 2015 Author: Credit Risk & Fraud External version 1 Indirect Sales Table of Contents Introduction ............................................................................................................................ 3 Distance Selling ..................................................................................................................... 4 Face to Face Selling............................................................................................................. 10 Additional Proofs Policy Information ................................................................................. 15 2 Indirect Sales Introduction Proofs are taken for new and existing, private and business customers prior to processing the application and submitting for credit check. The diagram below demonstrates at what point of the application process proofs are required. Customer Proof process Pass Proceed to credit check Fail Do not proceed to credit check EE has a generic proofs list, which all Partners/ Stockists are required to follow. New customers need to provide a proof of identity and address (and business where applicable), whereas existing customers only need to provide a proof of identity (and proof of business where applicable). The type of proof process the Partner/ Stockist is required to follow is dependent upon • Their own route to market (e.g. face to face retailer or distance seller) • The type of customer applying (consumer, small business or large business customer) All Partners/ Stockists must provide proofs from the proofs list and adhere to the proof policy for that brand. The Partner/ Stockist may also add additional steps to the proofs policy if they wish but this must be over and above EE’s policy. The Partner/ Stockist is responsible for collecting and retaining all proofs obtained, with their customer agreement. 3 Indirect Sales Distance Selling Non-Face to Face trading (e.g. Digital or Telesales) – All Customer TypesConsumer and Business New Customers If the Partner/ Stockist performs distance/ non-face to face sales (for example Web or Telesales) they must only use Single Card Proof as the proof of ID and proof of address; Where applicable the proof of business must be scanned or photocopied (electronic copy of the original proof). The proof must be: • accompanied by Single Card Proof (AVS) to verify ID and address (not applicable for large businesses) • a scan or photocopy of the original proof in (locked) PDF format, where applicable • stored securely by the Partner/ Stockist for future audit. The Indirect distance selling/ non-face to face proofs summary is as follows: Table 1: Proof requirements for the various account types Account Type EE Private Consumer EE Self-Certified business EE Proofed Small Business EE Large Business Proof of Identity and Address Single Card Proof (AVS) Single Card Proof (AVS) Single Card Proof (AVS) N/A AND Business Proof N/A and Self-Certification Form read out in script and 1 business proof and 2 business proofs Table 2: List of Acceptable Proofs − − − − − − − − − − − − Business Proof List UK bank or building society Business Credit or Debit card UK bank or building society Business account statement UK Business credit card statement Business premises council tax statement Business utility bill Existing mobile phone bill in the business name (excluding Orange, T-Mobile or EE bills) Fixed line telephone bill in the business name Business VAT registration certificate Certificate of Incorporation or change of company's name Certificate of Charity registration Inland Revenue ID card (registration card) Business premises leasing/ rental agreement 4 Indirect Sales The proof of business must be scanned or photocopied (electronic copy of the original proof). The proof must be: • a scan or photocopy of the original proof in (locked) PDF format • stored securely by the Partner/ Stockist for future audit Additional Information: • Self-Certified Small Business – customer must be made aware that their business information will also be passed on to the Credit Reference Agencies. • Proofed Small Business refers to sole trader, ‘self-employed’, small partnerships (1 to 9 employees). • The Self-Certification Form must only be used if a Sole Trader, Self Employed or Small Partnership customer has no business proof as listed in Table 2. • The Self-Certification form must not be used for the customer account transfer (CAT) process. Customers must provide 1 business proof as listed in table 2. • Large Business refers to Limited company, PLC, charity or large partnership (10+ employees). • Non-Limited Partnerships - If a joint partnership account is required, then each applying partner must authenticate their identity before a credit check can be processed. • Single Card Proof (AVS) - The customer can provide a Credit or Debit card (excluding ‘pre-paid’ cards) to act as both proof of ID and Address. A £2 transaction will then be taken and refunded, to check the validity of the card details against the customer’s name and application address. • Pre to Post pay migration applications processed via TeleRegistrations must be proofed using Single Card Proof (AVS) only. • The same proof cannot be used as proof of ID and proof of address. • Government and NHS applications must follow the Large Business process. 5 Indirect Sales Existing Customers – (Upgrades & Migrations) Existing customers requiring Upgrades and Migrations are required to prove their identity prior to checking for eligibility. Table 3: Proof requirements for the various account types Account Type Proof of Identity AND and Address Business Proof OR OR EE Private Consumer Single Card Proof (AVS) N/A EE Small Business Single Card Proof (AVS) N/A EE Large Business Call validation Confirm customers name, address and DOB Confirm customers OR name, company name, address and DOB 1 business proof N/A N/A Table 4: List of Acceptable Proofs − − − − − − − − − − − − Business Proof List UK bank or building society Business Credit or Debit card UK bank or building society Business account statement UK Business credit card statement Business premises council tax statement Business utility bill Existing mobile phone bill in the business name (excluding Orange, T-Mobile or EE bills) Fixed line telephone bill in the business name Business VAT registration certificate Certificate of Incorporation or change of company's name Certificate of Charity registration Inland Revenue ID card (registration card) Business premises leasing/ rental agreement The proof of business must be scanned or photocopied (electronic copy of the original proof). The proof must be: • a scan or photocopy of the original proof in (locked) PDF format • stored securely by the Partner/ Stockist for future audit All Call Validations must be recorded and securely stored for a minimum of the term of contract plus 90 days. Additional Information: • Small Business refers to sole trader, ‘self-employed’, small partnerships (1 to 9 employees). 6 Indirect Sales • Large Business refers to Limited company, PLC, charity or large partnership (10+ employees). • Under no circumstances can a Large Business Upgrade or Migration be authenticated using the Call Validation method. • Single Card Proof (AVS) - the customer can provide a Credit or Debit card (excluding ‘pre-paid’ cards) to act as both proof of ID and address. A £2 transaction will then be taken and refunded, to check the validity of the card details against the customer’s name and application address. • Call Validations can only be completed by dialling the mobile number to be Upgraded / Migrated. The Partner/ Stockist must ask the customer to o confirm that they are the Account Holder o state their full name o state their full address o state their date of birth The Partner/ Stockist must NOT prompt the customer with any of this information in order to confirm identity. • • • Government and NHS applications must follow the Large Business process. • The Self-Certification form must not be used for the customer account transfer (CAT) process. Customers must provide 1 business proof as listed in table 4. 7 Indirect Sales Existing customers – (Additional Lines) Existing customers requiring Additional Lines are required to provide proofs to confirm their identity. Table 5: Proof requirements for the various account types Account Type EE Private Consumer EE Small Business EE Large Business Proof of Identity and Address Single Card Proof (AVS) Single Card Proof (AVS) N/A AND Business Proof N/A N/A 1 business proof Table 6: List of Acceptable Proofs − − − − − − − − − − − − Business Proof List UK bank or building society Business Credit or Debit card UK bank or building society Business account statement UK Business credit card statement Business premises council tax statement Business utility bill Existing mobile phone bill in the business name (excluding Orange, T-Mobile or EE bills) Fixed line telephone bill in the business name Business VAT registration certificate Certificate of Incorporation or change of company's name Certificate of Charity registration Inland Revenue ID card (registration card) Business premises leasing/ rental agreement The proof of business must be scanned or photocopied (electronic copy of the original proof). The proof must be: • a scan or photocopy of the original proof in (locked) PDF format • stored securely by the Partner/ Stockist for future audit. Additional Information: • Small Business refers to sole trader, ‘self-employed’, small partnerships (1 to 9 employees) • Large Business refers to Limited company, PLC, charity or large partnership (10+ employees) • Non-Limited Partnerships - if a joint partnership account is required then each applying partner must authenticate their identity before credit check can be processed 8 Indirect Sales • Single Card Proof (AVS) - the customer can provide a Credit or Debit card (excluding ‘pre-paid’ cards) to act as both proof of ID and address. A £2 transaction will then be taken and refunded, to check the validity of the card details against the customer’s name and application address. • Existing customers who request an new connection on EE and already have additional connections on T-Mobile or Orange must be authenticated as an existing customer on their account prior to checking for the new connection request. • Government and NHS applications must follow the Large Business process. • The Self-Certification form must not be used for the customer account transfer (CAT) process. Customers must provide 1 business proof as listed in table 6. 9 Indirect Sales Face to Face Selling Face to Face trading – All Customer Types - Consumer and Business The Partner/ Stockist must ensure that a valid proof of age is collected, unless the customer clearly looks aged 18 or over. Table 7: Acceptable Proof of Age Proof of Age EE – Full or Provisional UK or NI Driving Licence EE – Passport EE – Proof of Age Standard Scheme (PASS) cards New Customers The Indirect proofs summary for Retail/ Face to Face is as follows: Table 8: Proof requirements for the various account types Account Type EE Private Consumer EE Self-Certified Business EE Proofed Small Business EE Large Business Proof of Identity and Address AND Business Proof Single Card 1 proof of ID + 1 Or N/A Proof (AVS) proof of address Single Card 1 proof of ID + 1 Signed SelfOr and Proof (AVS) proof of address Certification Form Single Card 1 proof of ID + 1 Or and 1 business proof Proof (AVS) proof of address N/A 2 business proofs Table 9: List of Acceptable Proofs Proof of ID Proof of Address - Full or Provisional UK or NI Driving - Full or Provisional UK or NI Driving Licence Licence - UK bank, building society or Credit card - Passport account statement - UK bank or building society Credit - Fixed phone bill / Debit card - Existing mobile bill (excluding Orange, TMobile or EE bills) W - Council Tax statement - Utility bill (in customer name) 10 Indirect Sales Table 10: List of Acceptable Proofs − − − − − − − − − − − − Business Proof List UK bank or building society Business Credit or Debit card UK bank or building society Business account statement UK Business credit card statement Business premises council tax statement Business utility bill Existing mobile phone bill in the business name (excluding Orange, T-Mobile or EE bills) Fixed line telephone bill in the business name Business VAT registration certificate Certificate of Incorporation or change of company's name Certificate of Charity registration Inland Revenue ID card (registration card) Business premises leasing/ rental agreement The proof of business must be scanned or photocopied (electronic copy of the original proof). The proof must be: • a scan or photocopy of the original proof in (locked) PDF format • stored securely by the Partner/ Stockist for future audit. Additional Information: • Self-Certified Small Business – customer must be made aware that their business information will also be passed on to the credit reference agencies • Proofed Small Business refers to sole trader, ‘self-employed’, small partnerships (1 to 9 employees) • The Self-Certification Form must only be used if a Sole Trader, Self Employed or Small Partnership customer has no business proof as listed in Table 10. • The Self-Certification form must not be used for the customer account transfer (CAT) process. Customers must provide 1 business proof as listed in table 10. • Large Business refers to Limited company, PLC, charity or large partnership (10+ employees) • Non-Limited Partnerships - if a joint partnership account is required then each applying partner must authenticate their identity before credit check can be processed • If using Driver’s Licence or Passport, the date of birth on the proof must be the same as that on the agreement and the customer must be aged 18 or over. • Single Card Proof (AVS) - the customer can provide a Credit or Debit card (excluding ‘pre-paid’ cards) to act as both proof of ID and address. A £2 transaction will then be taken and refunded, to check 11 Indirect Sales the validity of the Card details against the customer’s name and application address. • The same proof cannot be used for proof of ID and proof of address. • Pre to Post pay migration applications processed via TeleRegistrations must be proofed using Single Card Proof (AVS) only. • Government and NHS applications must follow the Large Business process. 12 Indirect Sales Existing Customers – (Upgrades, Migrations and Additional Lines) Existing customers are required to provide proofs to confirm their identity; this is applicable to Upgrades, Migrations and Additional Lines. Table 10: Proof requirements for the various account types Account Type EE Private Consumer EE Self-Certified Business EE Proofed Small Business EE Large Business Proof of Identity and Address Single Card Or 1 proof of ID Proof (AVS) Single Card Or 1 proof of ID Proof (AVS) Single Card Or 1 proof of ID Proof (AVS) N/A AND Business Proof N/A N/A N/A 1 business proof Table 11: List of Acceptable Proofs Proof of ID – Single Card Proof (AVS) – Full or Provisional UK or NI Driving Licence – Passport – UK bank or building society Credit/ Debit card Table 12: List of Acceptable Proofs − − − − − − − − − − − − Business Proof List UK bank or building society Business Credit or Debit card UK bank or building society Business account statement UK Business credit card statement Business premises council tax statement Business utility bill Existing mobile phone bill in the business name (excluding Orange, T-Mobile or EE bills) Fixed line telephone bill in the business name Business VAT registration certificate Certificate of Incorporation or change of company's name Certificate of Charity registration Inland Revenue ID card (registration card) Business premises leasing/ rental agreement The proof of business must be scanned or photocopied (electronic copy of the original proof). The proof must be: • a scan or photocopy of the original proof in (locked) PDF format • stored securely by the Partner/ Stockist for future audit. 13 Indirect Sales Additional Information: • Self-Certified Small Business – customer must be made aware that their business information will also be passed on to the credit reference agencies • Proofed Small Business refers to sole trader, ‘self-employed’, small partnerships (1 to 9 employees) • Large Business refers to Limited company, PLC, charity or large partnership (10+ employees) • Non-Limited Partnerships - if a joint partnership account is required then each applying partner must authenticate their identity before credit check can be processed • Single Card Proof (AVS) - The customer can provide a Credit or Debit Card (excluding ‘pre-paid’ cards) to act as both proof of ID and address. A £2 transaction will then be taken and refunded, to check the validity of the card details against the customer’s name and application address. • Pre to Post pay migration applications processed via TeleRegistrations must be proofed using Single Card Proof (AVS) only. • Existing customers who request an new connection on EE and already have additional connections on T-Mobile or Orange must be authenticated as an existing customer on their account prior to checking for the new connection request. • Government and NHS applications must follow the Large Business process. • The Self-Certification form must not be used for the customer account transfer (CAT) process. Customers must provide 1 business proof as listed in table 12. 14 Indirect Sales Additional Proofs Policy Information Table 23: Requirements for Photocopying and storing proofs List of proofs that DO NOT require photocopying or scanning EE – Single Card Proof (AVS) List of proofs that require photocopying or scanning – UK Bank or Building Society Credit or Debit card (for non-AVS checks) – Passport – Proof of Age standards Scheme (PASS) cards – UK bank, building society or Credit card account statement – Council Tax statement or payment book – Utility bill – VAT registration certificate – Certificate of Incorporation or change of company name – Certificate of Charity registration – Inland Revenue ID Card (registration card) – Leasing/ rental agreement – Existing mobile phone bill in the business name (excluding Orange, T-Mobile or EE bills) – Fixed line telephone bill in the business name All copies of proofs must contain the customer’s name and (where applicable depending on proof type) their address and statement date. Copies of bank / building society / Credit card related proofs must conceal all personal account information. The registering Partner/ Stockist is responsible for collecting valid proofs (business, private consumer, age) and retaining them with the customer agreement. If Proof of Age is required it must be photocopied or scanned and stored with the customer agreement. If using Single Card Proof (AVS) policy option to validate proof of ID and Address: o the customer must provide full card details (incl. CV2 code) o the Partner/ Stockist must ensure the Credit or Debit card is registered at application address (applications for this proof type can contain first name or initial) All major UK Credit/Debit cards are accepted (excluding ‘pre-paid’ credit cards) Distance sales business proofs can be scanned or photocopied (electronic) copies of the original proof. The proof must be: o o o accompanied by Single Card Proof (AVS) to verify ID / Address (applicable to small business only) a scan or photocopy of the original proof in (locked) PDF format sent to the Partner/ Stockist from a business e-mail address, matching the trading details of the applicant 15 Indirect Sales o All proofs must: o o o o o o o o stored securely by the Partner/ Stockist for future audit. be originals and not copies be printed and not hand written contain a Great Britain or N.I address (proof of address) match the customer’s name, address and date of birth details entered on the customer agreement be viewed at point of sale and pre-date registration date (for new customers) pre-date the date of account activity for additional connection request (for existing customers) be complete and have their source of origin clearly identifiable be clear and legible. The customer must sign the agreement and their signature must match that supplied on the proof of identification where applicable. Copies of required proofs for successful applications must be made AT POINT OF SALE. Customer proofs must contain the full first name and surname on at least one of the proofs provided. New customers must sign the bank instruction section of the agreement for Direct Debit payment and the signature must match that on the agreement and proof of identification. Bank, building society and Credit card account statements, phone bills, and utility bills must be dated within 3 months of the application date. Bank and building society account statements can be a print out copy, supplied directly by the bank or building society. These must be date stamped by the bank or building society and be the original document, not a photocopy. Online bank/building Society and Credit card account statements can be accepted subject to having 5 debit/ credit transactions. The following proofs are unacceptable: o o o o o o o o o o British Gas statements Sky/ mobile broadband bills Payment books Council tax / Utility payment cards Reminder bills or letters Overdue account letters Account information documents Terms and conditions confirmation letters Confirmation of address information Cheques and cheque books 16 Indirect Sales Table 24: Individual proof requirements Type of Proof Requirements - Photocard licences are acceptable without the counterpart - When accepting photocard licences the counterpart can be taken along with the photocard, however the counterpart alone is not acceptable Full or Provisional UK or NI Driving Licence - Provisional licences must be the photocard type only - ‘Old style’ paper driving licences must be fully copied to ensure the expiry date is visible - Ensure the address and signature matches the contract address and signature. - Ensure the licence has not expired - Customer’s name should match the name on the agreement - Must be signed by the applicant - Must be valid and not expired - Name must be displayed on the front of the card UK bank or building society Credit or Debit card - Must contain the customer’s forename initial as a minimum - Must have a CV2 number - Front and back of card must be copied in accordance with PCIDSS regulations - Both the CV2 number on the back and the middle 8 digits on the front of the card must be concealed - Must be a machine readable and biometric passport Passport - Must contain customer’s full name and date of birth - Must contain the customer’s signature - Must not have expired - Must not be an extension - Must include the PASS hologram Proof of Age Standards Scheme (PASS) cards - Photo ID must be a true likeness - DOB must state that they are 18 years of age or over (or has the 18+ symbol) and matches the DOB on the agreement 17 Indirect Sales Type of Proof Requirements - Must contain Sort code and account number - Must contain customer’s full name and UK bank, building society and Credit address card account statement - Must detail name of bank/ building society - Must be a statement and not a letter - Must contain 5 debit / credit transactions - Must detail customer’s full name Council Tax statement - Must details customer’s full address - Must show the account or property reference number - Must detail customer/ business full name Utility bill - Must details full address - Customer reference/account number must be detailed VAT registration certificate - Must show full business name and address - Must detail VAT number - Must detail Company registration number Certificate of Incorporation or change of company name - Must include Full company name - Company must be registered in the UK - Certificate must have been supplied by appropriate authority - Must detail company registration number Certificate of charity registration - Must detail full company name - Company must be registered in the UK - Certificate must have been supplied by the charities commission - Must be in business name Inland Revenue ID Card (registration - Must have National Insurance number card) - Partner/ Stockist must document card number Leasing/ rental agreement - Must be a current (active) agreement - Must clearly display the start and/or end date of the agreement Existing mobile/ fixed line phone bill - Excludes EE, T-Mobile and Orange bills END OF PROCESS 18
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