July 29th, 2021 | Sterling

What is BPSS? The Essentials of the Baseline Personnel Security Standard

What Is Baseline Personnel Security Standard (BPSS)? 

Sterling’s security standards screening solution includes comprehensive BPSS screening services. We’ve also put together a helpful guide highlighting the essentials of BPSS requirements and the practical considerations for employers. The guide can help your organisation understand the BPSS pre-employment screening process, what to know before choosing a screening package, and other common check types for risk management you should consider when adding new people to your team. 

Since 2013, a surge in demand for BPSS came as a result of the phased introduction of requirements for the PSN, as seen below: 

1. 2013 – all users of PSN services or data needed to be BPSS checked 
2. 2014 – all users of PSN email had to be BPSS checked 
3. 2015 – all users of PSN services, emails, or data must be BPSS checked 

It’s worth noting that a BPSS clearance would not be deemed adequate for an individual operating in a position where they are able to gain a complete and overall picture of a SECRET plan, policy or project.  For this, formal security clearance is a must. 

With this in mind, BPSS is the most basic of the four levels of personnel security controls, and as the ‘Baseline’ name in the BPSS meaning suggests, represents a prerequisite for higher levels of national security checks including the Counter-Terrorist Check (CTC), Security Check (SC), and Developed Vetting (DV). 

The Purpose of a BPSS Clearance

The main purpose of BPSS clearance, according to the HMG BPSS guidance, is to act as a sensible and precautionary measure intended to “confirm the identity of individuals (employees and contractors) and provide a level of assurance as to their trustworthiness, integrity, and reliability.” Hopefully, with the aim of mitigating potential risks – that may include identifying individuals involved in illegal activities, identifying unspent criminal convictions not disclosed but revealed by other sources, and identifying CV or qualification embellishments. The latter is particularly prevalent, as according to our research, 53% of resumes and job applications contain falsifications. 

However, ultimately at a macro level, BPSS clearances also aim to reinforce and protect national security, safeguarding the country and community against untoward dangers that may impact order and well-being. This could extend to threats to citizens, way of life, integrity, and interests. 

The Elements of a BPSS Clearance

Here are the four key elements of the BPSS standard which must be verified – the mnemonic ‘RICE‘ fits as a handy reminder: 

1. Right to Work – Verification of Nationality, ID documentation, and Immigration status* 
2. Identity – ID Data check (electronic identity authentication – name, address, aliases, links, accounts, etc.) 
3. Criminal Records – Search for ‘unspent’ convictions (Basic Disclosure) 
4. Employment checks – Confirmation of 3 years (minimum) Employment History / Activity 

All organisations carrying out a BPSS clearance, even the Civil service, must ensure that they comply with the immigration, asylum, and nationality Act 2006, aiming to prevent illegal migrants working in the UK. It is also important for employers to note that prospective employees are obliged to give a reasonable account of any substantial periods spent abroad (six months or more in the past three years). 

The responsibility for the application of BPSS checks on a candidate generally rests with the HR function, although the government advises that HR should work in conjunction with security units, and if possible with the involvement of legal advisors and procurement staff. 

Latest Updates to BPSS Guidance 

In June 2024, several updates were made to the BPSS to enhance security measures, improve clarity, and ensure compliance with evolving regulatory and technological landscapes. Here are the key changes in the updated guidance: 

• Enhanced Identity Verification: The new BPSS guidance places greater emphasis on robust identity verification processes, including: 
• Use of Digital Identity Verification: The adoption of digital identity verification technologies is now recommended, ensuring more accurate and efficient validation of an individual’s identity.
• Strengthened Documentation Requirements: There is now an increased focus on the types and combinations of documents required for identity verification, reducing the risk of fraud.
• Employment Verification: The new guidance now states that evidence of activity must be provided for any gaps of more than 6 months in the 3-year employment timeline. In addition, employment history can now be verified via His Majesty’s Revenue and Customs (HMRC) PAYE, or by employer references. 
• International Criminal Records: There is now more detailed guidance on obtaining and assessing international criminal records for individuals who have lived and/or worked abroad. 
• Continuous Monitoring and Re-screening: The importance of ongoing security is highlighted through recommendations for continuous monitoring and periodic re-screening of personnel: 
• Regular rescreening Intervals: The guidance now suggests regular intervals for re-screening existing employees to ensure ongoing suitability for their roles.

The updated BPSS guidance reflects a comprehensive approach to personnel security, integrating modern technological advancements, stricter compliance requirements, and practical usability enhancements. These changes are designed to ensure that organisations can effectively mitigate risks and maintain high standards of security in an evolving threat landscape. 

Recent Developments 

Organisations are beginning to acknowledge the increased importance of screening their contingent workforce, particularly third-party contractors, to the same standards of their own employees. After all, many of these workers will have the same level of access to company information and resources. This is consistent with our research which shows that 60% of organisations screen their contingent workforce, including contractors or temporary workers, compared to 53% in 2016, indicating a gradual increase. However, a 40% gap still exists, which we predict will steadily close. 

An increasing number of organisations are now partnering with screening providers to implement and create more robust and comprehensive screening programmes, with 8 of out 10 now acknowledging the importance of background screening (compared to 6 out of 10 in 2016). It’s also clear that many companies are now mirroring and completing the four key elements of the BPSS standard, with a clear focus on ongoing checks, as there is a realisation that a one-off check only provides an assessment of a person at that point in time. 

Increased Demand for Screening Standards 

It’s clear that the demand for screening standards, particularly relating to BPSS, shows no sign of slowing down or diminishing. Compliance represents a primary consideration for many employers, and with an increase in screening regulations, this is perhaps no surprise. It is also consistent with our trends report which indicates that improving or meeting regulatory compliance is now the top cause for conducting pre-employment background screening. 

While you may now be familiar with the BPSS clearance, we’ve also created a BPSS screening standards guide to help you understand the practical considerations in more depth, along with the additional recommended checks. Download our guide here. 

What are the steps to implement BPSS in an organisation?

Implementing the Baseline Personnel Security Standard (BPSS) in an organisation involve several steps:

1. Understand the BPSS requirements, including identity verification, employment history checks, nationality and immigration status confirmation, and criminal record checks.
2. Develop a BPSS policy that outlines the process and procedures.
3. Train HR and security staff on BPSS requirements and processes.
4. Collect and verify necessary documents from employees and job candidates.
5. Conduct regular audits and reviews to ensure compliance and address any gaps.
6. Implement a tracking system to monitor the status and results of BPSS checks, ensuring that all personnel meet the standard.

What tools are needed for effective BPSS implementation?

Effective BPSS implementation requires several tools:

• A comprehensive HR management system to track and store personnel information.
• Background check services can be essential for verifying identity, employment history, and criminal records.
• Document verification tools help authenticate the provided documents.
• Training platforms for educating HR and security staff on BPSS requirements can also be crucial.
• Compliance monitoring software ensures ongoing adherence to BPSS standards.
• Secure communication tools are necessary for handling sensitive information.

These tools collectively support a streamlined, efficient, and compliant BPSS implementation process.

How can companies ensure compliance with BPSS?

• Companies can ensure compliance with BPSS by establishing clear policies and procedures aligned with BPSS requirements.
• Regular training for HR and security personnel on BPSS guidelines is essential.
• Implementing robust tracking and auditing systems helps to monitor compliance.
• Regular internal audits and reviews can identify gaps and areas for improvement.
• Partnering with reputable background check services ensures accurate and thorough verification processes.
• Additionally, maintaining up-to-date records and documentation supports compliance efforts.
• Effective communication and collaboration across departments enhances the overall compliance with BPSS standards.

What are the challenges of implementing BPSS?

Implementing BPSS presents several challenges. Ensuring accurate and thorough background
checks can be time-consuming and complex. Maintaining up-to-date records and
documentation requires additional and consistent effort. Training HR and security staff on BPSS requirement and procedures is essential but can be resource-intensive. Integrating BPSS processes with existing HR systems may pose technical difficulties. Compliance monitoring and audits demand
ongoing attention and resources. Additionally, balancing thorough checks with employee
privacy concerns can be challenging. Addressing these challenges requires a well-coordinated
approach and the right tools and processes.

How can BPSS improve organisational security?

BPSS improves organisational security by ensuring that all personnel have been thoroughly vetted and meet essential security standards. By verifying identity, employment history, nationality, and criminal records, BPSS reduces the risk of employing individuals with fraudulent backgrounds or potential security threats. This comprehensive screening process helps prevent insider threats and protects sensitive information and assets.

BPSS also promotes a culture of security awareness and compliance within the organisation. Overall, BPSS strengthens the organisation’s defence against various security risks and enhances overall trust and integrity.

This content is offered for informational purposes only. First Advantage is not a law firm, and this content does not, and is not intended to, constitute legal advice.  Information in this may not constitute the most up-to-date legal or other information.

Readers of this content should contact their attorney or lawyer to obtain advice concerning any particular legal matter.  No reader, or user of this content, should act or refrain from acting on the basis of information in this content without first seeking legal advice from counsel or lawyers in the relevant jurisdiction.  Only your individual attorney or legal advisor can provide assurances that the information contained herein – and your interpretation of it – is applicable or appropriate to your particular situation.  Use of, and access to, this content does not create an attorney-client relationship between the reader, or user of this presentation and First Advantage.