Part 4: Detecting immigration identity fraud
4.1
In this Part, we outline our expectations for the detection of immigration identity
fraud and present our findings on how the Department:
- is organised to detect immigration identity fraud;
- plans to detect immigration identity fraud;
- is staffed to detect immigration identity fraud;
- provides training, supervision, and support for staff with detection responsibilities;
- supports detection through systems, processes, and procedures; and
- evaluates its detection of immigration identity fraud.
Our expectations
4.2
We expected the Department to have:
- a clear plan for the detection of identity fraud;
- dedicated staff capacity for the detection of identity fraud;
- all relevant staff appropriately trained, supervised, and supported in the detection of identity fraud;
- systems, processes, and procedures for relevant staff designed to assist the detection of identity fraud;
- robust systems and processes for effective high-risk identity fraud profiling;
- robust systems, processes, and procedures for effective identity verification; and
- a system for evaluating the effectiveness of its detection activities.
Arrangements for detecting immigration identity fraud
4.3
The Department is organised to detect immigration identity fraud through a
range of assessment and verification processes and procedures by the Workforce
Group.
4.4
In relation to the selection process for skilled migrants, the Department’s identity
fraud detection relies on the assessment and verification of expressions of
interest and applications for residence. In relation to the selection process for
UN-quota refugees, the Department’s activities in detecting identity fraud rely
on the pre-mission assessment, interviews held during selection missions, and
assessments of UNHCR refugee referrals conducted after the selection missions.
Planning related to the detection of identity fraud
Our findings
4.5
The Department has no specific plan for the detection of identity fraud within the
skilled migrant and UN-quota refugee entry categories. Instead, the Department
said that the detection of identity fraud is part of the general assessment and
verification of applications against the entry requirements of the two categories.
4.6
In relation to the skilled migrant category, the assessment and verification of
identity focuses on information provided by the applicant in relation to the
requirements of:
- employability, including job offers;
- capacity building factors;
- ability to settle and contribute to New Zealand; and
- meeting relevant health, character, and English language requirements.
4.7
Verification of identity is included as part of the assessment of whether an
applicant for skilled migrant status meets the entry requirements.
4.8
In relation to the UN-quota refugee category, the priority for detecting identity
fraud during the assessment process focuses on information provided by the
UNHCR in the refugee referral process and during the refugee mission interviews
conducted by the Department. This includes information in relation to the entry
category requirements and risks to New Zealand’s international reputation. Assessment of identity is included as part of the consideration of whether a
candidate referred by the UNHCR meets the entry requirements.
4.9
The Department’s Strategic Risk Paper (noted in paragraph 3.9) outlines important
judgements relating to risks, and regional- and country-specific overviews of
issues relevant to immigration. The Department also identifies broad immigration
fraud risks. However, it is not clear how these judgements, issues, and risks are
reflected or prioritised in the Department’s general assessment and verification
against the entry requirements of the skilled migrant and UN-quota refugee
categories.
| Recommendation 3 |
|---|
| We recommend that the Department of Labour prepare a specific plan for the detection of immigration identity fraud within the skilled migrant and UN-quota refugee entry categories based on identified risks. |
Staff capacity, training, supervision, and support
Our findings
4.10
The Department has staff throughout the Workforce Group whose work involves
the detection of identity fraud. Supervision and support is provided for these staff
members, but staff roles and responsibilities could be better defined. There is
limited training available for most staff that relates specifically to their detection
roles.
Staff capacity
4.11
Staff responsible for the detection of identity fraud within the skilled migrant
entry category include:
- customised service officers within Immigration New Zealand branch offices in New Zealand and overseas;
- analysts in the Processing and Review Team of the Immigration Profiling Group for applications from countries that pose a high risk to New Zealand’s international reputation;
- verification officers within Immigration New Zealand branch offices in New Zealand and overseas; and
- verification officers within the Central Verification Unit for applications from the Auckland region.
4.12
Staff dedicated to the detection of identity fraud within the UN refugee entry
category include:
- refugee quota immigration officers within the Refugee Quota Branch; and
- risk profiling analysts within the Risk Assessment Team of the Immigration Profiling Group.
4.13
Customised service officers and refugee quota immigration officers have
important roles in the selection of skilled migrants and UN-quota refugees. Customised service officers in Immigration New Zealand branch offices in New
Zealand and overseas are responsible for supporting skilled migrants through
the selection and settlement process, and refugee quota immigration officers are
responsible for the selection and assessment of UN-quota refugees.
4.14
The ability to identify accurately and manage actual and potential risks is a
required skill in the job description for customised service officers, but there is no
similar required skill in the job description for refugee quota immigration officers.
4.15
The roles of customised service officers and refugee quota immigration officers
should have specific responsibilities for the detection of immigration identity fraud, given their crucial roles in the selection process for skilled migrants and UNquota
refugees.
4.16
For both roles, there is a clear and understandable focus on client service
responsibilities. However, this needs to be balanced to reflect the importance of
detecting immigration fraud, including immigration identity fraud.
| Recommendation 4 |
|---|
| We recommend that the Department of Labour emphasise the importance of the detection of immigration fraud for customised service officers and refugee quota immigration officers, and include detection in the refugee quota immigration officer job description. |
Staff training
4.17
The induction programmes and training available to customised service officers
and refugee quota immigration officers do not include material specific to
detection.
4.18
All new immigration officers complete an induction programme, and immigration
officers’ warrant training which gives authorisation to make decisions under
the Immigration Act 1987. They also use the New Zealand Immigration Service
Manual. Warrant training is targeted at visa and permit staff, and covers
immigration policy. It does not include training in relation to international or
humanitarian policy, or areas specific to the detection of immigration identity
fraud.
4.19
A best practice verification training course was run by the Central Verification Unit
in June 2006 to standardise verification practice within the Department. However,
due to budget constraints the course has not been run since and there are no
plans to run it again.
4.20
A basic introductory course is conducted for new verification officers in the Central
Verification Unit. However, a study commissioned by the Department in May 2006
found that there was no robust training for verification officers.
4.21
A new training initiative was developed for the Immigration Profiling Group in
February 2006. New risk profiling staff receive a two-day introductory course
that covers important aspects of their work. The course includes the processes
and roles of the Risk Assessment Team, profiling indicators, and the work of the
Refugee Quota Branch.
4.22
Customised service officers, verification officers, and refugee quota immigration
officers hold specialised positions, which require introductory and ongoing training specific to their roles. In our view, the Department needs to address the
lack of training available for these roles by providing a co-ordinated detection and
verification training and development programme.
| Recommendation 5 |
|---|
| We recommend that the Department of Labour address the lack of training available for customised service officers, verification officers, and refugee quota immigration officers by providing a co-ordinated detection and verification training and development programme specific to their roles. |
Staff supervision and support
4.23
Verification officers in Immigration New Zealand branch offices in New Zealand
and overseas generally report to a resident immigration manager, and the
branch manager. However, there is limited technical advice or support available
to verification officers within Immigration New Zealand branches, although the
Central Verification Unit often provides informal technical advice and support.
Detection support systems, processes, and procedures
Our findings
4.24
The Department has tools in place within its mainstream systems and equipment,
such as document verification equipment, for relevant staff to support fraud
detection. However, there are limited processes and procedures in place to
support profiling of applicants who pose a risk of committing immigration fraud,
and to support consistency in the assessment and verification of identity in the
skilled migrant and UN-quota refugee categories.
Detection systems
4.25
The Department’s AMS is not set up to hold all information about clients
electronically. Some information from manual applications is stored in hard copy
rather than electronically. It was noted by staff from throughout the Department
that access to identity information within or linked to the system would improve
standards for identity verification and management. This would enable staff
to compare identity information in new applications and supporting travel
documents with that provided for previous applications.
4.26
Access to all facets of identity documentation electronically would improve
identity management, assessment, and verification throughout the Department,
and should be considered as part of improvements to the computer system.
| Recommendation 6 |
|---|
| We recommend that the Department of Labour consider storing all identity information within or linked to its Application Management System as part of future information technology developments. |
4.27
The client risk methodology that verification officers have been using as a pilot
scheme contains a toolkit designed to assist in verifying information submitted
with applications. It provides information such as domestic and international
contact lists, and a database of samples of known genuine and fraudulent
documents, such as foreign police clearance certificates, national identity cards,
and qualifications.
High-risk profiling processes and procedures
4.28
High-risk profiling is carried out by the Process and Review and Risk Assessment
Teams in the Immigration Profiling Group. It is a process for identifying people
who pose a risk to New Zealand’s international reputation; not those who pose a
risk of committing immigration fraud.
4.29
Applicants who might pose a risk to New Zealand’s reputation can be declined on
this basis. Applicants are considered to pose a risk to New Zealand’s international
reputation if they have been involved with any government, regime, group, or
agency that has advocated or committed war crimes, crimes against humanity,
and/or other gross human rights abuses.
4.30
All skilled migrant applicants using a passport from a pre-determined high-risk
country and all quota refugees are referred to and assessed by the Immigration
Profiling Group.
4.31
A list of high-risk countries was originally compiled by the Officials Committee
for Domestic and External Security Co-ordination in June 2005. The list has since
been expanded. The Immigration Profiling Group also considers visa applications
from people using a passport from a country deemed a high risk in relation to
proliferation of nuclear weapons.
4.32
The Immigration Profiling Group uses client risk assessment report templates
and checklists, and has reference guides for its Processing and Review and Risk
Assessment Teams. The reference guides set out step-by-step processes and
procedures for staff in carrying out risk assessments. A review of the Immigration
Profiling Group in October 2006 noted that these were very good reference guides,
and much of the information was applicable to visa and permit processing carried
out in Immigration New Zealand branch offices.
Verification processes and procedures
4.33
The verification process within the skilled migrant entry category involves
confirming information and documentation provided at the expression of interest
and application stages of the selection process.
4.34
The verification indicator tool is used by customised service officers to decide
the level of verification risk associated with an application for entry as a skilled
migrant. The tool provides a four-point risk rating system, as follows:
- R1 – no need to verify;
- R2 – preliminary verification required at the expression of interest stage;
- R3 – verification required at the application stage; and
- R4 – verification required at both the expression of interest • and application stages.
4.35
Where verification is required, an application is passed on from the customised
service officer to the relevant verification officer.
4.36
Although there is no specific guidance on how verification is to be carried out
throughout the Department, the verification process focuses on information
and documentation provided in relation to identity, English language proficiency,
immigration agent, employer, job offer, work experience, and qualifications.
4.37
Verifying identity information and documentation involves:
- identifying and assessing any relevant AMS notes and previous applications;
- checking identity with external agencies and Immigration New Zealand branch offices; and
- document comparison and examination.
4.38
Verification officers generally have only photocopies of identity documentation to
verify. However, original documentation can be requested from the applicant and
checked by the Department.
4.39
A study of the Central Verification Unit commissioned by the Department in
May 2006 found the current process within the Central Verification Unit allows
verification officers to use their own discretion as to how far they examine an
applicant’s employment, qualifications, and work experience. This results in
inconsistencies in verification practice. A lack of thorough quality assurance was
also identified in the study.
4.40
The Department’s business case for its client risk methodology stated that,
in relation to verification processes, New Zealand Immigration branch offices
have been inclined to devise their own verification systems and country-specific
information in isolation from other areas of the Workforce Group.
4.41
Given the distribution of verification staff throughout the Department, and that
verification systems can be inconsistent and lack thorough quality assurance, the
Department needs to provide for consistency in its practice of identity verification
through specific guidance on how verification is to be carried out throughout the
Department.
| Recommendation 7 |
|---|
| We recommend that the Department of Labour prepare specific guidance on how identity verification is to be carried out throughout the Department to provide for consistency in verification practice. |
4.42
We examined a small sample of preliminary and final verification reports
completed in November 2006 from three Immigration New Zealand branch offices
and the Central Verification Unit.
4.43
We found inconsistency between different Immigration New Zealand branch
offices and the Central Verification Unit in the structure of the verification reports,
and in the level of detail and assessment provided in them. We also found
that, although most reports included evidence to confirm that an applicant’s
identity was verified against either information held on the AMS or identity
documentation submitted in the application, in a number of instances there was
no evidence to confirm that identity had been verified.
4.44
In our view, given the level of inconsistency in the reporting of identity verification
that the sample highlighted, the Department needs to review the consistency
of verification reports throughout all of its Immigration New Zealand branch
offices. This should identify any common deficiencies in the way verification is
reported, and enable the Department to improve and provide for consistency in its
reporting of identity verification.
| Recommendation 8 |
|---|
| We recommend that the Department of Labour review recent verification reports throughout the Department to identify any common deficiencies and to provide for consistency in the reporting of identity verification. |
4.45
There is no specific identity verification process within the UN-quota refugee
entry category. In line with United Nations guidelines on refugee protection and
resettlement, there is no verification work carried out in an applicant’s country of
origin as it may place applicants and their families at risk. Instead, refugee quota
immigration officers consult and engage directly with the UNHCR to clarify any
issues relating to refugee referrals.
4.46
The selection process for UN-quota refugees focuses on risk factors, security
screening, resettlement factors, and the credibility of the case. Assessments of
the credibility of refugees referred by UNHCR are carried out by refugee quota
immigration officers and risk profiling analysts in the Risk Assessment Team of the
Immigration Profiling Group.
4.47
Refugee quota immigration officers examine UNHCR refugee referrals for
discrepancies between information provided on a refugee registration form by the
UNHCR and information provided during and after the mission interview process. The use of DNA testing is available in any situation where there is reason to doubt
relationships (for example, in instances where the sponsor is applying for family
members who were not originally declared as family members). The Department
has indicated that DNA testing is not used regularly, as it is a costly, complex, and
logistically difficult process. There are generally only three or four cases each year.
4.48
Risk profiling analysts also examine refugee referrals. They provide advice on the
level of risk identified for each referral, and specific questions for refugee quota
immigration officers to ask during mission interviews and pre-mission briefings. After the mission, a risk assessment for each referral is carried out, based on
information provided during the mission interview.
4.49
The Refugee Quota Branch has checklists for processing applications, and the
Immigration Profiling Group has prepared refugee mission interview guidelines
that cover questions relating to risks to New Zealand’s international reputation. Interviews can take from one-and-a-half to two hours, and local interpreters are
often used. On the most recent mission, 330 people (some in family groups) were
interviewed in two weeks by two refugee quota immigration officers. Refugee
quota immigration officers have said there is not enough time during refugee
missions to complete the risk components of the interview as the questions are
too detailed.
4.50
Also, the review of the Immigration Profiling Group reported in October 2006
found that some staff within the Immigration Profiling Group were concerned
about whether refugee quota immigration officers on overseas missions had
sufficient time and the necessary risk identification skills when interviewing and
assessing refugee families for resettlement.
4.51
In view of the increasing demand on the Immigration Profiling Group from the
Refugee Quota Branch, the review recommended that consideration be given
to including a member of the Group in all missions, and that refugee quota
immigration officers receive training on risk assessment issues from the Group.
4.52
The refugee mission interview is an important part of the UN-quota refugee
selection process. Because it is the first time in the process that the Department is able to directly gather relevant information about cases referred to it for
resettlement by the UNHCR, it is essential that this information is able to be
gathered in a thorough and timely manner, given the number of interviews
carried out during a mission.
| Recommendation 9 |
|---|
| We recommend that the Department of Labour review the UN-quota refugee interview guidelines for questions relating to risks to New Zealand’s international reputation, to ensure that all relevant information can be gathered in a thorough and timely manner. |
Evaluation of detection activities
Our findings
4.53
The Department has not formally evaluated the effectiveness of its identity fraud
detection activities within the skilled migrant and UN-quota refugee categories. There are no formal systems to accurately collect, assess, and report on such
information.
4.54
The Department reports informally on its detection activities through team
newsletters. The Central Verification Unit produces a staff newsletter with
contributions from verification officers in New Zealand and overseas. The
newsletter communicates information about specific verification cases, trends,
and relevant convictions relating to cases managed by verification officers in the
Workforce Group.
4.55
There is no formal mechanism to retrieve or assess data on verification trends,
such as continuing experience of the qualifications claimed from a particular
university being fraudulent.
4.56
In preparing its business case for improving client profiling and verification, the
Department recognised that there was no consistent collection, evaluation, or
formal analysis of information for profiling and verification purposes within the
Workforce Group. The collection of information is not actively managed, and
information is not collected centrally in order to aid analysis.
4.57
The study of the Central Verification Unit commissioned by the Department in
May 2006 indicated that the Department did not use the Unit’s results to assess
whether its detection activities were working. The Department needs to make
more targeted use of the verification results, and gather more accurate data for
deciding current and future staff requirements.
4.58
Regular formal evaluation would enable the Department to measure the
effectiveness of its detection activities, and provide information and intelligence
to identify risks and inform its prevention and investigation priorities.
| Recommendation 10 |
|---|
| We recommend that the Department of Labour regularly and formally evaluate its detection activities, and gather and assess relevant information and intelligence from verification and assessment of skilled migrant applications and UN-quota refugee referrals. |