This page provides examples of how you may use alternative identification procedures to identify individuals who may not be able to provide standard identification. 

On this page:

• Individuals affected by family and domestic violence
• Individuals affected by a natural disaster
• Individuals in prison or recently released from prison
• Intersex, transgender and gender diverse individuals
• Related pages

Individuals affected by family and domestic violence

It’s critical for the safety of people affected by family and domestic violence to have access to financial services independent of the perpetrator. This also applies to financial abuse and elder abuse. 

Importance of confidentiality

Confidentiality is critical. It’s important you don’t take any steps that would alert the perpetrator to an individual’s activities.

It’s important that you don’t ask for details or evidence of the violence. This includes asking for this level of detail from victim-survivors and their advocates, referees and support persons.

A statement by a referee will generally be sufficient if it states:

• the individual has experienced family or domestic violence
• why this has impacted their ability to access identification documents.

Example: Customer needs to get new identification documents

Customer D’s partner doesn’t allow her to have access to a bank account and has hidden her identification documents. She recently fled without any identification documents and is staying at a friend’s home. She needs to open a bank account urgently to receive Centrelink payments and a grant to relocate to her parents’ home interstate.

Replacing each of Customer D’s identification documents is difficult and time-consuming. She is also experiencing delays getting new identification documents because she’s at a temporary address.

Her doctor of several years is familiar with her situation. They provide a reference to the bank from their official email address. The bank does an internet search of the clinic to confirm its legitimacy. They also check if the doctor is registered on the AHPRA register of practitioners. 

The bank assesses the ML/TF risk of providing Customer D with the designated service as low and opens the account. The bank requests that Customer D provide her identification documents as soon as she is able.

Example: Customer unable to obtain identification documents

Customer E is living with her brother who controls her finances and prevents her from working. She recently fled her home to a domestic violence refuge.

Customer E goes to the bank to open a new account so she can get Centrelink payments. She only has photos on her phone of her passport and driver’s licence. These show her previous address.

The refuge director provides a written reference to the bank from their official email address and copies in Customer E. The bank assesses the ML/TF risk of providing Customer E with the designated service as low. The bank opens the account with a requirement that Customer E provides her new identification documents when she gets them.

The police help her to retrieve her belongings and identification documents. She returns to the branch 2 weeks after the account is opened and completes the standard identification checks.

Individuals affected by a natural disaster

Individuals affected by a natural disaster may have suffered significant losses or property damage. They may not have access to identification documents, or they may have been destroyed. It can take time to piece together information and apply for replacement documents. 

Example: Customers’ identification documents are destroyed

Customers F and G are a married couple who operate a mixed farming enterprise. A major bushfire recently impacted their region. Like many of their neighbours, they lost their home, surrounding buildings, farm machinery, fencing and stock.

The fire destroyed all their personal and business documents, including identification. This prevents them from accessing their bank accounts, including getting an Australian Government disaster recovery payment.

They visit their nearest bank branch. The bank is mindful of the hardship the community has endured. The bank works with the couple to determine the most appropriate form of alternative identification. The couple agree to obtain a referee statement confirming their personal details and circumstances.

A local police officer witnesses a statutory declaration confirming their identities. The reference states the family was affected by the bushfire resulting in the loss of their identification documents.

The bank provides access to their bank accounts. Customers F and G agree to provide standard forms of identification once they are replaced.

Individuals in prison or recently released from prison

Accessing standard forms of identification can be difficult for people in, or recently released, from prison. This creates barriers to opening or accessing an account for a range of reasons, including:

• they didn’t have standard forms of identification when they entered prison
• the identification expired, was lost, stolen or misplaced
• their bank account was deactivated
• they don’t have a stable address upon release. 

People released from prison who are eligible for a Services Australia Crisis Payment need an active bank account to get the payment.

In some states and territories, corrective services may issue photographic identification to assist people transitioning out of the prison system. 

People in prison may use financial counsellors, case workers and reintegration officers to help them to open a bank account.

Example: Customer will soon be released from prison

Customer H is due to be released from prison in 2 weeks and will get a Crisis Payment. However, her bank account was closed during her time in prison.

Customer H’s identification documents have expired. It will take some time to get a proof of age card.

A financial counsellor has worked with Customer H for 12 months and is familiar with her situation. The counsellor provides the bank with a written reference.

After speaking to the counsellor, the bank agrees to open a new account for Customer H so she can get and access the Crisis Payment. Customer H agrees to provide standard identification documents when she receives them. 

Intersex, transgender and gender diverse individuals

Individuals who are intersex, transgender (trans) or gender diverse may not have matching or accurate forms of identification.

This can be for a range of reasons, including:

• different state laws and eligibility for changing gender markers
• a change in appearance that doesn’t match photo identification
• inability to access documentation, which may be held by unsupportive parents or guardians of a minor
• the high cost of updating and replacing identification documents
• the emotional burden of navigating administrative processes that may also expose the individual to discrimination.

Misgendering

Individuals who don’t have identification documents matching their gender or preferred name may experience misgendering as a result. This can be distressing for those affected. 

Misgendering is when an individual is addressed in ways that don’t align with their gender, including using:

• incorrect pronouns (he/she/they) or titles (Mr/Ms/Mx)
• an individual’s previous name (informally known as ‘deadnaming’).

How to help

To support intersex, trans and gender diverse individuals, you could: 

• consider adding optional information fields where individuals can provide details like their pronouns and preferred name
• promptly update an individual’s details across all correspondence, platforms and transaction records upon receiving updated identification documents
• make sure staff maintain accurate records and file notes so individuals don’t have to repeatedly explain their situation.

Related pages

• Identifying individuals who don’t have standard identification
• Customer due diligence.