Worker Verification (KYC) Policy

Last updated: [EFFECTIVE DATE] | Version: 1.2 (a police clearance and a resume or biodata replace the NBI clearance as the standard requirement; an NBI clearance is still accepted in place of the police clearance)

Customers let Workers into their homes. To build trust, every Worker must be verified before they can be listed or receive bookings. This policy explains what we ask for, why, and how we protect it. It is part of the Privacy Notice and Worker Agreement.

1. What we require

Accepted ID types (examples): Philippine passport, driver's licence, UMID, PhilSys National ID (or ePhilID), PRC ID, postal ID, voter's ID, SSS ID, TIN ID, PhilHealth ID. [CONFIRM final accepted list; some IDs have security or format limits.]

Files: JPG, PNG or PDF, up to 8 MB each. Images must be sharp, uncropped and show all four corners.

2. Why we ask

• To confirm you are who you say you are.
• To reduce the risk of fraud and impersonation.
• To give Customers reasonable confidence about who comes to their home.

Collecting a police clearance (or an NBI clearance) involves sensitive personal information, because it shows whether you have been the subject of offences or proceedings. We collect it only with your consent, only for worker-safety screening, and we limit who can see it. Your resume or biodata is ordinary personal data (your contact details, address and work history); we use it only to check your identity and experience, and only authorised reviewers can open it.

3. How review works

1. You submit documents in the app and tap "Submit for review". Status becomes Pending.
2. Automated checks flag problems such as missing items, expired IDs, the same ID type used twice, or a duplicate ID already used on another account. [CONFIRM which checks exist at launch.]
3. AI-assisted pre-check (advisory only). If enabled, an automated assistant provided by a third-party AI vendor ([AI VENDOR NAME], [COUNTRY/REGION]) looks at the images of your IDs, police clearance (or NBI clearance) and selfie. It does not receive your resume or biodata. It reads the visible text (name, birth date, document dates, ID type, the last 4 characters of an ID number, the clearance result) and notes quality or consistency problems: blur, cropping, glare, screenshots or photos of a screen, possible editing, wrong document type, expiry, names or birth dates that do not match, the same document uploaded twice, a clearance older than 6 months. It produces a short suggestion (low, medium or high risk, with reasons) for the reviewer. It never approves or rejects anyone, and it is never the only basis for a decision. PDF files are not analysed. See section 3A.
4. A trained human reviewer examines the documents, compares names and photos across them, checks dates, and works through a written checklist (section 6A). [Future: third-party ID verification / face-match service, with a separate privacy assessment.]
5. The reviewer approves or rejects. Decisions are never made solely by automation (see section 3A).
6. You are notified in the app. If rejected, you see the reason (for example "Police clearance older than 6 months") and can fix and resubmit.

Target review time: [1-3 business days] (not guaranteed).

3A. AI-assisted pre-check: what it is and is not

• What is sent: only the images of your IDs, police clearance (or NBI clearance) and selfie, resized and stripped of photo metadata (such as GPS location). We do not send your resume or biodata, your phone number, account name, full ID number we hold, or any other account data.
• What is stored: the suggestion (extracted fields, flags and reasons) is stored encrypted, visible only to authorised reviewers, and only the last 4 characters of an ID number are kept from it. It is deleted on the same schedule as your documents (section 7) and immediately if you delete your account.
• Who processes it: [AI VENDOR NAME] acts as our processor under a written agreement that limits use of the images to providing this service for us, [prohibits using them to train its models], and sets retention at [NO RETENTION / MAX DAYS]. [CONFIRM actual vendor terms; zero-retention is preferred.] Processing may take place outside the Philippines (see the Privacy Notice, overseas processing).
• No solely automated decisions: a Jaypees reviewer makes every approval and rejection. An AI suggestion that is wrong, or that a reviewer disagrees with, has no effect on you. We do not automatically reject anyone because of the AI result. [LAWYER: confirm this satisfies the right to object to automated processing under Sec. 16(c)(6) / 18 of the DPA and IRR, and decide whether a separate consent line is needed.]
• Your choices: you can object to the AI pre-check at any time by emailing our DPO at [DPO EMAIL]. We will then have your documents reviewed by a person without the AI step [CONFIRM operational process and response time]. Declining the AI pre-check does not affect the outcome of your application.
• Safety of the model: documents can contain text meant to trick an AI. The system treats everything inside a document as data, checks the AI output against a strict format, and ignores anything that looks like an instruction. A document that tries this is flagged to the reviewer.
• Limits: AI can misread documents and can be wrong in both directions. Reviewers are trained not to rely on it.

What leads to rejection

The reviewer's written approval and rejection criteria are in section 6A.

Unreadable or edited documents, mismatched names, expired IDs, a clearance older than 6 months, a resume or biodata that cannot be read, a clearance showing a record relevant to the safety of customers (such as offences involving violence, theft, fraud or sexual offences), or suspected fraud. [LAWYER: define a written, non-discriminatory criteria policy for how criminal-record information is assessed, including the treatment of old, dismissed or unrelated matters, and the right to explain. A "hit" on a police or NBI clearance may be resolved with the issuing office; applicants can resubmit once cleared. Consider the Fair Chance / ex-offender employment-related guidance and the DPA principle of proportionality.]

4. Ongoing verification

• We re-check when a document expires, on a [yearly] cycle, or after safety complaints. You may be asked for a fresh police clearance.
• Verification can be revoked if information is found to be false.

5. Who can see your documents

• Only authorised Jaypees verification and compliance staff.
• Every access to a file is recorded in an audit log.
• Customers and other Workers never see your IDs. Your public profile shows only a "Verified" badge, never ID numbers (we display at most the last 4 digits to you and our reviewers).
• We may disclose documents to authorities when legally required.

6. Security of KYC data

Stored privately (not reachable by public URL), encrypted in transit and at rest, access via authenticated staff-only streams, least-privilege roles, and monitoring. See the Privacy Notice for details.

6A. Reviewer criteria and standard reasons

Every approval requires the reviewer to confirm, item by item (the confirmed checklist is saved in the audit log):

1. ID 1 is readable: all four edges, sharp text, no glare over the photo.
2. ID 2 is a different ID type, readable and unexpired.
3. Names match across both IDs and the clearance (minor spelling or middle-name differences may pass).
4. Police clearance issued within 6 months (or the NBI clearance uploaded in its place) and its result is visible. [A "hit" or record needs a second reviewer and the criteria in "What leads to rejection".]
5. Resume or biodata provided: it opens, is readable and is the worker's own.
6. Selfie matches the ID photo (the reviewer's own judgement, not the AI's).
7. No signs of editing: mismatched fonts, pasted photos, screen photos, blurred or overwritten fields.

Rejections use a standard reason so the worker knows how to fix it: ID unreadable or blurry; glare or shadow on ID; ID expired; both IDs the same type; names do not match; clearance older than 6 months; clearance result not visible; resume or biodata unreadable; selfie unclear; selfie does not match ID; photo of a screen or a copy; signs of editing; wrong document type; ID already used on another account; other (free text). Reviewers add a plain message the worker can act on. [LAWYER: review the reasons for fairness and non-discrimination.]

7. Retention and deletion

Reason for these periods: we need to keep enough to investigate incidents and defend claims after a job, but not longer than needed, because identity documents are high-risk if leaked. Periods are subject to legal review.

8. Your rights

You may access, correct, object to (including to the AI-assisted pre-check), or ask for deletion of your KYC data, and complain to the NPC. Contact our DPO at [DPO EMAIL]. See the Privacy Notice.

9. Our limits

Verification checks documents at a point in time. It does not prove future behaviour, skill, health, or that you have no record not shown on a police or NBI clearance. Jaypees does not conduct a full background investigation.

10. Honest information

Submitting false or altered documents is a serious violation. We will ban the account and may report it to authorities (for example under the Revised Penal Code on falsification, and the Cybercrime Prevention Act, RA 10175).

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Drafting notes (remove before publishing)

• Retention numbers are proposals. Principle: shortest period that supports safety investigations and legal claims. Consider deleting clearance images soon after verification.
• Conduct a Privacy Impact Assessment for KYC; document the criteria for evaluating police clearance results, and add the resume or biodata to the data inventory.
• If a third-party eKYC vendor is added, update processor list and overseas-transfer disclosures.
• AI pre-check (ADR 0012): keep the feature OFF in production until counsel and the DPO have approved this text, signed a data processing agreement with the AI vendor (no training, retention, sub-processors, breach notice), completed the Privacy Impact Assessment addendum, and decided the objection process. The API refuses to enable the vendor in production without an explicit KYC_AI_LEGAL_SIGNOFF=true.
• Update the in-app consent text and its version together with this policy; the app and API both use the consent version 2026-10-v3 (which names the police clearance and resume).