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DVS Participation Agreement - FAQ

DVS Participation Agreement - FAQ

Document Verification Service (DVS) Participation Agreement  

What is the Document Verification Service Business User Participation Agreement? 

  • The Participation Agreement replaces your existing Business User Terms and Conditions with the DVS. 

When will the first email notification be sent to all the business users? 

  • The first email notification will be sent to business users on 20 January 2025 from IVS Manager. This email will advise business users that a separate email will be sent from Attorney-General’s Department Noggin platform, with instructions on how to sign and submit the DVS Business User Participation Agreement. 

I didn’t get the Participation Agreement what do I do?

  • You will need to email the IVS Manager direct to request the Agreement is sent to you at

IVS.Agreements@ag.gov.au 

What is the deadline for business users to sign the DVS Participation Agreement and what happens if the agreement is not signed by the deadline? 

  • The Identity Verification Services Act 2023 (Cth) requires all users of the DVS to sign the Participation Agreement by 13 June 2025. Failure to sign and return the Participation Agreement in adequate time for the DVS to review and approve your application will result in connection to the DVS being automatically removed on 14 June 2025. There is no extension to this date

Will I need to physically sign the DVS Participation Agreement? 

  • NO. To streamline the process and eliminate the need for physical signatures, the DVS Business User Participation Agreement can be digitally signed and witnessed. Once the agreement is signed, it must be uploaded via DVS’s Noggin platform. 

Does the new DVS Participation Agreement replace my existing DVS agreements? 

  • YES. The new DVS Business User Participation Agreement replaces the existing DVS Business User Terms and Conditions.  

What documents will be provided to business users? 

  • All necessary documents will be provided to the business users and will be included in the email from DVS’s Noggin platform and subsequent follow-up emails. The email will include: 

  • DVS Business User Participation Agreement (for signing) 

  • DVS Access Policy 

  • Attachment A – Updates to DVS definitions 

  • Attachment B – Comparison between the old Business User Agreements and the new Participation Agreement 

  • Instructions on how to complete and upload the Participation Agreement. 

Does Clause 3.4 of the Business User Participation Agreement mean that business users need to sign an additional contract with Austroads and Registries of Births, Deaths and Marriages? 

  • NO. Clause 3.4 refers to a separate Participation Agreement that will be signed between the Attorney-General’s Department, Austroads and Registries of Births, Deaths and Marriages. Business users will not be required to sign an additional contract with these organisations. 

Where can I get a comparison of the old DVS Terms and Conditions and the new Participation Agreement? 

  • Attachment B provided by the DVS provides an overview of the major difference between the two agreements.  

Do I submit a Compliance Statement with my Participation Agreement? 

  • NO. Users do not need to complete a compliance statement with your Participation Agreement.  The compliance statement process is being finalised and will be announced after the 14 June 2025 

Our business has overseas personnel, what do we need to do? 

  • Authorised DVS users must not access the DVS overseas without requesting and receiving approval from IVS.Manager@AG.gov.au. On request, a questionnaire will be sent. Organisations accessing the DVS without approval will not be able to enter into agreements or operate under the IVS Act as they will be in breach of the terms and conditions. Signed agreements from breached organisations will not be counter-signed by the Attorney-General’s Department until they are compliant with the IVS Act and subsidiary artefacts. 

Privacy Impact assessment

What are the obligations around conducting Privacy Impact Assessments (PIA)?
The IVS Act requires that a participation agreement must provide for privacy impact assessments (PIA) of requesting identity verification services.

The Department, as the Framework Administrator, is in the process of preparing a PIA for the DVS. The Department intends for the DVS PIA to cover the standard use of the DVS, with standard user types including GSPs, IDSPs or business users. Once the PIA is finalised, the Department will publish the PIA on the IDMatch website and notify all DVS users.

In accordance with the DVS user’s privacy obligations, and paragraph 5.3 of the standard participation agreement, users are to ensure their use of the DVS is consistent with the findings and recommendations of any PIA applicable to their use of the DVS. The agreements also require users to commission their own independent PIA for their use of the DVS if it is inconsistent with the findings and recommendations of the department’s PIA.

Will all business users be expected to have a PIA?
Yes, as per above, all business users will need to be covered by either the Framework Administrator’s general PIA, or have their own PIA.

When will the new PIA be available? How will it be communicated?
The Department is still developing the PIA. The findings and recommendations of the PIA will be published on the IDMatch Website. All DVS users will be notified once this has occurred.

The participation agreement requires business users to acknowledge that the PIA has been done. How can our business acknowledge the existence of a PIA by 30 April when that PIA will not be completed and published by DVS until the end of March 2025?
An existing PIA for the DVS is published on the ID Match website. DVS are in the process of updating this PIA following the commencement of the Act.

DVS anticipate this PIA will be published before May 2025, and will be in place before the legislative deadline of 14 June 2025 to execute the participation agreements.
As such, business users need to consider whether they would prefer to sign the agreement before, or after, receipt of the updated PIA.

Please consider, that the timeframe for signing the participation agreements by 30 April 2025 is to ensure agreements are signed, and reviewed and counter-signed by the Department, ahead of the statutory timeframe.

What happens if we have already signed the participation agreement and we subsequently identify that our use of the DVS is not consistent with the findings or recommendations of the updated PIA when it is published? How long do I have to address this?
As per above, a PIA for the DVS is already published on our ID Match website. The updated PIA will be published before the legislative deadline of 14 June 2025 to execute the participation agreements.

Clause 5.3(d) of the DVS business user participation agreement provides that once users identify that their usage of the DVS is not consistent with the PIA, then they must promptly notify the Department, commission an independent PIA, and share the findings with DVS.

The agreement does not specify a timeframe that any subsequent PIA needs to be commissioned by. However, it is recommended that users seek their own legal advice to ensure they meet their obligations under the agreement, and ensure any subsequent PIAs are conducted as soon as practicable.

 

Annual Compliance statement

What is the submission process for the annual compliance statement as per Addendum 1? Where does a business submit the compliance statement?
Businesses are not required to complete a compliance statement prior to 14 June 2025. Annual compliance statements will be due on a date that will be advised by the Department. DVS will provide further communication regarding the annual compliance statement process once the details have been finalised.

Are compliance statements required after 12 months usage or a set date during the year?
Clause 6.3 of the DVS business user participation agreement provides that the compliance statement should cover the 12 months preceding its submission date, or for a shorter duration if the DVS has been utilised for a shorter period. The Department will provide further guidance after the DVS business user participation agreements have been executed or closer to when compliance statements are due.

General  

Are there any changes to the requirements for obtaining customer consent under the new DVS Participation Agreement? Where can I find the consent statement? 

  • YES. Where previously express consent was a requirement under the Privacy Act, it is now a requirement under the Identity Verification Services Act 2023 (Cth). Guidelines for obtaining express consent can be found in the DVS Access Policy, Part 2, Section 2.50. including the below sample consent statement: 

☐ I confirm that I am authorised to provide the personal details presented and I consent to my information being checked with the document issuer or official record holder via third party systems for the purpose of confirming my identity.   

NOTE: the new IVS Act 2023 consent requirement is not materially different to the existing Privacy Act requirement, but you should review your current process and consent statement to ensure you remain compliant.  

What is the process for notifying the IVS Manager of overseas personnel? 

  • Any requests for overseas personnel or access must be sent to IVS.Manager@ag.gov.au. Our Audit and Compliance team will review your request and will contact you if any further information is required before processing it.

Will the new Participation Agreements mean the DVS users are no longer required to sign a Commonwealth Electoral Roll Declaration? 

  • Commonwealth Electoral Roll Declaration will still be required as per the current process. 

What do I do if I have issues logging into Noggin? 

Face Verification Service (FVS)  

What is the Face Verification Service? 

The FVS is a government service that compares a person's photo to the image on their government-issued ID, such as their passport or driver licence.   

The FVS is currently only available to government agencies, however the IVS Act (2023) has provision to make this available to commercial entities, similar to the DVS.  

Based on updates received from the IVS Manager, it is expected that the FVS will become commercially available in the second half of 2025. GBG are currently working to ensure that we make the FVS service available to our customers as soon as possible once it is available commercially.  

GBG customers wishing to use the FVS will need to sign a separate FVS participation agreement, details will be provided when they are available.  

Impacts to greenID service   

How does the new Participation Agreement impact my identity service? 

  • If you do not sign and return the Participation Agreement to DVS in adequate time for the DVS to review and approve your agreement by 13 June 2025, your access to DVS will cease on 14 June 2025 and DVS transactions will not be processed. 

Can GBG submit the new Participation Agreement for me? 

  • NO. You will need to use the link provided by the IVS Manager to sign and upload your Participation Agreement, Gateway Service Provider’s such as GBG cannot do this on your behalf.  

Can GBG provide advice on the changes to the Participation Agreement? 

  • NO. GBG cannot provide specific advice on the changes to the Participation Agreement. As each business is unique, the impacts and necessary adaptations required to implement the new terms are best evaluated by your legal and compliance teams. 

 

 

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