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CQC Essentials: SMARTcards

NHS providers are required to obtain proof of identity (with a recent photograph) when recruiting staff, the CQC will accept SMARTcards as proof of ID when assessing whether practices meet this requirement.

This article relates to the CQC key question: Is your practice safe? 

CQC has had a number of queries from GP practices asking whether staff having a SMARTcard is evidence that the provider sought proof of ID when recruiting.

NHS SMARTcards are issued to health professionals to give them secure access to confidential patient’s data, including personal and healthcare details.

A SMARTcard is printed with NHS staff member's name, photograph and unique user identity number. To obtain a SMARTcard an identity check must be carried out which includes:

  • a mandatory face-to-face meeting
  • at least three forms of evidence (including photo and non-photo forms)
  • proof of address.

Regulation 19: Fit and proper persons employed

Our inspection of GP practices is underpinned by the Health and Social Care Act 2008. From 1 April 2015 all providers carrying on a regulated activity must meet the new fundamental standards of care, including Regulation 19: Fit and proper persons employed.

The intention of this regulation is to make sure that providers only employ 'fit and proper' staff who are able to provide care and treatment appropriate to their role and to enable them to provide the regulated activity. To meet this regulation, providers must operate robust recruitment procedures, including undertaking any relevant checks.

Regulation 19(3)(a) requires a provider to have certain information available in relation to their staff, including proof of identity (with a recent photograph). This information should be collected at the point of recruitment.

When inspecting GP practices we will accept SMARTcards as proof of ID to demonstrate compliance with this part of the regulation. The SMARTcard application process involves a rigorous identity check – therefore a person with a SMARTcard would have been through this process.


To demonstrate compliance, we expect to see evidence that the provider has checked that staff have a SMARTcard; a copy of the SMARTcard must be kept in the employee’s file as proof of ID.

Where a new member of staff has not worked in the NHS before, and will therefore need to apply for a SMARTcard following appointment, the provider will need to demonstrate that they 'requested' the ID photo at the time of recruitment rather than at the time of SMARTcard request.

For those that do not have a SMARTcard, alternative ID will be needed.

  • Professor Nigel Sparrow is senior national GP advisor and responsible officer at the CQC

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