Checking callers who need a different approach
Some clients call through the National Relay Service, an interpreter or a support person, or can't easily use an SMS code. Here is what the published guidance says, and how we suggest applying it.
Help to communicate isn't identity, capacity or authority.
When someone helps a client communicate, it's easy to blur four things: who the client is, whether they can make the decision, whether they agree to it, and whether anyone else may act for them. A relay officer, interpreter or support person answers none of these by being there.
None of the sources below sets out a complete procedure for these calls, and no source says firms must offer a fixed number of check methods. Where this guide goes beyond their wording, it says so.
The call comes through the National Relay Service
Access Hub's guide for organisations says: "If you're required to authenticate the call, simply ask the same questions that you would of any caller." Speak to the client directly. The relay officer passes on your questions and the client's answers.
Access Hub: Guide for organisationsThe NRS can change voice to text or text to voice, so the voice you hear may be the relay officer's, not the client's. Don't compare it with the client's voice. Some NRS users do speak for themselves, so don't assume every relay call works the same way.
Access Hub: About the National Relay ServiceCaller ID can be faked, so a matching number doesn't prove who is calling. Our suggestion: arrange any call-back using contact details you established independently and the client's agreed way of communicating. For an NRS call-back, first find out which NRS option they use. A call-back doesn't by itself establish identity.
ACMA: Caller ID scams
You're speaking through an interpreter
TIS National tells agencies to "always speak in the first person and speak directly to the non-English speaker". Ask your check questions of the client, not the interpreter.
TIS National: How TIS National works for agenciesAn interpreter conveys what the client says. Our interpretation: having one on the line doesn't establish who the client is, whether they understand the instruction, or that anyone else may act for them. Those are separate questions.
TIS National: How TIS National works for agenciesTIS National notes that some private organisations may not accept its calls. Its Free Interpreting Service is only for eligible groups, so check your firm's eligibility and the service conditions before assuming interpreting will be free.
TIS National: Help using TIS National
A carer or support person is on the call
Find out who is on the line and what part they're playing. Our suggestion: confirm with the client that they want the person involved, and how much you may discuss, then keep addressing your questions to the client.
AHRC: Access for all (2016)If the support person wants to give instructions themselves, that's a question of authority. For requests to access personal information, the OAIC's APP 12 guidance expects the entity to be satisfied the requester is the individual or "another person who is authorised to make a request on their behalf". Our suggestion: check any authority to give instructions separately. Being family, a carer or the person holding the phone doesn't make someone authorised.
OAIC: APP 12, Access to personal informationFor solicitors, the Law Society of NSW says: "Before concluding lack of mental capacity, ensure that everything possible has been done to support the client to make a decision." Needing help to communicate isn't the same as lacking capacity, and a supporter isn't automatically a substitute decision-maker.
Law Society of NSW: When a client's mental capacity is in doubt (2016)
Your usual check doesn't suit this client
The Disability Discrimination Act covers failing to make reasonable adjustments for a person with disability. What's reasonable depends on the person and the circumstances. The Act doesn't prescribe a particular way to check a caller.
Disability Discrimination Act 1992 (Cth)The AHRC says the DDA requires businesses to make reasonable adjustments so people with disability can access their services, and suggests discussing adjustments with the person. Our suggestion: ask the client which way of checking works for them, and agree it before you need it.
AHRC: Access for all (2016)The ABA's vulnerability guideline suggests banks "offer a range of communication options". It applies to banks, but the idea carries over: one fixed method can shut some clients out.
ABA: Extra care for customers experiencing vulnerability (2024)
Record the adjustment, not the diagnosis
- The communication method agreed with the client, described as a need (for example "prefers written contact"), not a diagnosis
- Who was on the call and their role: relay officer, interpreter, support person
- What the client agreed others could hear or do, and any authority you checked
- Which check you used, the result, and any fallback
- Anything unresolved, and whether you paused or escalated
A suggested checklist, not a statement of minimum legal requirements. An adjustment note may itself reveal health information, and describing a need instead of a diagnosis doesn't remove privacy obligations. For firms covered by the APPs, collecting health information generally requires consent and must be reasonably necessary, unless an exception applies; the OAIC recommends generally seeking express consent. Record only what you need. OAIC: APP 3
A code check suits some of these clients, not all of them.
Vericode sends a short code to the Australian mobile your firm already holds and records the result. Being Deaf or having low vision doesn't by itself rule that out. It won't suit a client who can't read or pass on the code, needs more time than the code allows, shares a phone with someone else, or may be under pressure from someone in the room. Agree another check with those clients.
A correct result records that the code given matched the code sent to the nominated number. It doesn't show who received, read or passed on the code, or how they got it, which matters when a relay officer or interpreter is on the call. A correct read-back never establishes identity, capacity, consent or authority to act, and using Vericode doesn't, by itself, satisfy DDA, AML/CTF, VOI or other obligations.
- Disability Discrimination Act 1992 (Cth)
- AHRC: Access for all, improving accessibility for consumers with disability (2016)
- Access Hub: Guide for organisations
- Access Hub: About the National Relay Service
- TIS National: How TIS National works for agencies
- TIS National: Help using TIS National
- ACMA: Caller ID scams
- ABA: Extra care for customers experiencing vulnerability (2024)
- Law Society of NSW: When a client's mental capacity is in doubt (2016)
- OAIC: APP 12, Access to personal information
- OAIC: APP 3, Collection of solicited personal information
These organisations are cited for general guidance, not as endorsers of Vericode.
Ask how each client wants to be checked, at engagement.
It's easier to agree an adjustment calmly at the start than to improvise one during an urgent call.