With the rugby Xplorer system, it seems to be an easy thing to do
Clubs have raised the fact RX doesn't require a photo as one issue. Subbies has acknowledged that, noting that the photo is not critical to things like finals (where you need to bring ID anyway) but more for day-to-day i.e. clubs checking clubs. Even when Fuse required photos, it was - to put it politely - a mixed bag.
I believe it works like this (in terms of record creation): you might already have an RX profile e.g. I have one because I'm a ref and that's how the ref's association members register each year. Anyone might have RX for a similar reason e.g. Juniors or Schools Rugby - pretty much every other Union was on RX except Subbies and Premier until this year.
If someone has no RX profile they create their account and get a MyRugbyID.
When you go into RX and Register for a Subbies (or Premier) club, it sends your details to Fuse - checks name and DOB and sees if there is a match.
No match = New Fuse Record.
Match = retrieves what is on file under that name and DOB.
I found this out by accident - a guy new to the club this year attempted to register. They thought it didn't work, so tried again *sigh*
I suddenly had two profiles in Fuse with the same details, different birthdates - turns out they'd fat-fingered their DOB on the first profile and screwed up one digit in haste.
The profile with the incorrect DOB had a "new" Fuse profile.
The second profile had their correct DOB and pulled their "old" fuse profile with the correct DOB.
I double checked with Subbies and they did some kind of merge, and now everything is in one place as far as Fuse is concerned.
This system of matching name and DOB basically breaks if no precise match is found, so if you mess up DOB, or spell first name / surname incorrectly, it pretty much thinks you're a new person.