Compliance, Vetting and Eligibility Policy
COMPLIANCE, VETTING & ELIGIBILITY POLICY
Last Reviewed: January 2019
Responsible Officer: Business Services Director
We supply temporary and interim social workers and support workers into councils, private organisations and charities across the UK. These workers are in contact with some of the most vulnerable people in society. It is our responsibility to ensure that we only ever recruit people who have the values, behaviours and competencies to support their client base effectively and to act in their best interests at all times.
We help protect the ultimate end users of our service by ensuring that we operate effective recruitment polices underpinned by robust procedures.
We work with a wide variety of clients both directly and through a number of Managed / Neutral Vendors and RPO’s who have wide range of compliance standards. It is our stated objective for us to work to the following minimum level of protection.
Registration Form and Medical Declaration:
All people applying to find work through Liquid Personnel are required to register. This is done through an electronic form and captures personal details including; changes of name, qualifications, address history; medical declaration and permission to take up references and share information appropriately. This allows us to use the information for registered purposes under the Data Protection Act. Our registration process is in compliance with our obligations under the Employment Agencies Act 2003.
Equal Opportunities Monitoring:
At point of first registration with Liquid Personnel all candidates are requested to complete an online equal opportunities monitoring form in line with guidance under the Equalities Act 2010. This is stored separately to the candidate’s main file.
We require a full CV of the applicant’s career history specified in months and years. All employment gaps need to be accounted for. This can be covered by correspondence from a UK benefits agency or passport stamps/visas. Where a person was not working and not able to give a verifiable account of their movements we will always bring this to the client’s attention prior to the start of an assignment.
This is crucial as it is important to establish the capabilities and wishes of the applicant, verify their identity, and take copies of original documentation. Trainee consultants do not undertake interviews until they have had the appropriate interview training.
Enhanced DBS Check / Update Service:
All temporary workers assigned through Liquid Personnel will have an in‐date DBS at enhanced level (issued within the past 12 months) in place prior to starting, and throughout their entire assignment. All enhanced DBS’s shall be in the name of Liquid Personnel as the employer, as we do not recognise the validity of portability in this context.
If the temporary workers are subscribed to the DBS Update Service with an existing DBS Certificate from a third party, Liquid Personnel will run an online check to ensure data remains accurate and appropriate to the level of supply into the health and social care sector.
Candidates are instructed to take DBS checks to interview at the client organisation (the candidate’s recruitment consultant checks this has been viewed by the hiring manager after interview) and on their first day of work as a temporary worker.
DBS Checks will be reapplied for at least 8 weeks prior to their expiry through our e‐bulk provider, Civil and Corporate Security Ltd (The average response time through this service is 7 days). End dates are managed through the compliance module of our CRM system. The client will be informed in situations where a DBS renewal is within 1 working week of expiry. DBS Checks are stored separately to the candidate’s main file.
We are happy to work with candidates who are registered with the DBS update service provided they have provided us with written permission to conduct an on-line status check.
PVG Scheme Check (Scotland):
All temporary workers assigned through Liquid Personnel for regulated roles in Scotland will have a PVG Scheme Record, in full compliance with the guidelines published by Disclosure Scotland.
Liquid Personnel apply for PVG Scheme Records in bulk via a registered Umbrella Body. All Scheme Record Updates will be requested at least 8 weeks prior to their expiry.
We will take copies of original certificates of qualifications relevant to the role the candidate will be undertaking. Where there is any doubt over validity of qualifications we will insist that the applicant shall provide a verification letter from the appropriate governing body or educational establishment e.g. the HCPC.
Effective referencing of prospective workers is a vital element of our service as not only does it help verify the validity of the person’s employment record, it provides a strong indicator of the suitability of workers for future positions. Our referencing process has a real focus on quality of practice.
Our standards for referencing are high. It is our policy to have a minimum of two references, covering a minimum of the past five-year period fully referenced with all gaps verified. The references that we obtain must meet the following criteria;
- Initial references are undertaken verbally over the phone by a member of the business support team to get as much detail as possible regarding suitability. A transcript of the verbal reference is then sent to the referee for verification, additional information and amendment where appropriate
- On past employers headed paper or validated by official stamp and addressed to us or from a recognisable business email address e.g.
- Month and year dates for start and finish dates must appear otherwise additional confirmation must be obtained.
- Must not be a Bearer references (to who it may concern)
- Must be written, verbal references are not accepted.
If a referee offers an alternative person to provide more detail, we must approach that person.
Where information provided on a reference contradicts information on a CV a full and proper investigation will be completed to establish fact. This may include but not be limited to contacting previous agencies/HR to obtain specific employment dates. CV embellishment is to be viewed as a risk to the end client.
Any unsatisfactory references that are returned must be referred to the Managing Director for their final decision. All cases of misconduct or dismissal reported on references will result in us removing the candidate from our live database of candidates and placing them in archive. Some employers have restrictions against providing full references. If this is documented by the employer on our reference form and confirms the dates, then this will be an acceptable reference. All references will be provided to the hiring manager prior to engaging the temporary worker, unless in the unlikely event that the referee has stated that they are not willing for the reference to be shared.
Change of Name:
Where a worker has changed their name for any reason and another name is shown on any required documentation we will obtain a copy of deed‐poll change, marriage certificate, divorce or statutory declaration.
Registration with the relevant professional body:
At point of registration for all qualified Social workers we will take and store a copy of their registration letter with the HCPC, SSSC or CCW. We also save a screen‐shot of their current registration status on the relevant professional body’s website, both at point of registration with Liquid Personnel and before the start of a temporary assignment.
We ensure that our entire database of qualified social workers are fully registered with the HCPC or other relevant body. All registration expiry dates are managed through the compliance module of our CRM system.
We act as counter‐signatory for our workforce’s renewals with the HCPC, SSSC or CCW and it is our policy to pay the renewal fee. Please note, only registered counter‐signatories within the company are authorised to do this.
We review monthly all the outcomes of the HCPC, SSSC or CCW disciplinary meetings and archive people from our database if they have been removed or suspended from a national register.
Identity and Eligibility to work in the UK:
We have a legal responsibility to ensure that we have established a person’s legal right to work in the UK before they have started and act in accordance with the Immigration Asylum and Nationality act 2006 to prevent any possible legal challenges on discrimination and to ensure that we do not allow a temporary worker to work illegally.
We will do this by asking prospective workers to produce original specified documents at the time of their interview. These documents are identified clearly in www.ukba.homeoffice.gov.uk. The documents required may be singular (e.g. a British passport), in combination (e.g. a full (long) British birth certificate and supported by a document from a government Agency/past employer with National Insurance number) and sometimes multiple. Where staff are in any doubt as to a person’s right to work legally in the UK OR they are relying on List B documentation the sign‐off should be escalated to the Compliance Manager or Business Services Director.
Where a worker is relying on List B documentation we must re‐check and re‐copy documentation every 12 months or when the document is due for renewal.
As of May 2014, candidates with a visa issued in an out of date passport are requested to obtain a Biometric Residence Permit and will not be permitted to commence employment via Liquid Personnel. To ensure that we manage this process effectively we must use the compliance module date rules set to 45 days.
All staff undertake a detailed document verification training program prior to reviewing any documents relating to eligibility to work in the UK. We undertake regular training updates for all staff involved in document verification.
Proof of residence:
It is our policy to obtain two proofs of the workers current address at interview stage. This must be dated within the last three months. Furthermore, we only accept the following official documents; bank statement, utility bill, council tax or correspondence from the Inland Revenue.
The overwhelming majority of the positions that we fill require the candidate to have access to a motor vehicle. As such we always look to take copies of originals at interview stage. These must be full driving license cards accompanied by a DVLA driving licence online check.
Business car use insurance:
We always ask a worker to provide us with a copy of their insurance schedule that specifically mentions Class 1 use. It is our policy not to reimburse expenses until a copy of valid car insurance has been provided.
Temporary worker service reviews:
When a temporary worker is in placement with a client, the temporary workers consultant at Liquid will undertake service checks with the line manager of the temporary worker. The purpose of these checks is to ascertain whether the temporary worker is performing as expected and to manage any issues if not. After completion of an assignment these service checks (alongside formal referencing and other checks) form an integral part of the decision-making process as to whether we replace the temporary worker, or the type of role that we replace them in.
N.B. Service reviews are only possible where we have a direct contract with the end client. It is an obligation of Liquid Personnel when working under a Neutral / Master Vendor agreement to have no contact with individuals within the end client organisation before or during the temporary workers contract.
Temporary worker contract and client confidentiality agreement:
A temporary worker will sign their contract prior to starting work in the client organisation. This contract details specifics about the role as per the placement summary pro forma– start date, line manager, hourly rate, location of work etc. It also includes a client confidentiality agreement as a key clause.
Approving a candidate’s vetting and compliance documentation:
The compliance file for each candidate is reviewed by the Compliance Manager and must be approved if a candidate is to start work in a temporary position. In the absence of the Compliance Manager, compliance reviews are undertaken by the Business Services Director.
If candidate compliance is unclear, the file is escalated to the Business Services Director for review. Prior to interview and placement start date the client hiring manager will always have clarity on the compliance of the temporary worker.