A folder called 'passports'
During an HR audit, a consultant opens a client's shared drive and finds a folder called 'passports'. It contains photographs of some staff documents, a few scans, and a note saying the rest are 'in the filing cabinet'. There is no record of who did each check, when, or how. A handful of employees have time-limited permission, and nobody knows when their follow-up checks are due.
Your consultancy is not responsible for the client's checks. But clients look to you to help them keep their house in order, and this is a common gap.
Why records end up like this
- Checks are done by whoever hires, often a site manager, with no standard way to record them.
- Evidence is saved wherever is convenient: email, phone photos, a folder, a drawer.
- Follow-up dates for time-limited permission are not entered anywhere that sends reminders.
- Clients using online checks and document checks store the results differently.
- Nobody reviews the whole picture until an audit or an inspection prompts it.
What this costs your clients and you
Clients carry risk they cannot see, and the Home Office guidance your advisers refer to sets expectations about how checks are done and recorded. Your consultants spend audit time piecing together what exists. When a follow-up date passes unnoticed, the client finds out late and the conversation is harder. And the effort of reviewing records by hand means it happens rarely.
| Item | Typical state | In the register |
|---|---|---|
| Who was checked | Unclear | Every employee listed, checked or not |
| How and when | Not recorded | Method, date and checker recorded |
| Evidence | Scattered files | Stored against the employee record |
| Follow-up date | Nobody's diary | Reminder to the client in good time |
| Gaps | Found at audit | Listed for your consultant |
How we build the register
- Each client's employee list is read from their HR system or payroll export, so the register starts complete, with everyone who should have a record.
- Existing evidence is uploaded against each employee, and the date, method and person who did the check are recorded through a short form.
- New starters get a check record created automatically when they are added, with a prompt to the hiring manager to complete it before their start date.
- Follow-up dates are entered where they apply, and reminders go to the client's named contact well before each date, then to your consultant if nothing happens.
- A gap report lists employees with no record, incomplete records or overdue follow-ups, for your consultant to raise with the client.
- Evidence files are stored with restricted access, in the client's own environment or yours as agreed.
How checks must be carried out, and what counts as acceptable evidence, are matters for the client and your advisers under the current guidance. The register records and reminds. It does not decide whether a check is valid.
What changes
Hiring managers get help too. The new starter prompt explains, in the client's own words, what needs to be recorded and where, so a site manager doing their first check is not guessing. Your consultants can adjust that wording per client as the client's own process changes.
Clients can see at a glance who has a complete record and who does not. Follow-up dates are handled before they pass. New starters are checked as part of joining, not months later. Your consultants spend audits discussing gaps rather than finding them. And your consultancy offers a practical, ongoing service that clients can see working.
Does this sound like your clients?
- Right to work evidence is stored in several places per client.
- Nobody records who did each check, or how.
- Follow-up dates are not in any reminder system.
- Gaps are only found during audits.
- Site managers do checks with no standard process.