Chasing candidates for compliance packs, and why it never ends

What the pack has to contain #

The legal floor is regulation 19 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003. Everything else stacks on top of it.

• The legal floor Regulation 19

  Before an employment business introduces or supplies a work-seeker to a hirer, it must obtain confirmation of the work-seeker’s identity, and confirmation that they have the experience, training, qualifications and any authorisation the hirer considers necessary, or that is required by law or by a professional body.

• Higher risk roles Regulation 22

  Further requirements apply where a role needs a professional qualification or authorisation, or where the work-seeker will be working with vulnerable people.

• Whatever the client wants on top

  Driven by its own obligations or its own procurement rules: references in a particular format, specific training certificates, a site induction, an occupational health form, evidence of insurance for a contractor.

• The right to work check

  Separately again, the right to work check, which is a different duty with a different owner and a different penalty.

Why it stalls, structurally #

Three things make the chase harder than the arithmetic suggests.

• The state of the pack is not written down anywhere complete

  A field in the CRM says “compliance: in progress”. The actual position, that two references are in, one referee has bounced, the DBS is with the candidate and the training certificate was sent as a photograph of a screen, lives in an email thread and in one consultant’s head. Anyone else who touches it has to reconstruct it, and the cheapest way to reconstruct it is to ask the candidate again.

• Nobody on the other end has a deadline

  The candidate has already got what they wanted, which is the offer. The referee is doing you a favour. The client’s onboarding contact has forty other things on. The only person with urgency is the consultant, which is why the chase is always outbound and never inbound.

• The same evidence has to be produced more than once

  A worker placed at three sites for two clients generates the same documents in three portals, often rekeyed by hand because the portals do not accept a file the agency already holds.

Where the hours actually go #

If you watch a consultant do this for a week, the time does not go on collecting documents. It goes on the five minutes before and after each one.

1. Working out what is outstanding

2. Writing the message

3. Logging that the message was sent

4. Deciding when to send the next one

5. Answering an internal question about whether somebody can start on Monday

A pack of a dozen items generates dozens of those small interruptions, each too short to schedule and too frequent to ignore.

Then there is the record keeping at the end. Regulation 29 requires records to be kept for at least a year from creation, and for work-seeker and hirer applications, at least a year after the agency last provided services to that person. They may be electronic, but they have to be reproducible in legible form and deliverable within two business days of a request.

Which parts of the chase run on rules #

The pattern repeats across the desk, and it is set out in full in what agency admin genuinely runs on rules. If you want to size it before you talk to anybody, the free tools count hours rather than recommend software.

What this does not fix #

Compliance duties do not move. The Conduct Regulations are enforced by the Fair Work Agency, which took over from the Employment Agency Standards Inspectorate, and REC members sign up to a Code of Professional Practice on top of that.