Fair Checks Before Authorised Deployment
Version: 1.0 · Published: 21 October 2026 · Policy responsibility: UK Operations, with director oversight · Review: by 21 October 2027, or sooner following a relevant change.
Purpose and scope
This policy sets a fair, proportionate route from defining a cleaning role to authorising a suitable person to work at a client site. Recruitment checks, competence assessment and site access are separate controls. Completing one does not automatically satisfy the others.
It covers direct recruitment and the checks and responsibility allocation required when agency workers, subcontractors or cover personnel are used. The actual legal relationship and applicable law determine responsibilities, rather than a label such as self-employed.
Accountability and fair treatment
UK Operations must define role requirements, identify required checks and appoint a manager to review their completion. A director must oversee significant exceptions or unresolved concerns. Supervisors must confirm that the person arriving is the authorised individual and that the site briefing has been completed.
Selection must use relevant, consistent criteria. Applicants must be offered a way to request reasonable adjustments. Immigration, identity and suitability checks must be applied without discrimination or assumptions based on nationality, name, accent or appearance. Health questions must be limited to what the law permits at the relevant stage.
Recruitment sequence
- Record duties, working hours, location, access, supervision and contact with children or adults at risk where relevant.
- Define essential experience, capability and any lawful role-specific checking requirements.
- Assess applications and interviews consistently and explain the outstanding checks in any conditional offer.
- Verify identity and complete the applicable prescribed right-to-work check before relevant work starts.
- Obtain proportionate references and verify qualifications or competence where relied upon.
- Establish criminal-record-check eligibility before requesting a particular level of check.
- Give the applicant a fair opportunity to explain discrepancies and assess the relevant evidence.
- Record the deployment decision, restrictions and any required follow-up dates.
- Complete training, site induction and controlled issue of access credentials before independent work.
Identity and right to work
The responsible manager must follow current Home Office requirements, using the appropriate prescribed route rather than treating a passport copy, National Insurance number or informal assurance as sufficient in every case. Confirm the person matches the evidence, identify restrictions and arrange follow-up checks where required.
For agency, worker and subcontract arrangements, map checking responsibilities against the actual arrangement and current guidance, including relevant commencement or transitional provisions. A supplier’s assurance does not replace a check that the law requires Citywide to carry out itself. Do not assume a commercial contract automatically establishes or removes responsibility.
Where the Home Office guidance requires right-to-work evidence to be retained, apply its specific retention rule, normally throughout employment and for two years afterwards. That period is not a blanket rule for all recruitment information.
Employment history and references
Ask for information relevant to the role and investigate material inconsistencies fairly. Obtain an applicant’s permission before approaching their current employer and normally do so after a conditional offer. Explain the type of reference needed.
If a reference is unavailable, the manager must consider proportionate alternative evidence and record the decision. An employment gap, a name change or a former employer’s refusal to provide a reference is not automatic evidence of dishonesty. No unsupported claim is made that every role requires a fixed number of years of history or a particular number of references.
Criminal-record checks and safeguarding
| Location or role | Policy requirement |
|---|---|
| Ordinary commercial office | Assess the role and risk; do not automatically promise an Enhanced DBS check |
| School or healthcare setting | Establish actual duties, location, contact and supervision before selecting the lawful check |
| Sensitive office access | Assess proportionate controls, confidentiality and access authorisation; client preference alone does not create check eligibility |
| England and Wales | Use DBS routes and current eligibility guidance; barred-list access requires its own eligibility |
| Scotland | Apply Disclosure Scotland requirements and PVG rules where the role is within scope |
| Northern Ireland, if deployed | Apply AccessNI rules and relevant eligibility requirements |
A check is evidence at a point in time, not a guarantee of future behaviour. Assess disclosed information fairly, considering legal restrictions, filtering rules, relevance and the opportunity to explain. Seek authoritative advice where eligibility or disclosure rules are unclear. Do not require applicants to disclose information the law protects from disclosure.
Agency staff, subcontractors and urgent cover
Before a worker is accepted, identify the supplying organisation and the person, confirm the relevant checking responsibilities and obtain suitable evidence. Agree permitted substitution and notification arrangements. Further subcontracting must not conceal who is supplying labour or supervising the work.
Urgency does not authorise bypassing a legally required check, accepting an unidentified substitute or sharing another person’s pass. Where requirements are incomplete, delay the affected deployment or restrict duties only where lawful and safe. Record the decision and the person authorising it.
Illustrative example: A cover cleaner arrives at a secure office with another worker’s fob. The supervisor must verify identity and authorisation and follow the approved access process. Possession of a pass is not proof that recruitment or security checks are complete.
Privacy, review and records
Explain how applicant data will be used through an appropriate recruitment privacy notice. Collect only relevant information, restrict access and apply a retention schedule by record category. Criminal-offence information requires an appropriate lawful basis and additional legal conditions; applicant consent alone does not settle every requirement.
Do not send full identity documents, immigration evidence or criminal-record certificates to clients by default. Share only information necessary and lawful for the purpose, using an appropriate secure route. Applicants must have a way to raise inaccuracies or concerns.
Managers must track relevant permission expiry and follow-up dates, role changes, access withdrawal and unresolved actions. Audit completion and exceptions without presenting unverified statistics as performance results. Review the policy after legal changes, a significant checking failure or a change in labour arrangements.
Reporting and related information
Raise concerns with UK Operations. If the concern involves the recruiting manager, request director-level review through Contact Citywide. Do not attach identity documents to a general enquiry. Read alongside Citywide’s policy framework and the Staff Training and Competence Policy.
References: Home Office right-to-work guidance, DBS eligibility guidance, Acas references, Disclosure Scotland, AccessNI check types.
