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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Agency Representation Policy (Professional Image and Conduct in Client Settings)

1. Purpose

The purpose of this Agency Representation Policy is to establish clear standards of professional conduct, appearance and behaviour for temporary workers supplied by {{org_field_name}} while undertaking assignments within client organisations.

{{org_field_name}} operates as an employment business supplying temporary workers to client organisations. {{org_field_name}} does not itself provide, manage, direct or supervise regulated care or treatment and does not assume responsibility for the clinical or care services provided by its clients. Temporary workers supplied by {{org_field_name}} work under the appropriate direction and control of the client organisation for the purposes of their assignment.

Where a client organisation carries on a regulated activity, responsibility for compliance with the regulatory requirements applicable to the provision of that regulated activity remains with the relevant registered provider. Temporary workers must nevertheless comply with all lawful, reasonable and applicable policies, procedures, professional standards and instructions communicated by the client organisation while undertaking an assignment.

This policy is intended to ensure that temporary workers represent {{org_field_name}} professionally and behave in a manner consistent with applicable legal requirements, professional standards and the standards reasonably required by the client organisation.

This policy should be read in conjunction with the Employment Agencies Act 1973, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, the Agency Workers Regulations 2010, the Employment Rights Act 1996, the Equality Act 2010, the Working Time Regulations 1998, applicable health and safety legislation, safeguarding legislation, data protection legislation and, where applicable to the individual worker, the requirements of the worker’s professional regulator.

Registered nurses must comply with the NMC Code and maintain the registration and professional requirements necessary for the work they undertake. Healthcare support workers and adult social care workers must comply with applicable professional and sector standards relevant to their role.

Where temporary workers are supplied to a client that is regulated by the Care Quality Commission, workers must follow the client’s applicable policies and procedures and any requirements relevant to their work. Nothing in this policy represents {{org_field_name}} as a CQC-registered provider or as the provider of the regulated activity.

2. Scope

This policy applies to:

• All temporary workers engaged, employed or otherwise supplied by {{org_field_name}}, including registered nurses, healthcare assistants, support workers and other temporary healthcare or care personnel, whether engaged under a contract of employment, worker contract, zero-hours arrangement, casual arrangement or other lawful form of engagement.
• All assignments undertaken through {{org_field_name}}, including assignments within care homes, nursing homes, hospitals, residential settings and other health or social care organisations.
• All office, recruitment and managerial staff of {{org_field_name}} insofar as they are responsible for the supply, placement, administration or conduct management of temporary workers.
• All periods during which a temporary worker is representing {{org_field_name}} in connection with an assignment, including attendance at the client’s premises, client-specific induction, work-related meetings and authorised travel undertaken on client business.

For the avoidance of doubt, where a temporary worker is supplied to a client organisation, responsibility for the day-to-day direction and control of the work undertaken during the assignment rests with the client in accordance with the applicable contractual arrangements. {{org_field_name}} remains responsible for fulfilling its legal obligations as an employment business and for matters relating to its own contractual relationship with the temporary worker.

3. Related Policies

• Code of Conduct for Temporary Workers
• Uniform and Appearance Policy
• Safeguarding Adults and Children Policy
• Health and Safety Policy
• Whistleblowing Policy
• Incident Reporting and Management Policy
• Equality, Diversity, and Inclusion Policy

4. Professional Image and Conduct Overview

{{org_field_name}} requires all temporary workers to:

• Present a professional, safe, and positive image of themselves and the agency at all times
• Deliver care in a way that reflects the core values of respect, dignity, kindness, and competence
• Be punctual, reliable, and committed to providing high-quality care
• Follow client-specific policies and procedures as well as those of {{org_field_name}}
• Communicate effectively, professionally, and respectfully with service users, relatives, colleagues, and client staff
• Demonstrate accountability and integrity at all times

5. Professional Appearance

5.1 Uniform and Dress Code

Temporary workers must:

• Wear the uniform provided by {{org_field_name}} or the client organisation (where applicable)
• Ensure that uniforms are clean, well-maintained, and appropriate for the task and setting
• Wear an agency-issued photo identification badge at all times while on duty
• Avoid wearing clothing, jewellery, or accessories that may present health and safety risks (e.g., long necklaces, false nails, open-toe footwear)
• Follow infection prevention and control measures relating to appearance (e.g., bare below the elbows)
• Maintain good personal hygiene and grooming standards

5.2 Personal Presentation

Temporary workers must:

• Avoid strong fragrances which may cause discomfort to service users
• Ensure hair is tied back where appropriate
• Present a professional and tidy appearance at all times
• Refrain from wearing excessive make-up or inappropriate accessories

6. Professional Behaviour and Conduct

Temporary workers must:

• Always act with courtesy, kindness, and respect towards service users, relatives, colleagues, and client staff
• Promote dignity, privacy, and autonomy for service users
• Communicate clearly and appropriately, avoiding slang, inappropriate language, or discriminatory remarks
• Avoid gossip, criticism, or negative remarks about clients, colleagues, {{org_field_name}}, or other stakeholders
• Remain vigilant to safeguarding concerns and report any concerns immediately in line with the Safeguarding Policy
• Never engage in behaviour that may bring {{org_field_name}} into disrepute or undermine public trust

7. Punctuality and Attendance

Temporary workers must:

• Arrive punctually for all assignments and shifts
• Notify both the client and {{org_field_name}} immediately if delayed or unable to attend
• Complete the full duration of assigned shifts unless authorised otherwise
• Follow absence reporting procedures in the Absence Management Policy
• Avoid leaving assignments early without prior agreement from the client and {{org_field_name}}

8. Confidentiality and Information Governance

Temporary workers must:

• Maintain the confidentiality and security of personal, confidential, clinical, commercial and organisational information obtained or accessed during an assignment.
• Access, use, disclose and record personal information only where this is necessary and authorised for the performance of their role, or where another lawful basis permits or requires the disclosure.
• Comply with the UK General Data Protection Regulation, the Data Protection Act 2018, the client’s applicable information governance and confidentiality procedures, and {{org_field_name}}’s Data Protection and Confidentiality Policy.
• Take particular care when handling special category personal data, including information concerning an individual’s health, and any criminal offence information.
• Use only systems, devices and communication methods authorised by the client organisation or {{org_field_name}} for the relevant purpose.
• Keep records, passwords, access credentials and information secure and must not permit unauthorised persons to access confidential information.
• Report any actual or suspected loss, unauthorised disclosure, unauthorised access, cyber-security incident or personal data breach immediately in accordance with the client’s reporting procedure and to {{org_field_name}} where the matter concerns or may concern {{org_field_name}}.
• Return, securely dispose of or cease accessing client information at the conclusion of the assignment where required by the client or {{org_field_name}}.

Nothing in this policy prevents or restricts a temporary worker from:

• raising a safeguarding concern;
• reporting a criminal offence or other matter to the police or another competent authority where lawful;
• making a protected disclosure under applicable whistleblowing legislation;
• reporting a matter to an appropriate prescribed person or professional regulator where the legal requirements for doing so are met; or
• making any other disclosure that is required or protected by law.

Temporary workers must not misuse confidential information and must disclose no more information than is reasonably necessary for the lawful purpose of the disclosure.

9. Boundaries and Relationships

Temporary workers must:

• Maintain clear professional boundaries with service users, families, and colleagues
• Never accept gifts, loans, or personal favours from service users or relatives, except as permitted under the Gifts and Hospitality Policy
• Avoid forming personal or inappropriate relationships with service users or their families
• Refrain from sharing personal contact details with service users or their families
• Seek advice from {{org_field_name}} if unsure about maintaining professional boundaries

10. Use of Technology and Social Media

Temporary workers must:

• Never use personal mobile phones during working hours unless on a designated break in a private area
• Never use phones or personal devices to take photographs or videos within client premises
• Avoid posting comments or images on social media that relate to service users, clients, or {{org_field_name}}
• Maintain confidentiality and professionalism when using social media
• Follow the Social Media and Communications Policy where applicable

11. Health and Safety

{{org_field_name}} will, before supplying a temporary worker to an assignment, obtain from the client the information required by applicable employment agency legislation concerning the assignment, including relevant information about the nature of the work, location, working hours and any known health and safety risks associated with the position together with the measures taken by the client to prevent or control those risks.

{{org_field_name}} will provide the temporary worker with the health and safety information concerning the assignment that it is legally required to provide and will take reasonably practicable steps within its role as an employment business to protect the interests of the temporary worker and the client.

The client organisation remains responsible for the health and safety matters falling within its control at the workplace, including the working environment, workplace-specific risks, systems of work, equipment and appropriate local instruction.

Temporary workers must:

• Comply with the client’s health and safety policies, procedures, risk-control measures and reasonable instructions.
• Attend and comply with any required workplace or assignment-specific health and safety induction.
• Follow applicable infection prevention and control procedures, including hand hygiene and the appropriate use of personal protective equipment.
• Use equipment only where they are competent, authorised and appropriately trained to do so.
• Report hazards, defective equipment, unsafe practices, accidents, incidents and near-misses promptly to the appropriate person within the client organisation and to {{org_field_name}} where required.
• Stop and seek advice before undertaking work that they reasonably believe falls outside their competence, training or authority or presents a serious and unmanaged risk to health or safety.
• Cooperate with the client and {{org_field_name}} in relation to lawful health and safety requirements and investigations.

This section does not transfer to {{org_field_name}} responsibility for the client’s workplace, clinical governance or the day-to-day direction and control of the work performed during an assignment.

12. Incident Reporting

Temporary workers must:

• Report all incidents, accidents, and near-misses to both the client organisation and {{org_field_name}} in line with the Incident Reporting and Management Policy
• Document incidents clearly and factually without delay
• Cooperate fully with investigations by the client, {{org_field_name}}, or regulators

13. Responsibilities of {{org_field_name}}

{{org_field_name}} will comply with its legal responsibilities as an employment business before and during the supply of temporary workers.

In particular, {{org_field_name}} will:

• Agree and provide the terms and information that it is legally required to provide to work-seekers before providing work-finding services, including a Key Information Document where required by the Conduct of Employment Agencies and Employment Businesses Regulations 2003.
• Obtain sufficient information from the client about each assignment before supplying a temporary worker, including the identity of the client, the nature of the work, start date and expected duration, location, working hours, health and safety risks and control measures, and any experience, training, qualifications or authorisations required by the client, by law or by a relevant professional body.
• Provide the temporary worker with the information about an assignment that the agency is legally required to communicate.
• Confirm that the temporary worker is willing to undertake the position before supplying them to the client.
• Take all reasonably practicable steps required by law to ensure that the proposed supply is not detrimental to the interests of the temporary worker or the client.
• Verify, before supply, any qualification, professional registration or authorisation that the temporary worker is required by law or a professional body to hold for the position.
• Where the position involves working with, caring for or attending a vulnerable person for the purposes of the Conduct of Employment Agencies and Employment Businesses Regulations 2003, obtain two written references from persons who are not relatives of the temporary worker and who have agreed that their references may be disclosed to the client, and offer copies of those references to the client.
• Obtain and offer to the client copies of the relevant qualifications and authorisations required under the Conduct of Employment Agencies and Employment Businesses Regulations 2003.
• Where all required qualifications, authorisations or references cannot be obtained despite all reasonably practicable steps having been taken, comply with the statutory notification requirements before any supply is made, including informing the client of the information that could not be obtained and the steps taken to obtain it.
• Take all other reasonably practicable steps required under Regulation 22 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003 to establish that a temporary worker proposed for work with vulnerable persons is not unsuitable for the position.
• Carry out the right to work checks required by applicable immigration legislation and Home Office requirements before the worker commences work, together with any required follow-up checks where a person’s permission to work is time-limited.
• Undertake appropriate Disclosure and Barring Service and barred-list checks where the work is eligible and the applicable legal requirements require or permit such checks.
• Check the status of any professional registration required for the assignment and take appropriate steps where registration, authorisation or fitness to practise status changes.
• Maintain records required by the Conduct of Employment Agencies and Employment Businesses Regulations 2003 and other applicable legislation.
• Ensure workers receive information and induction concerning {{org_field_name}}’s professional conduct expectations before undertaking assignments.
• Provide appropriate support to temporary workers concerning their contractual relationship with {{org_field_name}} and matters falling within the agency’s responsibilities.
• Respond to information received indicating that a temporary worker may be unsuitable for a position and make the enquiries and notifications required by the Conduct of Employment Agencies and Employment Businesses Regulations 2003.
• Where {{org_field_name}} has reasonable grounds to believe that a temporary worker being supplied is unsuitable for the position, inform the client without delay and cease supplying the worker to that client in accordance with the applicable legal requirements.
• Manage complaints, conduct concerns and contractual matters concerning temporary workers without taking over the client’s responsibility for directing, managing or clinically supervising the work performed during an assignment.
• Comply with the Agency Workers Regulations 2010 and take the steps falling within the employment business’s responsibility to ensure qualifying agency workers receive applicable statutory entitlements.

14. Director’s Responsibilities

The director, or a suitably authorised manager designated by the director, will:

• Have overall responsibility for the implementation, monitoring and review of this policy.
• Ensure that appropriate systems are maintained to support compliance with the legal obligations applying to {{org_field_name}} as an employment business.
• Ensure temporary workers are informed of this policy and of the standards of professional conduct expected while undertaking assignments.
• Ensure concerns regarding a temporary worker’s conduct, suitability, professional registration or safeguarding risk are considered promptly and appropriate action is taken.
• Ensure complaints concerning the professional behaviour or conduct of temporary workers are appropriately investigated.
• Ensure the client is informed without delay where the law requires {{org_field_name}} to disclose information concerning a temporary worker’s suitability.
• Ensure any statutory notification or referral arising from a conduct or safeguarding matter is considered and made where the relevant legal threshold is met.
• Liaise with clients concerning matters relating to worker conduct, attendance, suitability and contractual performance while respecting the client’s responsibility for the day-to-day direction and control of the work undertaken at the client’s service.
• Ensure that {{org_field_name}} does not assume responsibility for directing, supervising or managing the regulated care or clinical activity undertaken by temporary workers within client organisations.
• Promote a culture of professionalism, lawful practice, safeguarding, respect and accountability.

15. Client Relationships

Temporary workers must:

• Cooperate with applicable client policies, procedures, systems of work and lawful and reasonable instructions relevant to the assignment.
• Complete any client-specific induction required before or during the assignment.
• Work within the duties, responsibilities and level of competence authorised for the assignment.
• Seek appropriate guidance from the client’s designated manager, nurse in charge, clinical lead or other authorised person where clarification regarding the work or care being provided is required.
• Follow the client’s appropriate escalation procedures where there is a concern relating to a service user’s health, welfare or safety.
• Report safeguarding concerns in accordance with applicable safeguarding procedures and notify {{org_field_name}} where required.
• Use the applicable whistleblowing procedure where a concern meets the relevant criteria.
• Raise concerns concerning client staff or practices professionally and through the appropriate reporting or escalation route rather than through inappropriate public criticism.
• Inform {{org_field_name}} promptly about material concerns affecting the suitability, safety or continuation of an assignment.

{{org_field_name}} will:

• Work collaboratively with client organisations in relation to the supply and conduct of temporary workers.
• Obtain and communicate the information concerning assignments that it is required to obtain or provide under applicable employment agency legislation.
• Respond promptly and appropriately to client concerns or complaints concerning a supplied worker.
• Take appropriate action where information received raises a question concerning a worker’s suitability for an assignment.
• Support workers in understanding the client’s assignment requirements and facilitate access to relevant client-specific induction information.
• Manage matters falling within {{org_field_name}}’s responsibilities as the employment business, including contractual conduct, attendance and suitability issues.
• Not undertake the client’s clinical governance responsibilities or assume day-to-day responsibility for directing or supervising the regulated care or clinical work undertaken by a temporary worker during the assignment.

16. Training and Conduct Monitoring

{{org_field_name}} will:

• Provide temporary workers with appropriate induction concerning the agency’s professional conduct, safeguarding, health and safety, confidentiality and information governance expectations relevant to their role.
• Ensure that, before supply, workers have evidence of the training, experience, qualifications and authorisations required by law, a professional body or the client for the particular assignment, insofar as required by applicable legislation.
• Monitor matters falling within {{org_field_name}}’s responsibility through client feedback, incident information, complaints, worker communication and appropriate compliance reviews.
• Require additional training, competency evidence or other appropriate action where this is necessary before a worker can lawfully or safely continue to be supplied to a particular type of assignment.
• Maintain appropriate records of training, qualifications, authorisations and enquiries where required by law.
• Distinguish agency conduct management from clinical or operational supervision. Clinical direction, workplace supervision and management of the care or treatment provided during an assignment remain the responsibility of the client organisation where those matters fall within the client’s regulated service.

Temporary workers must:

• Complete training required for the work they are supplied to undertake.
• Maintain any qualification, registration or authorisation required for their role.
• Inform {{org_field_name}} immediately of any restriction, suspension, condition, investigation or other material change affecting a professional registration or authorisation required for an assignment.
• Apply relevant training and professional standards while undertaking assignments.
• Work within their competence and seek appropriate assistance from the client where they are unsure how to undertake a task safely or lawfully.

17. Breaches of Policy

Any alleged breach of this policy will be considered promptly and proportionately. Depending upon the nature and seriousness of the concern, action may include:

• Investigation by {{org_field_name}}.
• Immediate communication with the client where necessary to protect service users, workers or other persons or where disclosure is otherwise required by law.
• Suspension from, or removal from, a particular assignment while enquiries are undertaken, where appropriate.
• Cessation of supply to a client where {{org_field_name}} has reasonable grounds to believe that the worker is unsuitable for the position and cessation is required by applicable employment agency legislation.
• Additional training or a requirement to provide further evidence of competence before undertaking further relevant assignments.
• Formal action in accordance with the worker’s applicable contract and employment or worker status.
• Termination of employment or engagement where justified and lawfully permitted by the applicable contract and employment status.
• Referral or notification to a professional regulator, including the Nursing and Midwifery Council where applicable and where the relevant reporting criteria are met.
• Referral to the Disclosure and Barring Service where {{org_field_name}} is under a statutory duty to make a barring referral.
• Notification to the police, local authority safeguarding service, client organisation, Fair Work Agency or another competent authority where reporting is required or otherwise lawfully appropriate.

Disclosure and Barring Service referrals

Where {{org_field_name}} acts as a personnel supplier in respect of regulated activity, it will assess whether the statutory conditions for a referral to the Disclosure and Barring Service are met.

Where the applicable statutory conditions are satisfied, {{org_field_name}} will make the required DBS referral. This duty is separate from any referral or notification made to a client organisation, local authority safeguarding service, police or professional regulator and will not be treated as discharged merely because another organisation has been notified.

Where a worker has ceased performing regulated activity before {{org_field_name}} has completed its consideration of the matter, including through resignation or the ending of an assignment, {{org_field_name}} will still consider whether the statutory DBS referral duty applies on the basis that it would or might otherwise have removed the worker from regulated activity.

18. Continuous Improvement

The director will:

• Review this policy annually or sooner if required by changes in legislation, guidance, or incidents
• Analyze complaints, incidents, and client feedback relating to conduct and professional image
• Use findings to update training, procedures, and policy content
• Promote reflective practice and professional learning for all temporary workers

19. Policy Review

This policy will be reviewed at least annually by the director of {{org_field_name}}, and sooner where required because of a material change in legislation, statutory guidance, the nature of the agency’s activities, safeguarding requirements or other relevant operational circumstances.

The review will have regard, where relevant, to changes affecting employment businesses and temporary workers, including employment agency legislation, agency worker rights, employment rights, safeguarding and Disclosure and Barring Service requirements, immigration and right to work requirements, equality law, data protection law, working time and health and safety requirements.

Changes to requirements applying to CQC-registered client organisations will be considered insofar as they affect the standards, qualifications, information or conduct required of workers supplied to those organisations. They will not be treated as making {{org_field_name}} a CQC-registered provider unless the nature of {{org_field_name}}’s activities changes so that registration is legally required.

All material amendments affecting temporary workers will be communicated to the relevant workers and, where appropriate, to client organisations.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.