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{{org_field_name}}

Registration Number: {{org_field_registration_no}}


Recruitment Record Keeping Policy

1. Purpose

The purpose of this policy is to establish a clear, robust, and legally compliant framework for the management and retention of recruitment records at {{org_field_name}}. As a temporary healthcare staffing agency supplying registered nurses, healthcare assistants, and other healthcare workers to care homes and healthcare environments, {{org_field_name}} is legally and ethically obliged to maintain accurate and secure records of all recruitment activities. These records provide evidence that all workers supplied meet the required professional, regulatory, and legal standards, and are suitable to deliver safe and effective care. Proper record keeping is critical to safeguarding service users, maintaining the integrity of the recruitment process, and complying with national legislation including the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, the Care Quality Commission (CQC) Fundamental Standards, the Data Protection Act 2018 and UK GDPR, the Employment Rights Act 1996, and the Immigration, Asylum and Nationality Act 2006.

2. Scope

This policy applies to: All registered nurses, healthcare assistants, and temporary workers who apply to or are employed by {{org_field_name}}. All directors and office-based staff involved in recruitment, onboarding, compliance, and placement activities. All records created or maintained during the recruitment, induction, and registration processes, whether in paper or electronic formats. The management of records relating to prospective applicants, successful candidates, unsuccessful applicants, self-employed workers, and limited company workers engaged through the agency.

3. Related Policies

4. Policy Statement

{{org_field_name}} is committed to: Maintaining secure, accurate, and complete recruitment records for all applicants and workers. Complying with all legal and regulatory requirements for the storage, access, and retention of recruitment records. Ensuring that records are readily available for inspection by regulatory bodies such as the CQC or for internal audits. Protecting the confidentiality and privacy of applicants and staff at all times. Using recruitment records solely for lawful and appropriate purposes related to recruitment, safeguarding, and regulatory compliance.

5. Responsibilities

Directors The directors of {{org_field_name}} will: Take responsibility for the effective implementation of this policy. Ensure that recruitment records meet CQC and statutory requirements. Oversee regular audits of recruitment records to check for completeness, accuracy, and security. Ensure that records are stored securely and are only accessible to authorised personnel. Manage the secure disposal of recruitment records in line with legal and regulatory requirements. Review this policy annually or sooner if needed.

Recruitment and Compliance Staff Staff involved in recruitment will: Ensure all recruitment records are accurately completed, dated, signed, and filed. Promptly collect, verify, and record evidence of applicants’ identity, qualifications, DBS checks, references, right to work, and all other required information. Handle recruitment records confidentially and only access them where authorised to do so. Report any missing, incomplete, or out-of-date documentation to the directors immediately.

6. Required Recruitment Records

The following documents must be collected and retained for each applicant, including self-employed and limited company workers: Completed application form. Up-to-date curriculum vitae (CV). Proof of identity (valid passport, photo ID, or other accepted document). Proof of right to work in the UK. Enhanced DBS certificate number and status (and DBS update service check where applicable). Verified references from previous employers (minimum of two, covering at least three years). Proof of qualifications and professional registration (e.g., NMC PIN). Mandatory training records and certificates. Interview records. Occupational health clearance (where applicable). Signed declarations (e.g., criminal convictions, health declaration). Signed contract, service agreement, or terms and conditions. Record of induction and any additional role-specific assessments.

7. Storage of Recruitment Records

Recruitment records must be: Stored securely in locked cabinets (for paper records) or encrypted and access-controlled systems (for electronic records). Accessible only to authorised personnel with a legitimate business need. Protected against unauthorised access, loss, theft, or damage. Stored separately from unrelated information to maintain organisation and ensure ease of retrieval. Backed-up regularly (for electronic records) to ensure records are recoverable in the event of a technical failure.

8. Data Protection and Confidentiality

{{org_field_name}} will comply fully with the Data Protection Act 2018 and UK GDPR by ensuring that: Personal data collected during recruitment is processed lawfully, fairly, and transparently. Data is collected for legitimate purposes and not processed in a manner incompatible with those purposes. Records are accurate, relevant, and kept up to date. Records are stored securely and retained only for as long as necessary. Applicants are informed of how their data will be used, stored, and retained as part of the application process. Access to recruitment records is limited strictly to those who require it to fulfil their role.

9. Retention of Recruitment Records

Recruitment records will be retained as follows: Successful applicants: Recruitment records will be retained for the duration of employment and for six years following termination of employment, in line with statutory limitations. Unsuccessful applicants: Records will be retained for six months following the recruitment decision, unless consent is given to retain them for longer for future opportunities. DBS certificates: {{org_field_name}} will not retain copies of DBS certificates but will record certificate numbers, issue dates, and check results. ID verification: Copies of documents used for right-to-work checks will be retained for two years after the employment ends, in line with Home Office guidance.

10. Access to Records

Records may be accessed: By directors, recruitment staff, or authorised personnel as required to perform their role. By regulatory bodies (e.g., CQC, HMRC, Home Office) during audits or inspections. By the individual to whom the record relates, upon written request in accordance with data subject access rights under UK GDPR. Information will not be disclosed to third parties without the consent of the individual, unless required by law.

11. Auditing and Quality Assurance

The directors of {{org_field_name}} will: Carry out regular audits of recruitment files and records to ensure compliance with this policy. Address any shortfalls through additional staff training or corrective action. Maintain audit records to demonstrate compliance during external inspection.

12. Staff Training

All relevant staff will receive training on: The principles of safe and lawful record keeping. The importance of data protection and confidentiality in handling recruitment records. Correct procedures for collecting, recording, storing, and disposing of recruitment records. Training will be refreshed regularly and monitored through supervision and appraisal.

13. Secure Disposal of Recruitment Records

At the end of the required retention period, recruitment records will be securely disposed of by: Shredding or secure confidential waste services (for paper records). Secure deletion from electronic systems, including backup systems, ensuring irretrievability. A record of disposal will be maintained for audit purposes.

14. Equality and Diversity

{{org_field_name}} will ensure that: Recruitment records are handled fairly and without bias. No information will be used in a way that discriminates unlawfully against any individual. All recruitment records will be processed in accordance with the Equality Act 2010.

15. Continuous Improvement

{{org_field_name}} is committed to continually improving its recruitment record keeping by: Incorporating lessons learned from audits, complaints, or incidents. Updating processes to reflect changes in legislation, regulatory guidance, or best practice. Seeking feedback from clients, regulatory bodies, and staff.

16. Policy Review

This policy will be reviewed at least annually or earlier if: Changes occur in relevant legislation or guidance. Feedback suggests that the recruitment record keeping process requires improvement. Findings from audits or inspections indicate the need for revision.


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.

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